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Treasury OIG: Semiannual Report to Congress, October 1, 2019 – March 31, 2020 (OIG-CA-20-017)

Summary

This Treasury Office of Inspector General Semiannual Report to Congress (OIG-CA-20-017) covers October 1, 2019 to March 31, 2020. In the period the Office of Audit issued 44 products with $2,550 in questioned costs, and work by the Office of Investigations resulted in 11 indictments and 11 convictions. Highlights include an audit that found two instances where Senior Executive Service basic pay was higher than Federal regulations permitted, and a review of the Bureau of Engraving and Printing's work on the NexGen $100 note, including the 1.4 billion notes produced in 2010. Deputy Inspector General Richard K. Delmar's message describes the CARES Act, signed on March 27, 2020, which gave Treasury OIG oversight of payroll support for airlines and funds for state, local, and tribal governments, and established SIGPR and the PRAC.

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“Treasury OIG: Semiannual Report to Congress, October 1, 2019 – March 31, 2020 (OIG-CA-20-017).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/semiannual-report-to-congress-mar-2020-07e47a6f40/, SHA-256 0e7bd8c6eaaa0a0716d2ad4bdb63353e8ff4285292ac328060ded338186a69ca.

Full text

Semiannual Report to Congress
October 1, 2019 – March 31, 2020
OIG-CA-20-017

Office of Inspector General
Department of the Treasury
Highlights
During this semiannual reporting period, our Office of Audit issued 44 products with
$2,550 in questioned costs. Work by our Office of Investigations resulted in 11
indictments and 11 convictions. Some of our more significant results for the period are
described below:

 • Independent public accounting firms, working under contracts with and
    supervised by our Office of Audit, issued unmodified opinions on the Department
    of the Treasury’s (Treasury) consolidated financial statements and the Gulf Coast
    Ecosystem Restoration Council’s financial statements for fiscal year 2019.
 • In our audit of Treasury Departmental Offices executive pay adjustments,
    bonuses, and awards, we identified two instances where the Senior Executive
    Service (SES) rate of basic pay was higher than the rate permitted by Federal
    regulations during a gap in Treasury’s SES performance appraisal system
    certification in 2016, resulting in overpayments for two individuals and estimated
    questioned costs totaling $2,550.
 • In our review of corrective actions taken by the Bureau of Engraving and Printing
    (BEP) to improve its project management related to the production of the Next
    Generation (NexGen) $100 note, we found that BEP (1) was unable to provide
    complete documentation on production validations and had stopped production at
    its Washington, DC Facility after finding a new issue that impacted the quality of
    the notes; (2) had implemented a Currency Quality Assurance Program and
    increased its capabilities in project management, but had not redesigned a new
    note since the NexGen $100 and had not documented all procedures that are to
    be followed under new processes; (3) had not completed the required 5 year
    update to its memorandum of understanding with the Board of Governors of the
    Federal Reserve System; and (4) had completed an analysis for the disposition of
    the 1.4 billion NexGen $100 notes produced in 2010, but could not provide
    detailed documentation to support the analysis or an update to its cost estimate
    to reflect actual amounts resulting from the disposition of the notes.
 • Our joint investigation with the Federal Bureau of Investigation identified a subject
    who initiated Denial of Service attacks on local and Federal Government websites.
    The subject was sentenced to 60 months of incarceration, 36 months of
    probation, and $669,000 in restitution in U.S. District Court, Northern District of
    Ohio Eastern Division.
 • Our investigation determined that a subject deposited counterfeit financial
    institution checks in various bank accounts and used fraudulently obtained debit
    cards to withdraw funds. The subject was sentenced to 58 months of
    incarceration, 36 months of probation, and $4,400 in restitution for Bank Fraud
    and Aggravated Identity Theft in the Middle District of North Carolina.

      Treasury Office of Inspector General Semiannual Report—March 2020       i
Message from the Inspector General
We are all navigating the challenges brought on by the 2020 coronavirus (COVID-19)
pandemic. Individuals, families, and businesses are affected by the virus. Many are in need
of assistance, whether it is health care assistance caused by illness or financial assistance
resulting from disruptions to their livelihoods. Regardless of the challenges, all of us are
making adjustments in our lives, from checking in on elderly neighbors and friends at a safe
social distance, to taking care of children and family members. We are all adapting to this
evolving situation.

On March 27, 2020, the President signed into law the Coronavirus Aid, Relief, and
Economic Security Act (CARES Act) to provide emergency assistance and health care
response for individuals, families, and businesses affected by the 2020 COVID-19
pandemic. Among other things, the CARES Act,

 • Authorizes Department of the Treasury (Treasury) Office of Inspector General (OIG) to
    oversee two programs within the CARES Act’s scope: a program that provides payroll
    support to passenger and cargo airlines and their contractors; and a larger program
    disbursing funds to state, local, and tribal governments.
 • Establishes a Special Inspector General (IG) for Pandemic Recovery (SIGPR) within
    Treasury. This Special IG will be Senate confirmed and will have many oversight
    responsibilities. SIGPR is scheduled to sunset in five years.
 • Establishes the Pandemic Response Accountability Committee (PRAC) within the
    Council of the Inspectors General on Integrity and Efficiency (CIGIE). The committee is
    to coordinate oversight of the pandemic legislation’s operation, and can support
    individual OIGs in their work. Treasury OIG is one of nine OIGs specified as members
    of the committee.

While my office has changed how we work to adapt to this situation, we continue to serve
the public. This Treasury OIG Semiannual Report to Congress for the 6-month period ended
March 31, 2020, is a testament to my staff’s dedication to service. I would like to express
my appreciation to all Treasury OIG staff for making possible the significant audit and
investigative results that are summarized in this Semiannual Report, and to Congress and
Treasury for their sustained commitment to the important work carried out by our office in
this challenging environment.

Richard K. Delmar



Deputy Inspector General

      Treasury Office of Inspector General Semiannual Report—March 2020       ii
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Contents
Highlights ......................................................................................... i
Message from the Inspector General .................................................... ii
Treasury Office of Inspector General Overview .................................... 1
Management and Performance Challenges ........................................... 5
Office of Audit – Significant Audits and Other Products ........................ 7
    Financial Management ............................................................................................ 7
    Cyber/Information Technology ............................................................................... 10
    DATA Act ........................................................................................................... 13
    RESTORE Act ...................................................................................................... 15
    Small Business Jobs Act ....................................................................................... 16
    Resource Management.......................................................................................... 17
    Manufacturing ..................................................................................................... 19
    Debt Management ................................................................................................ 22

Office of Investigations – Significant Investigations ............................ 27
Other Treasury OIG Accomplishments and Activities .......................... 31
Statistical Summary ........................................................................ 33
    Summary of Treasury OIG Activities ....................................................................... 33
    Metrics Used for Office of Investigations Activities ................................................... 33
    Reports with Unimplemented Recommendations ...................................................... 34
    Closed Investigations of Senior Government Employees Not Publicly Disclosed ............ 41
    Summary of Instances of Whistleblower Retaliation .................................................. 42
    Summary of Attempts to Interfere With Treasury OIG Independence, Including Instances
    Where Information or Assistance Request was Refused............................................. 42
    Listing of Audit Products Issued ............................................................................. 43
    Audit Reports Issued With Questioned Costs ........................................................... 47
    Audit Reports Issued With Recommendations that Funds Be Put to Better Use ............. 48
    Reports for Which No Management Comment was Returned Within 60 Days ............... 49
    Reports Issued Over 6 Months for Which No Management Decision Has Been Made ..... 49
    Significant Revised Management Decisions .............................................................. 49
    Significant Disagreed Management Decisions ........................................................... 49

       Treasury Office of Inspector General Semiannual Report—March 2020                                     iv
                                                                                                            Contents

    Peer Reviews ....................................................................................................... 50

Other Reporting Requirements and Requests ...................................... 53
References to the Inspector General Act............................................ 57
Abbreviations ................................................................................. 59




       Treasury Office of Inspector General Semiannual Report—March 2020                                     v
Treasury Office of Inspector General Overview
The Department of the Treasury’s (Treasury) Office of Inspector General (OIG) was
established pursuant to the 1988 amendments to the Inspector General Act of 1978.
Treasury OIG is headed by an Inspector General appointed by the President with the
advice and consent of the Senate.

Treasury OIG performs independent, objective reviews of Treasury programs and
operations, except for those of the Internal Revenue Service (IRS) and the Troubled
Asset Relief Program (TARP), and certain aspects of Pandemic Recovery, and keeps
the Secretary of the Treasury and Congress fully informed of problems, deficiencies,
and the need for corrective action. The Treasury Inspector General for Tax
Administration (TIGTA) and the Government Accountability Office (GAO) perform
oversight related to IRS. A Special Inspector General and GAO perform oversight
related to TARP. The Special Inspector General for Pandemic Recovery (SIGPR) will
perform oversight related to certain Treasury operations for Pandemic recovery as
identified in the Coronavirus Aid, Relief, and Economic Security Act (CARES Act).

Treasury OIG also performs independent oversight of programs and operations funded
by the Gulf Coast Restoration Trust Fund (Trust Fund) established within Treasury by
the Resources and Ecosystems Sustainability, Tourist Opportunities, and Revived
Economies of the Gulf Coast States Act of 2012 (RESTORE Act). In addition to
performing oversight of Treasury-related activities, Treasury OIG performs oversight of
programs and operations administered by the Gulf Coast Ecosystem Restoration
Council (Council), established as an independent Federal entity, and the Gulf Coast
Ecosystem Restoration Science, Observation, Monitoring, and Technology Program
(Science Program) administered by the National Oceanic and Atmospheric
Administration (NOAA). With regard to the Council and the Science Program, Treasury
OIG keeps the appointed Chairperson of the Council, the NOAA Science Program
Administrator, and Congress fully informed of problems, deficiencies, and the need for
corrective actions.

Treasury OIG has four components: (1) Office of Audit; (2) Office of Investigations;
(3) Office of Counsel; and (4) Office of Management. Treasury OIG is headquartered in
Washington, DC. Treasury OIG also has an audit office in Boston, Massachusetts.

The Office of Audit, under the leadership of the Assistant Inspector General for Audit,
performs and supervises financial and performance audits, attestation engagements,
and evaluations. The Assistant Inspector General for Audit also serves as the Special


      Treasury Office of Inspector General Semiannual Report—March 2020       1
                                         Treasury Office of Inspector General Overview

Deputy Inspector General for Small Business Lending Fund (SBLF) Program Oversight.
Under the Assistant Inspector General for Audit, there are three deputies. The first
deputy is primarily responsible for financial sector audits to include audits of banking
supervision, manufacturing of currency and coins, resource management, and alcohol
and tobacco excise tax revenue collection activities. The second deputy is primarily
responsible for financial management and transparency audits to include financial
audits of Treasury and the Council performed by Treasury OIG staff and contractors,
audits of Government-wide collection, payment, and debt programs and operations,
and audits of anti-money laundering/terrorist financing, foreign sanction, and audits of
intelligence programs and operations. The third deputy is primarily responsible for
cybersecurity, procurement, and financial assistance audits to include audits of
Treasury and the Council information systems performed by Treasury OIG staff and
contractors, audits of the SBLF program, RESTORE Act program, and CARES Act
programs and operations.

The Office of Investigations, under the leadership of the Assistant Inspector General
for Investigations, performs investigations and conducts initiatives to detect and
prevent fraud, waste, and abuse in programs and operations across Treasury OIG’s
jurisdictional boundaries; and to investigate threats against Treasury personnel and
assets in designated circumstances as authorized by the Inspector General Act. The
Office of Investigations also manages the Treasury OIG Hotline to facilitate the
reporting of allegations involving these programs and operations.

The Office of Counsel, under the leadership of the Counsel to the Inspector General,
provides legal advice to the Inspector General and all Treasury OIG components. The
office represents Treasury OIG in administrative legal proceedings and provides a
variety of legal services, including (1) processing Freedom of Information Act and
Giglio 1 requests; (2) conducting ethics training; (3) ensuring compliance with financial
disclosure requirements; (4) reviewing proposed legislation and regulations;
(5) reviewing administrative subpoena requests; and (6) preparing for the Inspector
General’s signature, cease and desist letters and monetary assessments against
persons and entities misusing the Treasury seal and name. The Office of Counsel also
responds to media and Congressional inquiries and serves as the Whistleblower
Protection Coordinator for Treasury.

The Office of Management, under the leadership of the Assistant Inspector General for
Management, provides administrative services to maintain the Treasury OIG

1
    Giglio information refers to material that may call into question the character or testimony of a
    prosecution witness in a criminal trial.

        Treasury Office of Inspector General Semiannual Report—March 2020                       2
                                   Treasury Office of Inspector General Overview

administrative infrastructure, including facilities, human resources, information
technology, procurement, records management, and security.

Treasury OIG’s fiscal year 2020 appropriation is $41 million. Treasury OIG’s oversight
of the SBLF program is funded on a reimbursable basis. As of March 31, 2020,
Treasury OIG had 147 full-time staff.




      Treasury Office of Inspector General Semiannual Report—March 2020         3
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Management and Performance Challenges
The Reports Consolidation Act of 2000 requires that the Department of the Treasury
(Treasury) Inspector General annually provide his perspective on the most serious
management and performance challenges facing Treasury and the Gulf Coast
Ecosystem Restoration Council (Council). The following is a synopsis of our annual
assessments, which are available in their entirety, on the Treasury Office of Inspector
General (OIG) website.

      Treasury
      In an October 15, 2019, memorandum to Secretary of the Treasury Steven
      Mnuchin, Acting Inspector General Richard Delmar reported the following four
      challenges facing the Department that were repeated from the prior year.

          • Operating in an Uncertain Environment
          • Cyber Threats
          • Anti-Money Laundering/ Terrorist Financing and Bank Secrecy Act
             Enforcement
          • Efforts To Promote Spending Transparency and To Prevent and Detect
             Improper Payments
      We also reported a new challenge related to IT acquisition and project
      management.

      Gulf Coast Ecosystem Restoration Council
      In an October 1, 2019, letter to the Honorable Andrew Wheeler, Administrator
      of the Environmental Protection Agency, as Chairperson of the Gulf Coast
      Ecosystem Restoration Council, we reported two challenges that were repeated
      from the prior year.

          • Federal Statutory and Regulatory Compliance
          • Grant and Interagency Agreement Compliance Monitoring
      .




      Treasury Office of Inspector General Semiannual Report—March 2020        5
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Office of Audit – Significant Audits and Other Products
Financial Management
Treasury’s Consolidated Financial Statements

KPMG LLP (KPMG), a certified independent public accounting firm working under a
contract with and supervised by our office, issued an unmodified opinion on the
Department of the Treasury’s (Treasury) fiscal years 2019 and 2018 consolidated
financial statements. KPMG reported (1) a significant deficiency in internal control over
cash management information systems and a significant deficiency in internal control
over Federal debt information systems at the Bureau of the Fiscal Service (Fiscal
Service), collectively representing a significant deficiency for Treasury as a whole, and
(2) a significant deficiency in internal control over unpaid tax assessments and a
significant deficiency in internal control over financial reporting systems at the Internal
Revenue Service (IRS), collectively representing a significant deficiency for Treasury as
a whole. KPMG also reported that Treasury’s financial management systems did not
substantially comply with certain requirements of the Federal Financial Management
Improvement Act of 1996 (FFMIA) related to federal financial management systems
requirements. KPMG found no other instances of reportable noncompliance with laws,
regulations, contracts, and grant agreements tested. (OIG-20-012)

In connection with its audit of Treasury’s consolidated financial statements, KPMG
issued a management report, which provided the specific findings and
recommendations pertaining to the significant deficiency in internal control over cash
management information systems and the related noncompliance with FFMIA’s federal
financial management systems requirements at Fiscal Service that were summarized in
the auditor’s report. (OIG-20-022) Additionally, KPMG issued a management letter
recommending improvements to strengthen internal control over financial reporting
with respect to terminating user access, implementing a segregation of duties matrix
for the Federal Analysis and Reporting System user account roles, evaluating
compliance with the Federal Managers Financial Integrity Act of 1982, documenting
the preparation and review of a reconciliation, and reviewing year-end balances
submission. (OIG-20-015)

Other Treasury Financial Audits

The Chief Financial Officers Act of 1990, as amended by the Government
Management Reform Act of 1994, requires annual financial statement audits of
Treasury and any component entities designated by the Office of Management and

      Treasury Office of Inspector General Semiannual Report—March 2020          7
                                Office of Audit – Significant Audits and Other Products

Budget (OMB). In this regard, OMB designated IRS for annual financial statement
audits. The financial statements of certain other Treasury component entities are
audited either pursuant to other requirements, their materiality to Treasury’s
consolidated financial statements, or as a management initiative. The table below
shows the audit results for fiscal years 2019 and 2018.
 Treasury-audited financial statements and related audits
                            Fiscal year 2019 audit results                Fiscal year 2018 audit results
                                       Material                                      Material
                                       weak-    Significant                          weak-    Significant
 Entity                     Opinion    nesses   deficiencies              Opinion    nesses   deficiencies
 Government Management Reform Act/Chief Financial Officers Act requirements
 Department of the Treasury             U            0                2           U           0                 2
 Internal Revenue Service (A)           U            0                2           U           0                 2
 Other required audits
 Department of the Treasury’s
 Closing Package Financial
 Statements                            (B)         (B)              (B)           U           0                 0
 Office of Financial Stability
 (TARP) (A)                             U            0                0           U           0                 0
 Bureau of Engraving and
 Printing                              (C)         (C)              (C)           U           0                 0
 Community Development
 Financial Institutions Fund            U            0                0           U           0                 0
 Office of D.C. Pensions                U            0                0           U           0                 0
 Federal Financing Bank                 U            0                0           U           0                 0
 Treasury Forfeiture Fund               U            0                0           U           0                 0
 U.S. Mint
   Financial Statements                 U            0                0           U           0                 1
   Custodial Gold and Silver
   Reserves                             U            0                0           U           0                 0
 Other audited accounts/financial statements that are material to Treasury’s financial statements
 Bureau of the Fiscal Service
   Schedule of Federal Debt
   (A)                                  U            0                1           U           0                 1
 Exchange Stabilization Fund            U            0                0           U           0                 0
 Management-initiated audits
 Office of the Comptroller of
 the Currency                           U           0               0            U             0                0
 Alcohol and Tobacco Tax and
 Trade Bureau                           U           0               0            U             0                0
 U.S. Gold Reserves Held by
 Federal Reserve Banks                  U           0               0            U             0                0
 U    Unmodified opinion.
 (A) Audited by the Government Accountability Office.
 (B) Department of the Treasury’s Closing Package Financial Statements was not required for fiscal year 2019.
 (C) Audit was in progress as of March 31, 2020.



        Treasury Office of Inspector General Semiannual Report—March 2020                          8
                             Office of Audit – Significant Audits and Other Products

In connection with the fiscal year 2019 financial statement audits, the auditors issued
management letters on other matters involving internal control at the Federal Financing
Bank (OIG-20-010) and the United States Mint (Mint) (OIG-20-017).

Gulf Coast Ecosystem Restoration Council’s Financial Statements

The audit of the Gulf Coast Ecosystem Restoration Council’s (Council) financial
statements is also required by the Chief Financial Officers Act of 1990, as amended
by the Accountability of Tax Dollars Act of 2002. RMA Associates, LLC (RMA), a
certified independent public accounting firm working under a contract with and
supervised by our office, issued an unmodified opinion on the Council’s fiscal years
2019 and 2018 financial statements. RMA did not identify any matters involving
internal control and its operation that are considered material weaknesses.
Additionally, RMA did not identify any instances of reportable noncompliance with
laws, regulations, contracts, and grant agreements tested. (OIG-20-013)

Federal Financial Management Improvement Act

The following instances of noncompliance with the Federal Financial Management
Improvement Act of 1996, were reported in connection with the audit of Treasury’s
fiscal year 2019 consolidated financial statements.

                                                                                              Type of
 Condition                                                                                    noncompliance
 Treasury continues to have deficiencies in IRS financial management systems.                 Federal financial
 Specifically, IRS did not consistently design, implement, and operate information system     management system
 controls and security programs over its financial management systems in accordance           requirements
 with the federal financial management systems requirements. (first reported in fiscal year
 1997)
 Treasury has deficiencies in Fiscal Service Government-wide cash and federal debt            Federal financial
 management information systems. Specifically, Fiscal Service did not consistently design,    management system
 implement, and operate information system controls and security programs over its cash       requirements
 management and federal debt information systems in accordance with the federal
 financial management systems requirements. (first reported in fiscal year 2018)


The status of these instances of noncompliance, including progress in implementing
remediation plans, will be evaluated as part of the audit of Treasury’s fiscal year 2020
consolidated financial statements.




        Treasury Office of Inspector General Semiannual Report—March 2020                            9
                       Office of Audit – Significant Audits and Other Products


Cyber/Information Technology
FISMA

The Federal Information Security Modernization Act of 2014 (FISMA) requires
Inspectors General to perform an annual, independent evaluation of their agency’s
information security program and practices. During this semiannual reporting period,
we issued reports on Treasury’s and the Gulf Coast Ecosystem Restoration Council’s
(Council) compliance with FISMA.

      Fiscal Year 2019 Audit of Treasury’s Information Security Program
      for its Unclassified Systems

      KPMG, a certified independent public accounting firm working under a contract
      with and supervised by our office, performed an audit of Treasury’s information
      security program and practices for its unclassified systems. The Treasury
      Inspector General for Tax Administration (TIGTA) performed the annual FISMA
      evaluation of IRS’ unclassified systems. For fiscal year 2019, KPMG determined
      that Treasury’s information security program and practices for its unclassified
      systems were established and have been maintained for the 5 cybersecurity
      functions and 8 FISMA metric domains. However, the program was not
      effective. KPMG identified 4 deficiencies within 1 of the 5 cybersecurity
      functions and within 4 of the 8 FISMA metric domains. Specifically, KPMG
      reported the following at one or more Treasury component entity:

        • controls over security baseline configurations, vulnerability scanning, and
            flaw remediation were not consistently followed (2 component entities);
        • access management, personnel screening, and data encryption controls
            were not fully implemented (3 component entities);
        • a privacy program was not fully established (1 component entity); and
        • specialized security training requirements were not consistently
            implemented (1 component entity).

      KPMG made 14 recommendations to the responsible officials to address the
      identified deficiencies. Treasury management agreed with the recommendations
      and prepared corrective action plans that met the intent of KPMG’s
      recommendations. (OIG-20-003)




      Treasury Office of Inspector General Semiannual Report—March 2020      10
                 Office of Audit – Significant Audits and Other Products

Fiscal Year 2019 Audit of Treasury’s Information Security Program
for its Collateral National Security Systems

KPMG, working under a contract with and supervised by our office, also
performed an audit of Treasury’s information security program and practices for
its collateral National Security Systems (NSS). For fiscal year 2019, KPMG
reported that Treasury established and maintained its information security
program and practices for its collateral NSS for the 5 cybersecurity functions
and 8 FISMA metric domains. However, the program was not effective. KPMG
identified 1 deficiency within 1 of the 5 cybersecurity functions and within 1 of
the 8 FISMA metric domains at 1 component entity. KPMG made 1
recommendation to responsible officials to address the identified deficiency.
Treasury management agreed with the recommendation and prepared a
corrective action plan that met the intent of KPMG’s recommendations. Due to
the sensitive nature of these systems, this report is designated Sensitive But
Unclassified. (OIG-20-002, Sensitive But Unclassified)

Fiscal Year 2019 Audit of Treasury’s Information Security Program
for Its Intelligence Systems

In our fiscal year 2019 audit of Treasury’s information security program and
practices for its intelligence systems, we reported an unresolved issue from the
prior year’s audit and identified new matters that require management’s
attention. Treasury management agreed with the recommendations made in our
report. Due to the sensitive nature of Treasury’s intelligence systems, this report
is classified. (OIG-20-004, Classified)

Fiscal Year 2019 Evaluation of the Gulf Coast Ecosystem
Restoration Council’s Information Security Program

RMA, a certified independent public accounting firm working under a contract
with and supervised by our office, performed this year’s annual FISMA
evaluation of the Council’s information security program and practices for the
period July 1, 2018 through June 30, 2019. RMA reported that the Council’s
information security program and practices were established and have been
maintained for the 5 cybersecurity functions and 8 FISMA metric domains, and
concluded that the Council’s information security program and practices were
effective for the period July 1, 2018 through June 30, 2019. (OIG-CA-20-006)



Treasury Office of Inspector General Semiannual Report—March 2020        11
                            Office of Audit – Significant Audits and Other Products

Cybersecurity Act

Section 107 of the Cybersecurity Information Sharing Act (CISA), under Title 1 of the
Cybersecurity Act of 2015, requires Inspectors General of appropriate Federal
entities, 2 in consultation with the Inspector General of the Intelligence Community and
the Council of Inspectors General on Financial Oversight (CIGFO), to jointly report to
Congress on the actions taken by the respective agencies over the recent 2-year
period to carry out the cybersecurity information sharing provisions of CISA. During
this semiannual reporting period, we issued a report covering Treasury’s cybersecurity
information sharing activities for calendar years 2017 and 2018 in support of the
biennial joint report to Congress. We also led a CIGFO Working Group survey of the
Financial Stability Oversight Council’s (FSOC) and its Federal voting member 3
agencies’ efforts to implement the information sharing provisions under CISA.

        Treasury's Cybersecurity Information Sharing

        We concluded that Treasury’s activities to share cyber threat indicators and
        defensive measures during calendar years 2017 and 2018 were adequate and
        aligned with provisions of CISA. Specifically, Treasury (1) designed and
        implemented sufficient policy, procedures, and practices to ensure the sharing
        of cyber threat indicators and defensive measures, including the removal of
        personally identifiable information not directly related to a cybersecurity threat;
        (2) did not share classified cyber threat indicators and defensive measures with
        the private sector that required authorization and accounting of the security
        clearances; (3) took appropriate, adequate, and timely actions to disseminate
        cyber threat indicators shared with the Federal Government; (4) shared specific
        aspects of cyber threat indicators that have been shared with the Federal
        Government; and (5) had no barriers affecting the sharing of cyber threat
        indicators and defensive measures. Accordingly, we did not make any
        recommendations to Treasury. (OIG-20-019)




2
    The “appropriate Federal entities” are comprised of the Office of the Director of National Intelligence
    and the departments of Commerce, Defense, Energy, Homeland Security, Justice, and the Treasury.
3
    The Federal voting members are the Secretary of the Treasury, Chairman of the Board of Governors
    of the Federal Reserve System, Comptroller of the Currency, Director of the Bureau of Consumer
    Financial Protection, Chairman of the U.S. Securities and Exchange Commission, Chairperson of the
    Federal Deposit Insurance Corporation, Chairperson of the Commodity Futures Trading Commission,
    Director of the Federal Housing Finance Agency, and the Chairman of the National Credit Union
    Administration.

        Treasury Office of Inspector General Semiannual Report—March 2020                       12
                       Office of Audit – Significant Audits and Other Products

      CIGFO’s Survey of the Financial Stability Oversight Council and its
      Federal Member Agencies’ Efforts to Implement the Cybersecurity
      Act of 2015

      A CIGFO Work Group provided FSOC and its Federal voting member agencies
      comparative information on how member agencies have implemented CISA from
      January 1, 2017 through March 31, 2019. The Working Group did not assess
      Federal voting member agencies’ compliance with CISA and did not make any
      recommendations to FSOC. (CIGFO-2020-01)


DATA Act
Treasury and OMB are leading the Government-wide implementation of the Digital
Accountability and Transparency Act of 2014 (DATA Act). As part of our ongoing
oversight of the DATA Act implementation, we are conducting a series of audits
reviewing Treasury’s and the Gulf Coast Ecosystem Restoration Council’s (Council)
efforts to meet their responsibilities under the DATA Act. During this semiannual
period, we issued reports on the results of our second audit in the series.

      Treasury Continues to Make Progress in Meeting its DATA Act
      Reporting Requirements

      Treasury continues to make progress in meeting its DATA Act reporting
      requirements. Treasury’s senior accountable official timely submitted and
      certified Treasury’s fiscal year 2019, first quarter spending data in the DATA
      Act broker for publication on USAspending.gov on March 20, 2019. Treasury’s
      implementation and use of the data standards resulted in a complete and timely
      agency submission and produced complete and accurate summary-level data.
      However, the data submitted was of moderate quality. Treasury’s non-IRS data
      had low error rates for completeness and accuracy and a moderate error rate for
      timeliness. While Treasury’s error rate for accuracy was low, we identified three
      data elements with higher error rates for accuracy: (1) primary place of
      performance address, (2) action date, and (3) ultimate parent legal entity name.
      We also noted (1) that the DATA Act Information Model Schema (DAIMS)
      definition for period of performance start date was not clear, (2) Treasury’s
      Executive Office for Asset Forfeiture had not reported financial assistance data
      for publication on USAspending.gov, and (3) Treasury did not timely report
      discounts for procurement awards to Federal Procurement Data System-Next
      Generation (FPDS-NG).

      Treasury Office of Inspector General Semiannual Report—March 2020      13
                 Office of Audit – Significant Audits and Other Products


We recommended that Treasury’s Assistant Secretary for Management, working
as needed with Treasury’s senior accountable official, reporting entities, the
DATA Act Project Management Office (PMO), and OMB, (1) develop, modify, or
implement policies and procedures that require primary place of performance
address, including ZIP+4, be documented in the initial award document, and
ensure that this information is accurate in FPDS-NG; (2) develop, modify, or
implement policies and procedures that ensure the action date of procurement
awards are accurately entered into FPDS-NG in accordance with the DAIMS;
(3) request that Treasury’s PMO ensures File D2 data (i.e., award and awardee
details associated with financial assistance awards) is properly extracted from
appropriate sources within the System for Award Management for publication
on USAspending.gov; (4) request that Treasury’s PMO and OMB update the
DAIMS definition of period of performance start date to prescribe definitively
which start date agencies should use, initial award or award modification, for
DATA Act purposes; or require the data element only for initial award actions;
(5) develop and implement a method and procedures to submit Treasury
Forfeiture Fund financial assistance award data to the Financial Assistance
Broker Submission in accordance with the reporting submission specifications
established by the DAIMS; and (6) establish and implement procedures to
recognize discounts in FPDS-NG in accordance with timeframes established by
the Federal Acquisition Regulation (FAR).
Treasury management generally concurred with recommendations 1 through 5
and outlined corrective actions that met the intent of these recommendations.
Treasury management did not agree with recommendation 6, which is related to
the treatment of discounts Treasury receives on payments to vendors. Treasury
management stated that treatment of discounts varies across Federal agencies
due to lack of Government-wide guidance. We have reviewed Treasury’s
position and while we agree that the FAR does not include specific guidance on
the treatment of discounts, it does require agencies to report any modification
to awards that change previously reported award action data, regardless of
dollar value, to FPDS-NG within three business days. Our position is that this
would include discounts. We are working with Treasury management, OMB, and
the Council of the Inspectors General on Integrity and Efficiency’s DATA Act
Working Group to gain further clarification on this issue. (OIG-20-007)

TIGTA performed a separate audit of the IRS’ efforts to report financial and
payment information as required by the DATA Act. The results of our audit and
TIGTA’s audit were used to assess Treasury’s efforts, as a whole, to comply

Treasury Office of Inspector General Semiannual Report—March 2020    14
                       Office of Audit – Significant Audits and Other Products

      with the DATA Act. In summary, Treasury’s completeness and accuracy error
      rates were low, and the error rate for timeliness was near the cutoff between
      lower and moderate. (OIG-20-008)

      The Gulf Coast Ecosystem Restoration Council Met DATA Act
      Reporting Requirements but Data Accuracy Could be Improved

      Council’s fiscal year 2019 first quarter data submission met the standards for
      completeness, accuracy, timeliness, and was of higher quality (i.e. contained
      less than 20 percent errors). Furthermore, Council’s data was submitted to the
      Broker on March 19, 2019, meeting the Treasury PMO’s March 20, 2019
      deadline for publication on USAspending.gov; and the Council fully implemented
      and used the Government-wide financial data standards established by OMB and
      Treasury in August 2015.

      While the Council’s fiscal year 2019 first quarter data was of higher quality, we
      found errors in certain procurement data elements made by Fiscal Service’s
      Administrative Resource Center (ARC). As a result, certain procurement data
      elements in the Council’s data submission were inaccurate. Specifically, the
      award type and action date for one contract included in File D1 (i.e., award and
      awardee details associated with procurement awards) did not match the
      contract, the authoritative source record. We recommended that the Council’s
      Executive Director ensure that the senior accountable official (1) directs ARC to
      correct the procurement data errors identified in FPDS-NG; and (2) improves
      oversight of ARC’s future DATA Act submissions to ensure the accuracy of the
      Council’s data. Council management agreed with our recommendation, and its
      actions as stated in the report, met the intent of our recommendation.
      (OIG-20-005)

RESTORE Act
As part of our ongoing oversight of Resources and Ecosystems Sustainability, Tourist
Opportunities, and Revived Economies of the Gulf Coast States Act of 2012
(RESTORE Act) programs, we are assessing the Gulf Coast Ecosystem Restoration
Council’s (Council) and Treasury’s activities funded by the act. During this semiannual
period, we assessed Jefferson Parish, Louisiana’s internal control over the
administration of Federal awards in accordance with Federal laws, regulations, and
Treasury’s grant application requirements.



      Treasury Office of Inspector General Semiannual Report—March 2020       15
                       Office of Audit – Significant Audits and Other Products

      Jefferson Parish’s Internal Control over Federal Awards

      We found that Jefferson Parish’s system of internal control did not include an
      entity-wide risk assessment to identify and manage organizational risks.
      Jefferson Parish had designed and implemented internal controls to administer
      Federal awards in the areas of budgeting, cash management, financial reporting,
      and performance monitoring as required by OMB’s Uniform Administrative
      Requirements, Cost Principles, and Audit Requirements for Federal Awards,
      2 CFR Part 200 (Uniform Guidance), Treasury’s RESTORE Act Financial
      Assistance Standard Terms and Conditions and Program-Specific Terms and
      Conditions, and Treasury’s RESTORE Act Direct Component Guidance and
      Application to Receive Federal Financial Assistance. However, Jefferson Parish
      had not yet designed and implemented controls in the areas of disbursements
      (i.e. grant timekeeping), equipment management, and procurement as of
      November 2018. Among other things, these areas lacked policies and
      procedures for (1) tracking and allocating employee time charged to RESTORE
      Act grants; (2) maintaining records to manage Federally-funded equipment; and
      (3) ensuring compliance with Treasury’s conflict of interest requirements.

      We recommended that Treasury’s Fiscal Assistant Secretary ensure that the
      deficiencies identified in Jefferson Parish’s controls over Federal awards are
      considered as part of Treasury’s oversight of future awards as well as risk
      assessments of Jefferson Parish as required by the Uniform Guidance. Treasury
      management stated that they will consider the internal control deficiencies
      identified as part of Treasury’s risk assessments for any future Jefferson Parish
      awards. Treasury management’s response met the intent of our
      recommendation. (OIG-20-029)


Small Business Jobs Act
The Small Business Jobs Act of 2010 established the Small Business Lending Fund
(SBLF) program at Treasury to increase the availability of credit to small businesses.
Under Section 4107 of the act, we are responsible for audits related to the SBLF
program. During this semiannual reporting period, we assessed the impact of the
mandatory dividend and interest rate increases on financial institutions participating in
Treasury’s SBLF program.




      Treasury Office of Inspector General Semiannual Report—March 2020         16
                            Office of Audit – Significant Audits and Other Products

        Impact of Mandatory Dividend Rate Increases on Small Business
        Lending Fund Participants

        Financial institutions that received capital investments under the SBLF program
        were expected to pay dividends or interest (collectively referred to as dividend
        rates) to Treasury. Between December 2015 and April 2016, the dividend rates
        for SBLF participants increased to 9 percent for C corporations and
        13.8 percent for S corporations. 4 We found that financial institutions exited the
        SBLF program at an accelerated pace prior to their respective dividend rate
        increases. That is, 227 of the 281 SBLF participants (or 81 percent) fully
        redeemed their investments totaling $3,416,196,880. From April 2016 through
        March 2018, another 42 financial institutions redeemed investments totaling
        $378,259,000. Of the 197 dividend payments totaling $46,062,138 that were
        due subsequent to the dividend rate increases, the SBLF program office
        collected 182 payments (or 92 percent) totaling $39,736,183. The remaining
        $6,325,955 was owed by three financial institutions. For these missed dividend
        payments, we found that the SBLF program office took appropriate actions in
        accordance with the Securities Purchase Agreement(s). Overall, we found that
        SBLF program officials and staff complied with the office’s Redemption
        Procedure and Dividend and Interest Procedures. Since SBLF participants
        remaining as of March 31, 2018 were not required to redeem their investments,
        we did not make recommendations to Treasury. (OIG-20-026)


Resource Management
We conduct audits on Treasury’s administration of its programs and operations. During
this semiannual reporting period we issued a report on Treasury’s Office of the Deputy
Assistant Secretary for Human Resources and Chief Human Capital Officer’s
(DASHR/CHCO) processes and practices related to pay adjustments, bonuses and
awards for Treasury Departmental Office (DO) executives.




4
    C corporations are legal entities operating under state law whose profits are taxed to the corporation
    when earned, and taxed to the shareholders when distributed as dividends. S corporations are
    entities, as allowed by the Internal Revenue Code, which pass income, losses, deductions, and
    credits to their shareholders for Federal tax purposes. In so doing, the corporation avoids double
    taxation on corporate income.

        Treasury Office of Inspector General Semiannual Report—March 2020                      17
                 Office of Audit – Significant Audits and Other Products

Treasury Departmental Offices Executive Pay Adjustments, Bonuses,
and Awards

Treasury’s Office of Executive Resources (OER), within DASHR/CHCO, generally
complied with applicable laws, regulations, policies, and procedures when
administering performance ratings, pay adjustments, and bonuses for DO Senior
Executive Service (SES) members authorized for the fiscal year 2016
performance period. For example, all awardees approved by Treasury’s Deputy
Secretary met the bonus eligibility requirements, and Treasury’s aggregate
spending on SES performance bonuses did not exceed established thresholds.
However, DASHR/CHCO’s processes and practices related to pay adjustments
and bonuses did not meet all the requirements established in 5 CFR 534.404,
Setting and adjusting pay for senior executives, and 5 CFR 534.405,
Performance awards. For example, OER did not comply with 5 CFR 534.404
(h)(2), Setting pay upon transfer, nor 5 CFR 534.403(a)(3)(b), Suspension of
certification of performance appraisal system, during a gap in Treasury’s SES
performance appraisal system certification. Specifically, we identified two
instances where the SES rate of basic pay was higher than the rate permitted
by Federal regulations during a gap in Treasury’s SES performance appraisal
system certification in 2016, resulting in overpayments for two individuals and
estimated questioned costs totaling $2,550.

In addition, we identified weaknesses in Treasury’s processes and practices
related to pay adjustments, bonuses and awards. We noted (1) DASHR/CHCO
had not finalized and approved Treasury’s SES Pay and Awards policy; (2) OER
did not have standard operating procedures (SOP) in place detailing the
processes and procedures used for administering Treasury DO SES member
performance ratings, pay adjustments, and bonuses; nor did they have
procedures in place to ensure that there was an adequate and full understanding
by SES’ supervisors and rating officials regarding exceptions to the Office of
Personnel Management’s (OPM) 12-month rule relating to pay adjustments; and
(3) OER did not timely submit Treasury’s final fiscal year 2016 SES data call
report to OPM. In addition, the 2017 data call report did not include 11
individuals who had left Treasury. We were told that the lack of sufficient
resources and workforce skills contributed to these weaknesses and the
instances of noncompliance with Federal regulations.

We recommended that the Assistant Secretary for Management; ensures:
(1) DASHR/CHCO and OER develop, implement, and include effective internal


Treasury Office of Inspector General Semiannual Report—March 2020    18
                       Office of Audit – Significant Audits and Other Products

      controls within its policies and SOPs to ensure Treasury’s SES basic pay rates
      are in compliance with 5 CFR 534.403(a)(3)(b), Suspension of certification of
      performance appraisal system; and 5 CFR 534.404 (h)(2), Setting pay upon
      transfer; (2) DASHR/CHCO and OER calculate the overpayment amounts for the
      two DO SES members whose pay was set higher than allowed by regulation;
      (3) DASHR/CHCO and OER seek recovery of the overpayment amounts or
      exercise the authority to waive any claim in accordance with applicable Federal
      regulations and Treasury Directive 34-01, Waiving Claims Against Treasury
      Employees for Erroneous Payments; (4) DASHR/CHCO and OER complete OPM
      data calls in accordance with OPM’s applicable instructions and guidance to
      ensure all required employees, such as those who have left Treasury, are
      properly reported; (5) DASHR/CHCO assesses staffing levels, workforce skills,
      and respective budgets to determine whether additional personnel should and
      can plausibly be incorporated into future strategic planning to ensure OER can
      meet its goals and mission; (6) DASHR/CHCO finalizes and approves Treasury’s
      SES Pay and Awards policy, and then periodically reviews it for continued
      relevance, effectiveness, and transparency in making pay decisions and
      awarding performance bonuses; (7) OER documents the processes and SOPs,
      with appropriate detail, followed in administering Treasury DO SES member
      performance ratings, pay adjustments, and bonuses; (8) OER oversees the
      process regarding exceptions to the 12-month rule; (9) OER includes information
      regarding the approval process for waiver requests for exceptions to the
      12-month rule in the instructions provided to bureau heads and DO policy
      offices. This information should be consistent with Federal regulations and
      Treasury’s SES Pay and Awards policy; and (10) OER submits Treasury’s
      respective data call report to OPM by the due dates established by
      5 CFR 534.405, Performance awards, and before any established deadlines per
      OPM’s annual data call memorandum. Management agreed with our
      recommendations and outlined corrective actions, planned and taken, that met
      the intent of our recommendations. (OIG-20-027) $2,550 Questioned Costs


Manufacturing
We conduct audits of the Bureau of Engraving and Printing’s (BEP) currency programs
and of the Mint’s coin programs. During this semiannual reporting period, we issued
the following reports.




      Treasury Office of Inspector General Semiannual Report—March 2020    19
                          Office of Audit – Significant Audits and Other Products

        BEP Improved Governance and Oversight over Note Development
        and Production But Challenges Remain

        We reviewed corrective actions taken to address the recommendations made in
        our January 2012 report on BEP’s project management related to the production
        of the Next Generation (NexGen) $100 note. 5 According to Treasury’s audit
        follow-up system, the Joint Audit Management Enterprise System (JAMES),
        these corrective actions were implemented and were closed in 2013. We found
        that:

           • BEP had completed production validations of the NexGen $100 note at its
               two production facilities, the Washington, DC Facility (DCF) and Western
               Currency Facility (WCF), but was unable to provide complete
               documentation on the production validations. BEP had resumed production
               of the NexGen $100 note at DCF and WCF in May 2013, but stopped
               production at DCF in September 2013 after finding a new issue that
               impacted the quality of the notes. BEP’s goal is to complete production
               validations and resume production at DCF in fiscal year 2020;
           • BEP implemented a Currency Quality Assurance Program and increased its
               capabilities in project management which improved governance processes
               and oversight over note development and note production quality. Despite
               this, challenges remained as BEP had not redesigned a new note using its
               Banknote Development Process. In addition, BEP had not documented all
               procedures that are to be followed under the new processes;
           • BEP and the Board of Governors of the Federal Reserve System (Board)
               had finalized a memorandum of understanding (MOU) on December 2011.
               However, the required 5 year update to the MOU still needed to be
               completed. The Interagency Currency Design Group charter was finalized
               and approved in March 2012; and
           • BEP completed a cost-benefit analysis, supported by the Board and United
               States Secret Service, for the disposition of the 1.4 billion NexGen $100
               notes produced in 2010, but could not provide detailed documentation to
               support this analysis or an update to its cost estimate to reflect actuals.
               Additionally, the number of notes reclaimed was significantly lower than
               BEP’s initial estimated recovery rate due to several factors.



5
    Treasury OIG, Bill Manufacturing: Improved Planning and Production Oversight Over NexGen $100
    Note Is Critical, OIG-12-038 (Jan. 24, 2012)

        Treasury Office of Inspector General Semiannual Report—March 2020                20
                 Office of Audit – Significant Audits and Other Products

Accordingly, we recommended that the Director of BEP (1) ensure that the
NexGen $100 note can be produced at both BEP facilities by completing the
necessary production validations in fiscal year 2020; (2) ensure that future
production validations at both facilities are documented consistently and
completely; (3) review and update, as needed, BEP’s guidance over its project
management processes to include best practice procedures, such as developing
an integrated master schedule, which are to be followed; (4) finalize the
required 5 year update of the MOU with the Board to formalize responsibilities
and authorities related to notes including activities, procedures, and obligations
related to the annual production, destruction, and research and development of
notes; (5) develop a plan to ensure the BEP’s Banknote Development Process
and the other processes developed under the Currency Quality Assurance
Program are properly transitioned and adhered to by BEP personnel after
contractor support ends; and (6) ensure future cost estimates are appropriately
documented and updated accordingly throughout the investment so that all
costs, savings, and other lessons learned can be incorporated into future cost
estimates. BEP management agreed with our recommendations and identified
corrective actions, both planned and taken, to address the recommendations.
Management’s corrective actions, taken and planned, met the intent of our
recommendations. (OIG-20-023)

The United States Mint Numismatic Order Management System is
Meeting User Needs But Improvements to Oversight are Needed

We found the Mint is effectively managing ordering processing for numismatic
products such as precious metal coins, commemorative coins, and medals for
sale to the public using a contractor Order Management System (OMS-II);
however, the Mint’s oversight of its contractor needs improvement. The Mint
provides oversight of the contractor through the Quality Assurance Surveillance
Plan (QASP). The QASP established contract performance requirements and the
Mint’s methodologies for conducting contractor oversight. Specifically, we
found the Mint did not make necessary adjustments or develop corrective action
plans, as required by the QASP, to improve contractor performance in meeting
established performance requirements. In addition, the Mint did not maintain
required quality assurance documentation of its monitoring activities. The Mint
also relied on contractor-provided summary reports to validate performance.
Further, at the end of fieldwork, the Mint was in the process of developing a
risk management program, but did not consider the risk of losing the numismatic
order management contractor.


Treasury Office of Inspector General Semiannual Report—March 2020        21
                       Office of Audit – Significant Audits and Other Products


      We also concluded that OMS-II, created and maintained by the contractor, is
      working as intended based on the contractor meeting most of its performance
      goals and successfully processing numismatic orders. In addition, OMS-II is
      meeting the needs of a majority of its users. However, the contractor operated
      and maintained website and Customer Contact Center do not offer services to
      those with limited English proficiency. Additionally, the Mint had not met
      targeted unit sales goals from fiscal years 2015 through 2017, resulting in
      declining revenues.

      We recommended that the Director of the Mint ensure the Numismatic and
      Bullion Directorate (1) periodically reviews QASP performance measures to
      determine necessary adjustments and develop corrective action plans, as
      required by the QASP, with the contractor, where needed; (2) retains evidence
      of its monitoring activities outlined in the contract’s QASP to better document
      the Mint’s oversight of the contractor’s compliance with contract requirements;
      (3) obtains and validates contractor’s supporting documentation against monthly
      performance reports and retains this as part of the Mint’s monthly monitoring
      documentation; (4) works with the newly appointed Chief Risk Officer to assess
      the need to include, the loss of the OMS-II contractor as a potential risk to the
      numismatic program as part of the Mint’s Risk Management Program;
      (5) performs an assessment regarding the impact of having limited language
      accessibility on Mint’s numismatic program services and considers adding these
      services to OMS-II; and (6) performs analyses to determine the feasibility and
      potential impact of proposed actions to improve numismatic sales, performs
      additional studies to enhance future sales, and reports the results to
      stakeholders. Management agreed with our recommendations, and its outlined
      corrective actions, planned and taken, met the intent of our recommendations.
      (OIG-20-030)

Debt Management
We conduct audits on Treasury’s debt management programs and operations. During
this semiannual reporting period we issued two reports, one on data analytics services
(DAS) provided by Fiscal Service’s Do Not Pay Business Center (Business Center) and
one on a review of corrective actions taken by Fiscal Service to address
recommendations made in two of our reports which related to the financial agency




      Treasury Office of Inspector General Semiannual Report—March 2020      22
                            Office of Audit – Significant Audits and Other Products

agreement (FAA) with Comerica Bank (Comerica) to operate the Direct Express® Debit
MasterCard® program (Direct Express). 6

        Performance Metric Policy Needed for the Fiscal Service Do Not Pay
        Business Center’s Data Analytics Services

        Fiscal Service established the Business Center in 2011 to support Federal
        agencies in their efforts to reduce the number of improper payments made
        through programs funded by the Federal Government. Fiscal Service partnered
        with the Federal Reserve Bank of St. Louis (FRB-STL), through a fiscal agency
        agreement, to develop and provide the Business Center DAS to agencies at no
        cost. Through these DAS, the Business Center assists agencies by identifying
        trends and patterns through complex analyses of agency payments and other
        information that may be indicative of improper payments and provides this
        information to the agencies for further study.

        Fiscal Service developed performance metrics for measuring the effectiveness of
        completed DAS projects. For example, the metrics summarize the number and
        types of DAS projects initiated by the Business Center, business process
        mapping activities, and newly adopted Do Not Pay functionalities requested
        based on completed projects. However, the metrics did not include criteria such
        as specific dollar amounts of and percentage of improper payments identified or
        prevented as a result of completed DAS projects and agency follow-up. In
        addition, Fiscal Service had not established a formal policy for the development,
        implementation, and periodic review of performance metrics for DAS.

        We recommended that Fiscal Service establish a formal policy to develop,
        implement, and periodically review performance metrics to measure the impact
        of the Business Center DAS on agencies’ efforts to identify and prevent
        improper payments. Fiscal Service management agreed with our
        recommendation, and its planned corrective actions, met the intent of our
        recommendation.

        In addition, customer agency feedback was provided for less than 50 percent of
        the completed DAS projects and FRB-STL was not centrally tracking approvals
        of project deliverables to ensure all required approvals were obtained prior to

6
    Treasury OIG, Corrective Action Verification for Two Prior OIG Reports: (1) Fiscal Service Needs to
    Improve Program Management of Direct Express (OIG-14-031, March 26, 2014) and (2) Direct
    Express Bid Evaluation Documentation Requires Improvement, OIG-17-034 (Jan. 24, 2017)

        Treasury Office of Inspector General Semiannual Report—March 2020                     23
                 Office of Audit – Significant Audits and Other Products

release of the end products to the customer agency. Rather, the approvals of
DAS project deliverables were recorded through email messages stored in
individual project folders. Similarly, FRB-STL was not centrally recording the
results of lessons-learned reviews of completed projects to facilitate sharing of
the review results. After completion of our fieldwork, Fiscal Service produced
language for all DAS agency agreements to improve the process in obtaining
feedback from customer agencies. Fiscal Service also developed a project
administrative closure form to provide central tracking of approvals for DAS
project deliverables and completion of lessons-learned reviews. Furthermore,
Fiscal Service responded that common issues from project level lessons-learned
reviews are rolled up by category to the portfolio level and discussed by Fiscal
Service leadership and analytics staff during a quarterly vision meeting. The
portfolio level lessons-learned are centrally stored and tracked on the FRB-STL
Analytics SharePoint Site. We were satisfied that Fiscal Service had taken
actions to improve the process to obtain customer agency feedback, centrally
track approvals of project deliverables and lessons-learned reviews, as well as to
ensure that the results of all lessons-learned reviews are considered by analytics
staff in conducting future projects. Therefore, we did not make any related
recommendations to Fiscal Service. (OIG-20-025)

Corrective Action Verification for Two Prior OIG Reports: (1) Fiscal
Service Needs to Improve Program Management of Direct Express
(OIG-14-031) and (2) Direct Express Bid Evaluation Documentation
Requires Improvement (OIG-17-034)

In reports OIG-14-031 and OIG-17-034, we made a total of
14 recommendations and raised a matter of concern to Fiscal Service regarding
its administration of the Direct Express program. In report OIG-17-034, we
verified corrective actions taken by Fiscal Service for 4 of the 13
recommendations we made in report OIG-14-031, which Fiscal Service closed in
Treasury’s audit follow-up system, JAMES. We also made a new
recommendation and raised a matter of concern in report OIG-17-034. At that
time, we did not verify the corrective actions taken for the remaining 9
recommendations on report OIG-14-031 that were also closed in JAMES.

In our most recent review of corrective actions taken by Fiscal Service, we
found that management implemented all but 1 of the 9 recommendations from
report OIG-14-031 that we had not previously verified. Specifically, we found
that the corrective actions to review Comerica’s compensation for

Treasury Office of Inspector General Semiannual Report—March 2020       24
                 Office of Audit – Significant Audits and Other Products

reasonableness throughout the FAA term were not being conducted as reported
in JAMES. While we did not make a new recommendation in our report, we
asked Fiscal Service management to re-open and revise this recommendation in
JAMES to reflect a process to review the financial data each month to ensure
Comerica’s reported revenues and expenses are reasonable and comply with the
FAA. We also verified that Fiscal Service had implemented the recommendation
and matter of concern we made in report OIG-17-034.

Fiscal Service management agreed to address the remaining recommendation on
report OIG-14-031, and its planned corrective actions met the intent of our
recommendation. (OIG-20-028)




Treasury Office of Inspector General Semiannual Report—March 2020   25
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Office of Investigations – Significant Investigations
FinCEN Employee Removed from Service for Time and Attendance Fraud

Our investigation revealed a Financial Crimes Enforcement Network employee
committed time and attendance fraud. The employee falsely completed time and
attendance documentation which represented a loss to the Federal Government of
approximately $4,000. Criminal prosecution of this matter was declined by the
Department of Justice, Public Integrity Section in lieu of administrative remedies. As a
result, the employee was removed from Federal service.

Subject Sentenced for Bank Fraud and Aggravated Identity Theft

On December 9, 2019, a subject was sentenced to 58 months of incarceration,
36 months of probation, and $4,400 in restitution. The subject deposited counterfeit
financial institution checks in various bank accounts and used fraudulently obtained
debit cards to withdraw funds. The United States Attorney’s Office (USAO) for the
Middle District of North Carolina prosecuted the case.

Findings of Misconduct by a Treasury Employee for Time and Attendance
Fraud

Our investigation revealed that a Department of the Treasury (Treasury) employee
committed time and attendance fraud. The employee’s time keeping records did not
accurately reflect the employee’s hours worked. The employee was administrative
support for three supervisors and worked in multiple locations. As a result, supervisors
were not aware that on several occasions the employee failed to report to work.
During the investigation, the subject resigned. The three supervisors also resigned or
retired prior to the conclusion of the investigation. Therefore, administrative action
could not be taken.

Mint Employee Sentenced for Sexual Exploitation of a Child

On November 22, 2019, a United States (Mint) employee was sentenced to 2 months
of incarceration, 120 months of probation, and required to register as a sex offender in
the District Court of Arapahoe County, Littleton, Colorado. The employee arranged a
meeting with an underage child, who was in fact an investigator, on an internet chat
site. The Arapahoe County Sheriff’s Office arrested the employee when he arrived at
the arranged location. The Mint placed the employee on administrative leave and
terminated his employment upon sentencing.

      Treasury Office of Inspector General Semiannual Report—March 2020        27
                             Office of Investigations – Significant Investigations

Direct Express Cashless Benefit Program Ended to Prevent Additional
Fraudulent Transactions

Our investigation revealed that proxies, posing as Federal benefits recipients, made
unauthorized telephonic transfer requests that misdirected funds from benefits
recipients’ accounts to a money transfer company. A Federal Government contractor
for the Direct Express Cardless Benefit Access program identified $350,000 in
fraudulent transfers made from the program’s cardholder accounts. Treasury
authorized the contractor to terminate the program to prevent further losses from
fraudulent transfers. This case was declined for prosecution by the USAO for the
Southern District of Florida due to insufficient evidence.

Bureau of Engraving and Printing Employee Resigned after Submitting a
Forged Document

Our investigation determined that a Bureau of Engraving and Printing employee
submitted a forged jury service certification letter to management for jury service in
Prince George's County Circuit Court. The employee resigned prior to the completion
of our investigation. The USAO for the District of Columbia and the Department of
Justice, Public Integrity Section declined to prosecute this investigation.

Findings of Misconduct Substantiated, But Forensic Analysis Did Not
Identify a Suspect

Our investigation of an anonymous threatening letter that was sent to a Mint
employee’s home substantiated misconduct, but did not identify a suspect. The letter
was in a pink envelope often used to route documents internally within the Mint, and
an outer envelope was addressed to the employee. All documentation related to the
threat, with the exception of the original outside envelope that was inadvertently
discarded, was submitted to the Treasury Inspector General for Tax Administration
(TIGTA) Forensics Laboratory for finger print and indentation analysis. TIGTA advised
that no fingerprints or readable markings were discovered. The forensics report was
provided to the Mint for their information.




      Treasury Office of Inspector General Semiannual Report—March 2020       28
                             Office of Investigations – Significant Investigations




Following is information related to significant investigative activities from prior
semiannual periods.

Subject Sentenced for Denial of Service Attacks on Local and Federal
Government Networks to Include Treasury.gov

Our joint investigation with the Federal Bureau of Investigation (FBI) identified a
subject who initiated Denial of Service attacks on local and Federal Government
websites, including a Treasury website. The subject, an anonymous-affiliated threat
actor, took credit for the attacks by posting on Twitter. The subject was indicted for
Damage to a Protected Computer and Loss to Persons of at least $5,000 in the U.S.
District Court, Northern District of Ohio Eastern Division. The FBI arrested the subject
in Akron, Ohio, on the charge of Damage to a Protected Computer. The subject pled
guilty to Damaging Protected Computers and was in the custody of the U.S. Marshall
Service.

Update: On October 3, 2019, the subject was sentenced to 60 months of
incarceration, 36 months of probation, and $669,000 in restitution. USAO for the U.S.
District Court, Northern District of Ohio Eastern Division, prosecuted the case.

Subjects Sentenced for Theft of Government Property and Identity Theft

As reported in previous semiannual periods, our joint investigation with the Social
Security Administration Office of Inspector General and the Internal Revenue Service,
Criminal Investigations identified three subjects who used stolen identities to access
the MySocialSecurity (MySSA) system and redirected victims’ benefit payments to
accounts the subjects controlled. The subjects also filed false tax returns and
redirected the fraudulent tax refunds to the subjects’ accounts. The three subjects
were indicted in the Middle District of Florida, Orlando Division, and were arrested for
Conspiracy, Aggravated Identity Theft, and Theft of Public Money in the amount of
$91,750.

Update: On March 16, 2020, the final subject in our joint investigation was sentenced.
Two subjects were sentenced to a total of 36 months of incarceration, 48 months of
probation, and $187,000 in restitution. A third subject was acquitted in a jury trial.
USAO for the Middle District of Florida, Orlando Division, prosecuted the case.



      Treasury Office of Inspector General Semiannual Report—March 2020           29
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Other Treasury OIG Accomplishments and Activities
Gears of Government Award

Debbie Harker, Assistant Inspector General for Audit, is part of a team award under
the Office of Management and Budget’s Gears of Government Award program.
Ms. Harker participated on a team under the auspices of the Federal Chief Financial
Officers Council. The team was commended for work that improved Digital
Accountability and Transparency Act (DATA Act) data quality, which impacts strategic
decisions, transparency, and services to citizens. These improvements enable agencies
to leverage data as a strategic asset for accomplishing their missions and provide
greater transparency to the public. The Department of the Treasury (Treasury) Office
of Inspector General (OIG) is a leader in implementing the DATA Act.

Treasury OIG Leadership Roles

Treasury OIG professionals serve on various important public and private professional
organizations supporting the Federal audit community. Examples of participation in
these organizations follow:

Deborah Harker, Assistant Inspector General for Audit, is serving as the Co-Chair of
the Council of the Inspectors General on Integrity and Efficiency (CIGIE) Federal Audit
Executive Council’s (FAEC) DATA Act Working Group Governance Committee.
Ms. Harker also represents CIGIE on the Chief Financial Officers Council, Leveraging
Data as a Strategic Asset Working Group.

Pauletta Battle, Deputy Assistant Inspector General for Financial Management and
Transparency Audits, chairs the FAEC’s DATA Act Working Group, which educates
Inspectors General and Government financial communities on the DATA Act oversight
process. The Working Group consists of approximately 200 members representing 38
OIGs.

Donna Joseph, Deputy Assistant Inspector General for Cyber and Financial Assistance
Audits, serves as the National Single Audit Coordinator for Treasury, and is a member
of the American Institute of Certified Public Accountants’ (AICPA) National
Governmental Accounting and Auditing Update planning committee. The committee
coordinates its annual conference.

Jeffrey Dye, Audit Director, regularly teaches a module of the Introductory Auditor
course sponsored by the CIGIE Training Institute.

      Treasury Office of Inspector General Semiannual Report—March 2020       31
                            Other Treasury OIG Accomplishments and Activities



James Hodge, Audit Director, serves with Ms. Joseph on the AICPA National
Governmental Accounting and Auditing Update Conference planning committee, and is
a member of the Office of Management the Budget’s Fraud Reduction and Data
Analytics Act Working Group. The Working Group’s current focus is on fraud
taxonomy to improve the Federal Government’s fraud risk management efforts. Within
the Working Group are numerous subgroups, broken out by internal and external fraud
types. Mr. Hodge is a member of the internal fraudulent financial reporting subgroup.

2019 Combined Federal Campaign

Treasury OIG exceeded its 2019 Combined Federal Campaign dollar goal. The OIG’s
campaign this year was led by Donna Joseph. Also assisting in the campaign were:
from the Office of Counsel, Loren Sciurba; from the Office of Investigations,
Sonja Scott; from the Office of Management, Mark Hill; and from the Office of Audit,
Bobbie Gambrill, Shiela Michel, and Yves Laison.




      Treasury Office of Inspector General Semiannual Report—March 2020     32
Statistical Summary
Summary of Treasury OIG Activities
October 1, 2019 through March 31, 2020

                                                                                    Number or
 OIG Activity                                                                       Dollar Value
 Office of Counsel Activities
 Regulation and legislation reviews                                                                 9
 Instances where information was refused                                                            0
 Office of Audit Activities
 Reports issued and other products                                                                 44
 Disputed audit recommendations                                                                     0
 Significant revised management decisions                                                           0
 Management decision in which the Inspector General disagrees                                       0
 Monetary benefits (audit)
 Questioned costs                                                                              $2,550
 Funds put to better use                                                                           $0
 Total monetary benefits                                                                       $2,550

 Office of Investigations Activities
Criminal and judicial actions (including joint investigations)*
 Investigative reports issued                                                                     119
 Cases referred for prosecution and/or litigation                                                  13
 Individuals referred for criminal prosecution to the Department of Justice                        20
 Individuals referred for criminal prosecution to state and local authorities                       1
 Cases accepted for prosecution and/or litigation                                                  18
 Arrests                                                                                            2
 Indictments/informations                                                                          11
 Convictions (by trial and plea)                                                                   11
* During the reporting period, defendants were sentenced to 370 months of prison time, 354 months
  of probation, 24 days of community service, and ordered to pay fines, restitution, and court fees in
  the amount of $5,179,813. In addition, Department of Treasury (Treasury) Office of Inspector
  General (OIG) participated in criminal investigations where subjects forfeited $3,989,034 and civil
  investigations involving $2,052,619 in judgments and settlements.



Metrics Used for Office of Investigations Activities
Treasury OIG investigative statistics listed above were obtained through reports drawn
from Treasury OIG’s Office of Investigations case management system.




        Treasury Office of Inspector General Semiannual Report—March 2020                   33
                                                                     Statistical Summary


Reports with Unimplemented Recommendations
Issued prior to October 1, 2019

The following list of Treasury OIG reports with unimplemented recommendations is
based on information in Treasury’s automated audit recommendation tracking system,
which is maintained by Treasury management officials, and recommendations tracked
by other Federal organizations related to Treasury OIG’s oversight of the Resources
and Ecosystems Sustainability, Tourist Operations, and Revived Economies of the Gulf
Coast States Act of 2012 (RESTORE Act) programs and activities of the Gulf Coast
Ecosystem Restoration Council (Council) and the National Oceanic and Atmospheric
Administration’s Gulf Coast Ecosystem Restoration Science, Observation, Monitoring,
and Technology Program.

Treasury OIG is reporting 42 open and unimplemented recommendations for
13 reports issued prior to October 1, 2019, with $12,580,279 in questioned costs.

Treasury OIG considers all unimplemented recommendations for reports issued over
6 months to be significant.

Treasury Programs and Operations

                Date Report Title and Recommendation Summary

OIG-16-059      09/16 General Management: Treasury Has Policies and Procedures to
                      Safeguard Classified Information but They Are Not Effectively
                      Implemented
                      The Assistant Secretary for Intelligence and Analysis should
                      direct the Deputy Assistant Secretary for Security to update
                      the Treasury Security Manual to include procedures requiring
                      the Office of Security Programs to follow up and obtain all
                      bureau self-inspection reports. Management agreed with the
                      recommendations. (1 recommendation)




      Treasury Office of Inspector General Semiannual Report—March 2020         34
                                                                    Statistical Summary

OIG-17-044     05/17 Terrorist Financing/Money Laundering: Federal Agencies Are
                     Generally Satisfied with TFFC's Collaboration Efforts, but
                     Enhancements Can Be Made
                     The Assistant Secretary for Terrorist Financing should
                     (1) develop policies and procedures to ensure continuity and
                     consistency in collaboration efforts with interagency task
                     forces and workgroups; (2) develop and implement a
                     mechanism to monitor, evaluate, and report on the
                     effectiveness of the Office of Terrorist Financing and Financial
                     Crimes' (TFFC) interagency collaboration; (3) develop
                     meaningful performance measures specific to TFFC
                     collaboration; and (4) address areas of concern expressed by
                     Federal agencies regarding TFFC’s collaboration that includes
                     feedback, intersessional meetings, and invitations to participate
                     in bilateral meetings with foreign countries during the Financial
                     Action Task Force Plenary. Management agreed with the
                     recommendations. (4 recommendations)




OIG-18-018     11/17 Terrorist Financing/Money Laundering: OFAC Human Resources
                     Practices Need Improvement
                     The Office of Foreign Assets Control (OFAC) Director should
                     (1) ensure that legacy employees' current position descriptions
                     are evaluated to ensure that the documented promotion
                     potential of these non-supervisory employees is consistent with
                     OFAC's current promotion practices; and (2) work with the
                     Office of the Deputy Assistant Secretary for Human Resources
                     and Chief Human Capital Officer to ensure that required records
                     are included in the electronic Official Personnel Folders (eOPF).
                     Management agreed with the recommendations.
                     (2 recommendations)


OIG-18-038     02/18 Financial Regulation and Oversight: Treasury OIG Review of the
                     Office of Financial Research's Government Purchase Card
                     Program
                     The Director of the Office of Financial Research (OFR) should
                     (1) when Approving Official duties are transferred to OFR


     Treasury Office of Inspector General Semiannual Report—March 2020         35
                                                                    Statistical Summary

                       employees in 2018, develop and implement a policy to require
                       OFR Approving Officials to review purchase card transactions
                       for potential split purchases on a monthly basis; (2) ensure a
                       review of purchase cardholder files are completed to ensure
                       that all documents required by policy and procedures are
                       included in the files; and (3) develop and implement a policy for
                       storing and maintaining government purchase card transaction
                       documentation in a centralized location. Management agreed
                       with the recommendations. (3 recommendations)


OIG-18-043     04/18 Terrorist Financing/Money Laundering: OFAC’s Licensing
                     Program Would Benefit From System Enhancements
                     The Director of OFAC should (1) develop performance
                     measures specific for the licensing division. Management
                     agreed with the recommendations. (1 recommendation)


OIG-18-044     04/18 Terrorist Financing/Money Laundering: Audit of the Office of
                     Intelligence and Analysis’ Authorities and Actions Related to
                     U.S. Persons’ Financial Information
                     The Under Secretary for Terrorism and Financial Intelligence, as
                     expeditiously as possible, should ensure that Office of
                     Intelligence and Analysis (OIA) (1) U.S. Persons Procedures are
                     finalized and submitted for approval to the Attorney General of
                     the United States and (2) implements a compliance monitoring
                     program to assess whether intelligence analysts' activities are
                     conducted in accordance with OIA authorities, and electronic
                     searches and other queries are performed in a manner that fully
                     protects the rights of U.S. persons. Management agreed with
                     the recommendations. (2 recommendations)


OIG-19-007     11/18 Information Technology: Department of the Treasury Federal
                     Information Security Modernization Act Fiscal Year 2018
                     Performance Audit
                     Treasury Inspector General for Tax Administration (TIGTA)
                     management should (1) develop a plan that incorporates and
                     takes into account interruptions in TIGTA System funding;
                     (2) obtain and issue full Authority to Operate to include the

     Treasury Office of Inspector General Semiannual Report—March 2020         36
                                                               Statistical Summary

                  following: a. Ensure that the TIGTA System's current System
                  Security Plan is finalized and updated to include the system
                  architecture and all security controls based on system
                  categorization are implemented according with Treasury
                  Directive Publication 85-01, Department of the Treasury
                  Information Technology Security Program (TD P 85-01) and
                  National Institute of Standards and Technology Special
                  Publication 800-53 Revision 4, Security and Privacy Controls
                  for Federal Information Systems and Organizations (NIST SP
                  800-53, Rev. 4), guidance. b. Develop Plan of Action and
                  Milestones for the 144 out of 159 TIGTA System NIST SP
                  800-53, Rev. 4, security controls that were not implemented or
                  were partially implemented. c. Complete the Security
                  Assessment and Authorization package for the TIGTA System
                  in accordance with National Institute of Standards and
                  Technology Special Publication 800-37 Revision 1, Guide for
                  Applying the Risk Management Framework to Federal
                  Information Systems; (3) establish a current enterprise baseline
                  of software and related configurations for the TIGTA System;
                  (4) perform vulnerability scanning over the TIGTA System 1
                  every 30 days in accordance with TD P 85-01; (5) develop and
                  disseminate to TIGTA personnel a TIGTA System access
                  control policy that addresses purpose, scope, roles,
                  responsibilities, management commitment, coordination among
                  organizational entities, and compliance; (6) perform and
                  document the Business Impact Analysis for the TIGTA System
                  environment every two years as required by the Department of
                  Homeland Security, Federal Emergency Management Agency,
                  Federal Continuity Directive 1 and TD P 85-01; and (7) develop
                  and disseminate to TIGTA personnel a TIGTA System
                  Information System Contingency Plan that addresses purpose,
                  scope, roles, responsibilities, management commitment,
                  coordination, and compliance to facilitate the implementation of
                  the contingency planning policy and associated contingency
                  planning controls. TIGTA should conduct disaster recovery and
                  business continuity testing for the TIGTA System on the
                  frequency stipulated by a Business Impact Analysis.
                  Management agreed with the recommendations.
                  (7 recommendations)

Treasury Office of Inspector General Semiannual Report—March 2020         37
                                                                    Statistical Summary



OIG-19-016     11/18 Financial Management: Audit of the Department of the
                     Treasury's Consolidated Financial Statements for Fiscal Years
                     2018 and 2017
                     The Assistant Secretary for Management and Deputy Chief
                     Financial Officer should ensure that (1) the Bureau of the Fiscal
                     Service (Fiscal Service) implement requisite corrective actions
                     to resolve control deficiencies over its cash management and
                     debt information systems; (2) the Internal Revenue Service
                     (IRS) implements corrective actions to resolve the control
                     deficiencies at IRS; and (3) IRS and Fiscal Service develop and
                     implement remediation plans outlining actions to be taken to
                     resolve noncompliance with the federal financial management
                     system requirements and the resources and responsible
                     organizational units for such planned actions. Management
                     agreed with the recommendations. (3 recommendations)

                       Treasury OIG Comment: The 3 recommendations on
                       OIG-19-016 were superseded by repeat recommendations on
                       the most recent audit report for Treasury’s consolidated
                       financial statements, FINANCIAL MANAGEMENT: Audit of the
                       Department of the Treasury's Consolidated Financial
                       Statements for Fiscal Years 2019 and 2018 (OIG-20-012,
                       11/15/2019).


OIG-19-038     07/19 Domestic and International Assistance Programs: Audit of ASI
                     Federal Credit Union’s CDFI Program Awards
                     The Director of the Community Development Financial
                     Institutions (CDFI) Fund should (1) determine whether ASI
                     Federal Credit Union (ASI) was in default of its 2006 through
                     2009, 2011, and 2012 Assistance Agreements as a result of
                     submitting invalid information in its Certification Application
                     and Assistance Applications for fiscal years 2006 through
                     2009, 2011, and 2012 and its failure to deploy all Healthy
                     Food Financing Initiative Financial Assistance (HFFI-FA) awards;
                     and as such, take appropriate action which may include
                     requiring ASI to reimburse the CDFI Fund all FA and HFFI-FA


     Treasury Office of Inspector General Semiannual Report—March 2020         38
                                                                    Statistical Summary

                       awards, and suspending or revoking ASI's CDFI certification
                       and (2) re-evaluate ASI’s fiscal year 2013 Certification
                       Application and fiscal year 2013 Assistance Application to
                       determine if the information submitted was valid and complete
                       and if ASI met all eligibility requirements to be re-certified as a
                       CDFI and to receive its $1,347,000 FA award.
                       (2 recommendations) $12,298,806 Questioned Costs


OIG-19-039     07/19    DOMESTIC ASSISTANCE - Recovery Act: Audit of Georgia
                       Department of Community Affairs' Payment Under 1602
                       Program
                       Treasury's Fiscal Assistant Secretary should ensure that the
                       Georgia Department of Community Affairs (DCA) (1) provides
                       sufficient support of other eligible costs used to offset the
                       $170,500 of excess 1602 Program payments made to 14
                       subawardees for unallowable legal fees. For any costs that
                       cannot be sufficiently supported, ensure that DCA reimburses
                       Treasury; (2) reimburses Treasury the $55,817 of excess 1602
                       Program payments made to West Haven Senior Apartments as
                       a result of including ineligible costs in the project's cost basis;
                       (3) reimburses Treasury the $55,156 of excess 1602 Program
                       payments made to The Terrace at Edinburgh as a result of
                       including ineligible costs in the project's cost basis; and (4)
                       require DCA to provide support, going forward, for its actual
                       costs to perform asset management functions over the
                       remaining 15-year compliance period to ensure that fees
                       collected from subawardees do not exceed actual costs.
                       (4 recommendations) $281,473 Questioned Costs


OIG-19-040     07/19 Treasury's Efforts to Increase Transparency Into Federal
                     Spending Continue, But Further Refinement is Needed
                     The Fiscal Assistant Secretary should (1) update the Digital
                     Accountability and Transparency Act (DATA Act) Program
                     Management Office's resource documentation to give prompt
                     attention to staffing and succession planning for DATA Act
                     implementation efforts to mitigate against resource gaps;
                     (2) develop an internal reference document for the DATA Act


     Treasury Office of Inspector General Semiannual Report—March 2020           39
                                                               Statistical Summary

                  Program Management Office development team that explains
                  why a designation of warning versus fatal error was assigned
                  to each rule; (3) incorporate sub-rules that already appear in
                  Broker output (i.e.,C23.1, C23.2, C23.3) and an explanation of
                  potential formatting violations (with appropriate error
                  designations) into the DATA Act Information Model Schema
                  (DAIMS) Validation Rules v1.1.2 and Financial Assistance
                  Broker Submission Validation Checklist v1.1 (or the most
                  updated versions of these); (4) either develop an instruction
                  guide to interpret DATA Act Broker output or incorporate
                  mechanisms in the output itself to aid user interpretation when
                  multiple fields are impacted by the same rule; (5) perform
                  testing and provide documentation assuring that the limited
                  validation rules identified as having inconsistencies operate as
                  intended in the DATA Act Broker with accurately displayed
                  output; (6) develop procedures to ensure changes to rules
                  implemented during coding are subsequently captured in official
                  DAIMS documentation; (7) enhance generic disclaimers on
                  USAspending.gov and expand the use of limitation statements
                  on pages with known and potential display issues so that the
                  public has a clear understanding of known limitations when
                  using the data as displayed and available for download; (8)
                  either expand the Interface Definition Document or create a
                  complementary document that includes all elements used for
                  validation, derivation, and display purposes from external tables
                  that interface with the Broker and USAspending.gov.
                  Documentation should include the cadence on which the tables
                  are pulled or referenced by the DATA Act Broker;
                  (9) incorporate a review of the Amazon Web Services (AWS)
                  complementary controls into the existing review process; and
                  (10) perform independent assessments to verify whether
                  controls outside the standard package of controls offered by
                  AWS could be adopted to mitigate the risk that security
                  violations will occur; and (11) develop and implement a process
                  to obtain and review AWS notifications of changes to the
                  control environment, including new controls available.
                  (11 recommendations)




Treasury Office of Inspector General Semiannual Report—March 2020         40
                                                                     Statistical Summary

OIG-19-041      07/19 Interim Audit Update - Matters for Consideration Prior to Fiscal
                      Service's Selection of the Direct Express® Debit Card Program
                      Financial Agent
                      The Commissioner of the Fiscal Service should periodically
                      request access to the Regulation E compliance reviews related
                      to Direct Express conducted by the banking regulators under
                      the provisions outlined in 12 CFR 261 or other relevant
                      provisions related to the regulator. This information should be
                      used by Fiscal Service to monitor the financial agent's
                      compliance with the federal agency agreement and Service
                      Level Requirements or to improve Direct Express.
                      (1 recommendation)


OIG-19-045      09/19 GULF COAST RESTORATION: Audit of Subsea Systems
                      Institute Center of Excellence's Use of RESTORE Act Funds
                      The Fiscal Assistant Secretary should consider the deficiencies
                      identified in the Subsea Systems Institute's effort reporting as
                      part of its oversight of the Texas Commission on Environmental
                      Quality's current and future subawards to the Subsea System
                      Institute, as required by the Office of Management and
                      Budget’s Uniform Administrative Requirements, Cost Principles,
                      and Audit Requirements for Federal Awards, 2 CFR Part 200
                      (Uniform Guidance). (1 recommendation)




Closed Investigations of Senior Government Employees Not
Publicly Disclosed
October 1, 2019 through March 31, 2020

Treasury OIG closed one investigation involving a senior Government employee during
the period that was not publicly disclosed. The investigation determined that the
allegations of misconduct against the employee were unsubstantiated.




      Treasury Office of Inspector General Semiannual Report—March 2020         41
                                                                     Statistical Summary

Case Number             Allegation/Disposition

USM-20-0025             Treasury OIG received a complaint regarding allegations that a
                        senior United States Mint (Mint) employee was receiving
                        monthly transit subsidy benefits of $249.00 while on a
                        full-time telework schedule. The complaint alleged that the
                        employee falsely certified the accuracy of the telework
                        agreement and that the employee appropriated transit subsidy
                        benefits for personal use. The investigation determined that the
                        employee was authorized to receive benefits while on an
                        interim work schedule adjustment for personal reasons. Our
                        Report of Investigation was provided to the Mint.
                        Unsubstantiated




Summary of Instances of Whistleblower Retaliation
October 1, 2019 through March 31, 2020

In the previous four semiannual periods we reported that Treasury OIG was
investigating two instances of possible whistleblower retaliation. The cases were
ongoing as of the end of this reporting period. There were no new cases of possible
whistleblower retaliation opened during this reporting period. As such, there were no
established cases of whistleblower retaliation to report for the period.



Summary of Attempts to Interfere With Treasury OIG
Independence, Including Instances Where Information or
Assistance Request was Refused
October 1, 2019 through March 31, 2020

There were no attempts made to resist, delay, or restrict Treasury OIG access to
records or other information and no instances where an information or assistance
request was refused during this reporting period.



      Treasury Office of Inspector General Semiannual Report—March 2020         42
                                                                     Statistical Summary




Listing of Audit Products Issued
October 1, 2019 through March 31, 2020

In the list of 44 audit products below we identified 4 products that were issued during
the reporting period that were not publicly disclosed.

Office of Audit

Letter to the Honorable Andrew Wheeler, Administrator, Environmental Protection
Agency and Chairperson, Gulf Coast Ecosystem Restoration Council: 2020
Management and Performance Challenges (OIG-CA-20-001, 10/1/2019)

Termination Memorandum–Audit of Alcohol and Tobacco Tax and Trade Bureau’s Use
of Collection Procedures to Collect Revenue (OIG-CA-20-002, 10/1/2019)

Termination Memorandum–Audit of Alcohol and Tobacco Tax and Trade Bureau’s Use
of Offers in Compromise to Collect Revenue (OIG-CA-20-003, 10/1/2019)

Quarterly Summary Memorandum for the Lead Inspector General, Department of
Defense: Operation Inherent Resolve-Summary of Work Performed by the Department
of the Treasury Related to Terrorist Financing, ISIS, and Anti-Money Laundering for
Fourth Quarter Fiscal Year 2019 (OIG-CA-20-004, 10/8/2019)

Information Memorandum for Secretary Mnuchin, Department of the Treasury:
Management and Performance Challenges Facing the Department of the
Treasury-October 2019 (OIG-CA-20-005, 10/15/2019)

Financial Management: Audit of the United States Mint's Schedules of Custodial Deep
Storage Gold and Silver Reserves as of September 30, 2019 and 2018 (OIG-20-001,
10/22/2019)

Information Technology: Department of the Treasury Federal Information Security
Modernization Act Fiscal Year 2019 Performance Audit for Collateral National Security
Systems (OIG-20-002, 10/25/2019) Sensitive But Unclassified, Not Publicly Disclosed

Information Technology: Department of the Treasury Federal Information Security
Modernization Act Fiscal Year 2019 Performance Audit (OIG-20-003, 10/25/2019)


      Treasury Office of Inspector General Semiannual Report—March 2020         43
                                                                     Statistical Summary

Information Technology: The Gulf Coast Ecosystem Restoration Council Federal
Information Security Modernization Act of 2014 Evaluation Report for Fiscal Year
2019 (OIG-CA-20-006, 10/25/2019)

Information Technology: Fiscal Year 2019 Audit of the Department of the Treasury's
Information Security Program and Practices for Its Intelligence Systems (OIG-20-004,
10/30/2019) Classified, Not Publicly Disclosed

Annual Plan, Fiscal Year 2020, Office of Inspector General, Department of the
Treasury (OIG-CA-20-008, 10/31/2019)

Gulf Coast Restoration-DATA Act: Council Met DATA Act Reporting Requirements but
Data Accuracy Could be Improved (OIG-20-005, 10/31/2019)

Financial Management: Audit of the Department of the Treasury's Schedules of United
States Gold Reserves Held by Federal Reserve Banks as of September 30, 2019 and
2018 (OIG-20-006, 10/31/2019)

Treasury Continues to Make Progress in Meeting its DATA Act Reporting
Requirements (OIG-20-007, 11/8/2019)

Audit of Treasury's Reporting Under the DATA Act-Summary Results (OIG-20-008,
11/8/2019)

Financial Management: Audit of the Federal Financing Bank's Financial Statements for
Fiscal Years 2019 and 2018 (OIG-20-009, 11/8/2019)

Financial Management: Management Letter for the Audit of the Federal Financing
Bank's Financial Statements for Fiscal Years 2019 and 2018 (OIG-20-010,
11/8/2019)

Financial Management: Audit of the Community Development Institutions Fund's
Financial Statements for Fiscal Years 2019 and 2018 (OIG-20-011, 11/13/2019)

Financial Management: Audit of the Department of the Treasury's Financial
Statements for Fiscal Years 2019 and 2018 (OIG-20-012, 11/15/2019)

Financial Management: Audit of the Gulf Coast Ecosystem Restoration Council's
Financial Statements for Fiscal Years 2019 and 2018 (OIG-20-013, 11/19/2019)

Financial Management: Audit of the Exchange Stabilization Fund's Financial
Statements for Fiscal Years 2019 and 2018 (OIG-20-014, 12/6/2019)


      Treasury Office of Inspector General Semiannual Report—March 2020         44
                                                                     Statistical Summary

Financial Management: Management Letter for the Audit of the Department of the
Treasury's Financial Statements for Fiscal Years 2019 and 2018 (OIG-20-015,
12/6/2019)

Financial Management: Audit of the United States Mint's Financial Statements for
Fiscal Years 2019 and 2018 (OIG-20-016, 12/6/2019)

Financial Management: Management Letter for the Audit of the United States Mint's
Financial Statements for Fiscal Years 2019 and 2018 (OIG-20-017, 12/6/2019)

Financial Management: Audit of the Office of the Comptroller of the Currency's
Financial Statements for Fiscal Years 2019 and 2018 (OIG-20-018, 12/9/2019)

Information Technology: Audit of the Department of the Treasury's Cybersecurity
Information Sharing (OIG-20-019, 12/10/2019)

Financial Management: Audit of Department of the Treasury Forfeiture Fund's
Financial Statements for Fiscal Years 2019 and 2018 (OIG-20-020, 12/11/2019)

Financial Management: Audit of the Alcohol and Tobacco Tax and Trade Bureau’s
Financial Statements for Fiscal Years 2019 and 2018 (OIG-20-021, 12/13/2019)

Financial Management: Management Report for the Audit of the Department of the
Treasury’s Consolidated Financial Statements for Fiscal Years 2019 and 2018
(OIG-20-022, 12/16/2019)

Bill and Coin Manufacturing: BEP Improved Governance and Oversight over Note
Development and Production But Challenges Remain (OIG-20-023, 12/31/2019)

Quarterly Summary Memorandum for the Lead Inspector General, Department of
Defense: Operation Inherent Resolve-Summary of Work Performed by the Department
of the Treasury Related to Terrorist Financing, ISIS, and Anti-Money Laundering for
First Quarter Fiscal Year 2020 (OIG-CA-20-009, 1/6/2020)

Survey Results—CIGFO Working Group’s Survey of FSOC and its Federal Member
Agencies’ Efforts to Implement the Cybersecurity Act of 2015 ( CIGFO-2020-01,
1/15/2020)

Financial Management: Audit of the Office of D.C. Pensions' Financial Statements for
Fiscal Years 2019 and 2018 (OIG-20-024, 1/17/2020)




      Treasury Office of Inspector General Semiannual Report—March 2020         45
                                                                     Statistical Summary

Memorandum to Richard K. Delmar, Treasury Deputy Inspector General: Joint
Purchase and Integrated Card Violation Report (April 1, 2019-September 30, 2019)
(OIG-CA-20-010, 1/23/2020) Internal Memorandum, Not Publicly Disclosed

Fiscal Service: Performance Metric Policy Needed for the Fiscal Service Do Not Pay
Business Center’s Data Analytics Services (OIG-20-025, 1/28/2020)

Letter to the Honorable Russell T. Vought, Acting Director, Office of Management and
Budget: Annual Report on the Status of the Department of the Treasury’s
Implementation of Purchase and Travel Card Audit Recommendations
(OIG-CA-20-011, 1/28/2020)

Letter to the Honorable Russell T. Vought, Acting Director, Office of Management and
Budget: Annual Report on the Status of the Gulf Coast Ecosystem Restoration
Council’s Implementation of Purchase and Travel Card Audit Recommendations
(OIG-CA-20-012, 1/28/2020)

Small Business Lending Fund: Impact of Mandatory Dividend Rate Increases on Small
Business Lending Fund Participants (OIG-20-026, 1/29/2020)

Resource Management: Audit of the Department of the Treasury Departmental Offices
Executive Pay Adjustments, Bonuses, and Awards (OIG-20-027, 2/4/2020),
Questioned Costs $2,550

Review of the Bureau of the Fiscal Service’s Processing of the Department of Labor,
Occupational Safety and Health Administration’s Delinquent Debts (OIG-CA-20-013,
2/27/2020) Not Publicly Disclosed

Government-Wide Financial Services-Corrective Action Verification for Two Prior OIG
Reports: (1) Fiscal Service Needs to Improve Program Management of Direct Express
(OIG-14-031) and (2) Direct Express Bid Evaluation Documentation Requires
Improvement (OIG-17-034) (OIG-20-028, 3/2/2020)

Gulf Coast Restoration: Jefferson Parish's Internal Control over Federal Awards
(OIG-20-029, 3/18/2020)

Bill and Coin Manufacturing: The United States Mint Numismatic Order Management
System is Meeting User Needs But Improvements to Oversight are Needed
(OIG-20-030, 3/25/2020)

Revenue Function Report-Trade Facilitation and Trade Enforcement Act of 2015,
Section 112 (OIG-CA-20-014, 3/30/2020)

      Treasury Office of Inspector General Semiannual Report—March 2020         46
                                                                                    Statistical Summary



Audit Reports Issued With Questioned Costs
October 1, 2019 through March 31, 2020

                                                                            Total              Total
                                                           Total No.        Questioned         Unsupported
Category                                                   of Reports       Costs              Costs
For which no management decision had been made by
beginning of reporting period                                          1         $281,473                $281,473
Which were issued during the reporting period                          1             $2,550                      $0
  Subtotals                                                            2         $284,023                $281,473
For which a management decision was made during the
reporting period                                                       1         $281,473                $281,473
  Dollar value of disallowed costs                                     1         $281,473                $281,473
  Dollar value of costs not disallowed                                 0                  $0                     $0
For which no management decision was made by the
end of the reporting period                                            1             $2,550                      $0
For which no management decision was made within 6
months of issuance                                                     0                  $0                     $0
Questioned costs include expenditures: (1) that are questioned because of an alleged violation of a provision of a
law, regulation, contract, or other requirement governing the expenditure of funds; (2) that, at the time of the
audit, are not supported by adequate documentation (i.e., unsupported costs); or (3) used for the intended
purpose that are unnecessary or unreasonable.




       Treasury Office of Inspector General Semiannual Report—March 2020                               47
                                                                                  Statistical Summary



Audit Reports Issued With Recommendations that Funds Be Put
to Better Use
October 1, 2019 through March 31, 2020

                                               Total
                                               No. of                                          Revenue
Category                                       Reports         Total           Savings         Enhancement
For which no management decision had been
made by beginning of reporting period                           0           $0               $0                  $0
Which were issued during the reporting
period                                                          0           $0               $0                  $0
  Subtotals                                                     0           $0               $0                  $0
For which a management decision was made
during the reporting period                                     0           $0               $0                  $0
  Dollar value of recommendations agreed to
  by management                                                 0           $0               $0                  $0
       Dollar value based on proposed
       management action                                        0           $0               $0                  $0
       Dollar value based on proposed
       legislative action                                       0           $0               $0                  $0
  Dollar value of recommendations not
  agreed to by management                                       0           $0               $0                  $0
For which no management decision was
made by the end of the reporting period                         0           $0               $0                  $0
For which no management decision was
made within 6 months of issuance                                0           $0               $0                  $0
A recommendation that funds be put to better use denotes funds could be used more efficiently if management took
actions to implement and complete the recommendation including: (1) reduction in outlays; (2) de-obligations of
funds from programs or operations; (3) costs not incurred by implementing recommended improvements related to
operations; (4) avoidance of unnecessary expenditures noted in pre-award review of contract or grant agreements;
(5) any other savings which are specifically identified; or (6) enhancements to revenues of the Federal Government.




       Treasury Office of Inspector General Semiannual Report—March 2020                            48
                                                                     Statistical Summary




Reports for Which No Management Comment was Returned
Within 60 Days
As of March 31, 2020

There were no such reports issued for comment over 60 days as of the end of the
reporting period.



Reports Issued Over 6 Months for Which No Management
Decision Has Been Made
As of March 31, 2020

There were no such reports as of the end of this reporting period.



Significant Revised Management Decisions
October 1, 2019 through March 31, 2020

There were no significant revised management decisions during the reporting period.



Significant Disagreed Management Decisions
October 1, 2019 through March 31, 2020

There were no significant disagreed management decisions during the reporting period.




      Treasury Office of Inspector General Semiannual Report—March 2020         49
                                                                     Statistical Summary


Peer Reviews
October 1, 2019 through March 31, 2020

Office of Audit

Audit organizations that perform audits and attestation engagements of Federal
Government programs and operations are required by generally accepted government
auditing standards to undergo an external peer review every 3 years. The objectives of
an external peer review are to determine, during the period under review, whether the
audit organization was complying with its quality control system to provide the audit
organization with reasonable assurance that it was conforming to applicable
professional standards. Federal audit organizations can receive a peer review rating of
Pass, Pass with Deficiencies, or Fail.

The most recent peer review of our office was performed by the Department of
Education (Education) Office of Inspector General (OIG). In its report dated
September 24, 2018, Education OIG rendered a Pass rating for our system of quality
control in effect for the year ended March 31, 2018. External audit peer review
reports of our office are available on Treasury OIG’s website. On June 6, 2019,
Treasury OIG rendered a Pass rating to the Department of Labor (DOL) OIG for its
system of quality control in effect for the year ended September 30, 2018. As of the
end of this reporting period, Treasury OIG’s review of the U.S. Agency for
International Development (USAID) OIG was ongoing.

Office of Investigations

Council of the Inspectors General on Integrity and Efficiency (CIGIE) mandates that the
investigative law enforcement operations of all OIGs undergo peer reviews every
3 years to ensure compliance with (1) CIGIE’s investigations quality standards and
(2) the relevant guidelines established by the Office of the Attorney General of the
United States.

In its report dated October 16, 2017, the Department of Energy OIG found our office
to be in compliance with all relevant guidelines for the period of April 2014 to
July 2017. In addition, the peer review team identified best practices that increased
the efficiency and effectiveness of our office. Best practices identified were the
Treasury OIG policy for Certified Forensic Examiners and a process used in obtaining



      Treasury Office of Inspector General Semiannual Report—March 2020         50
                                                                     Statistical Summary

Inspector General Subpoenas. Treasury OIG did not perform any peer reviews of other
Federal investigative law enforcement organizations during this reporting period.




      Treasury Office of Inspector General Semiannual Report—March 2020         51
This page intentionally left blank.
Other Reporting Requirements and Requests
This section addresses certain reporting requirements of our office that are separate
from the reporting requirements in the Inspector General Act of 1978 (as amended).

      Reviews of Bank Failures with Nonmaterial Losses

      We conduct reviews of failed banks supervised by the Office of the Comptroller
      of the Currency (OCC) with losses to the Federal Deposit Insurance
      Corporation’s (FDIC) Deposit Insurance Fund (DIF) that do not meet the
      definition of a material loss in the Federal Deposit Insurance Act. The reviews
      are performed to fulfill the requirements found in 12 U.S.C. §1831o(k). The
      term “material loss” triggers a material loss review if a loss to the DIF exceeds
      $50 million (with provisions to increase that trigger to a loss that exceeds
      $75 million under certain circumstances). For losses that are not material, the
      Federal Deposit Insurance Act requires that each 6-month period, the Office of
      Inspector General (OIG) of the Federal banking agency must (1) identify the
      estimated losses that have been incurred by the DIF during that 6-month period
      and (2) determine the grounds identified by the failed institution’s regulator for
      appointing the FDIC as receiver, and whether any unusual circumstances exist
      that might warrant an in-depth review of the loss. For each 6-month period, we
      are also required to prepare a report to the failed institutions’ regulator and the
      Congress that identifies (1) any loss that warrants an in-depth review, together
      with the reasons why such a review is warranted and when the review will be
      completed; and (2) any losses where we determine no in-depth review is
      warranted, together with an explanation of how we came to that determination.
      The table below fulfills this reporting requirement to Congress for the 6-month
      period ended March 31, 2020. We issue separate audit reports on each review
      to OCC.




      Treasury Office of Inspector General Semiannual Report—March 2020        53
                                     Other Reporting Requirements and Requests

 Bank Failures and Nonmaterial Loss Reviews
                                                                                  Reason/
                                                                                  Anticipated
                                        OIG Summary of                            Completion
                      Date Closed/      Regulator’s               In-Depth        Date of the
 Bank Name/           Loss to the       Grounds for               Review          In-Depth
 Location             DIF               Receivership              Determination   Review
 Resolute Bank,       October 25,       •   Dissipation of        No              No unusual
 Maumee, Ohio         2019                  assets or earning                     circumstances
                      $2.2 million          due to unsafe or                      noted
                                            unsound practices
                                        •   Unsafe or unsound
                                            condition
                                        •   Capital impaired
                                        •   Failed to submit an
                                            acceptable capital
                                            restoration plan
 City National Bank   November 1,       •   Dissipation of        No              No unusual
 of New Jersey,       2019                  assets or earning                     circumstances
 Newark,              $2.5 million          due to unsafe or                      noted
 New Jersey                                 unsound practices
                                        •   Unsafe or unsound
                                            condition
                                        •   Capital impaired
                                        •   Failed to submit an
                                            acceptable capital
                                            restoration plan


Operation Inherent Resolve Quarterly Summary Memorandums to the
Department of Defense OIG

During this reporting period, we issued two summary memorandums to the
Department of Defense OIG regarding information we obtained on the
Treasury’s activities with respect to disrupting the Islamic State of Iraq and
Syria’s (ISIS) finances. The memorandums included specific examples of
activities to disrupt ISIS’s financing, information on Treasury programs that
combat terrorist financing, and work we performed or plan to perform to review
these programs. (OIG-CA-20-004, OIG-CA-20-009)

Annual Reports on the Status of Implementation of Purchase and
Travel Card Audit Recommendations

In accordance with the Government Charge Card Abuse Prevention Act of
2012, we provided annual reports on the progress made by Treasury and by the
Gulf Coast Ecosystem Restoration Council (Council) in implementing charge card
related audit recommendations. In fiscal year 2018, we issued one audit report

Treasury Office of Inspector General Semiannual Report—March 2020                   54
                                          Other Reporting Requirements and Requests

        on the Treasury’s charge card use within its Office of Financial Research (OFR). 7
        The report identified two findings related to OFR purchase cardholders making
        split purchases and OFR’s purchase card files not meeting documentation
        requirements. As a result, we made seven recommendations. OFR management
        reported that it implemented 4 of the 7 recommendations and planned to fully
        implement the following 3 open recommendations by August 2019:

           • when approving official duties are transferred from Treasury Departmental
               Offices to OFR employees in 2018, develop and implement a policy to
               require OFR approving officials to review purchase card transactions for
               potential split purchases on a monthly basis;
           • ensure a review of purchase cardholders’ files to ensure all documents
               required by policy and procedures are included in the files; and
           • develop and implement a policy for storing and maintaining Government
               purchase card transaction documentation in a centralized location.

        We followed up on the status of these recommendations and noted that
        corrective action had not been implemented by the scheduled due date. In
        following up with OFR, management plans to fully implement the
        recommendations by March 2020. However, the recommendations remained
        open as of the end of this semiannual reporting period. We will continue to
        follow up on the status of these open recommendations in our September 30,
        2020 semiannual reporting.

        Our office did not issue any charge card related audit findings and
        recommendations to the Council, and therefore, did not have anything to report
        for the Council for fiscal year 2019. (OIG-CA-20-011, OIG-CA-20-012)

        Customs Revenue Function Report–Section 112 of the Trade
        Facilitation and Trade Enforcement Act of 2015

        Section 112 of the Trade Facilitation and Trade Enforcement Act of 2015
        (TFTEA) requires us to report on (1) the effectiveness of measures taken by
        U.S. Customs and Border Protection (CBP) with respect to protection of
        revenue, including (A) the collection of countervailing and antidumping duties;
        (B) the assessment, collection, and mitigation of commercial fines and penalties;


7
    Treasury OIG, Treasury 0IG Review of the Office of Financial Research's Government Purchase Card
    Program, OIG-18-038 (Feb. 8, 2018)

        Treasury Office of Inspector General Semiannual Report—March 2020                 55
                                Other Reporting Requirements and Requests

(C) the use of bonds to secure that revenue; and (D) the adequacy of CBP
policies with respect to the monitoring and tracking of merchandise transported
in bond and collecting duties, as appropriate; (2) the effectiveness of actions
taken by CBP to measure accountability and performance with respect to
protection of revenue; (3) the number and outcome of investigations instituted
by CBP with respect to the underpayment of duties; and (4) the effectiveness of
training with respect to the collection of duties for personnel of CBP. The
statute required Treasury OIG to produce the first report no later than June 30,
2016 and to produce reports biennially, starting in March 2018. We issued
letters in June 2016 and March 2018 to satisfy the first two reporting
mandates.

In our most recent report, an interim report issued to address our March 2020
reporting mandate, we described the work we performed to gain an
understanding of CBP’s processes to protect revenue and our plans for future
audit work. Our work did not include the analytical work necessary to opine on
the effectiveness of CBP’s processes related to the protection of revenue. Our
future work will expand upon the review conducted in support of this
March 2020 reporting mandate. It will include additional meetings with CBP
personnel at various locations to assess CBP’s revenue collection processes and
analytical work necessary to opine on the effectiveness of measures taken by
CBP to protect revenue in accordance with Section 112 of TFTEA.
(OIG-CA-20-014)




Treasury Office of Inspector General Semiannual Report—March 2020     56
References to the Inspector General Act
   Section                                           Requirement                                          Page
Section 4(a)(2)   Review of legislation and regulations                                                          33
Section 5(a)(1)   Significant problems, abuses, and deficiencies                                               7-29
Section 5(a)(2)   Recommendations with respect to significant problems, abuses, and deficiencies               7-29
Section 5(a)(3)   Significant unimplemented recommendations described in previous semiannual                  34-41
                  reports
Section 5(a)(4)   Matters referred to prosecutive authorities                                                    33
Section 5(a)(5)   Summary of instances where information was refused                                             42
Section 5(a)(6)   List of audit reports                                                                       43-46
Section 5(a)(7)   Summary of significant reports                                                               7-29
Section 5(a)(8)   Audit reports with questioned costs                                                            47
Section 5(a)(9)   Recommendations that funds be put to better use                                                48
Section           Summary of each audit, inspection, and evaluation report issued before the                     49
5(a)(10)(A)       beginning of the reporting period for which no management decision was made
Section           Summary of each audit, inspection, and evaluation report issued for which no                  49
5(a)(10)(B)       management comment was returned within 60 days
Section           Summary of each audit, inspection, and evaluation report issued before the                  34-41
5(a)(10)(C)       beginning of the reporting period for which there are outstanding unimplemented
                  recommendations, including the aggregate potential cost savings
Section           Significant revised management decisions made during the reporting period                     49
5(a)(11)
Section           Management decisions with which the Inspector General is in disagreement                      49
5(a)(12)
Section           Instances of unresolved Federal Financial Management Improvement Act                           9
5(a)(13)          noncompliance
Section           Results of peer reviews conducted of Treasury OIG by another OIG                            50-51
5(a)(14)
Section           List of outstanding recommendations from peer reviews                                       50-51
5(a)(15)
Section           List of peer reviews conducted by Treasury OIG, including a list of outstanding             50-51
5(a)(16)          recommendations from those peer reviews
Section           Statistics for the period related to the number of (A) investigative reports issued,          33
5(a)(17)(A-D)     (B) persons referred to the Department of Justice for criminal prosecution,
                  (C) persons referred to state and local authorities for criminal prosecution, and
                  (D) criminal indictments/informations
Section           Description of metrics used to develop investigative statistics in Section 5(a)(17)           33
5(a)(18)
Section 5a(19)    Summary of each investigation involving a senior Government employee where                  41-42
                  allegation of misconduct was substantiated
Section 5a(20)    Instances of whistleblower retaliation                                                         42
Section 5a(21)    Summary of attempts to interfere with Treasury OIG independence                                42
Section           Description of each inspection, evaluation, and audit that was closed and not               43-46
5a(22)(A)         publicly disclosed
Section           Description of each investigation closed, involving a senior Government employee,           41-42
5a(22)(B)         that was not publicly disclosed
Section 5(d)      Serious or flagrant problems, abuses, or deficiencies                                        N/A
Section 6(b)(2)   Report to Secretary when information or assistance is unreasonably refused                    49




       Treasury Office of Inspector General Semiannual Report—March 2020                                 57
This page intentionally left blank.
Abbreviations
ARC                     Administrative Resource Center
ASI                     ASI Federal Credit Union
AWS                     Amazon Web Services
BEP                     Bureau of Engraving and Printing
Board                   Board of Governors of the Federal Reserve System
Business Center         Do Not Pay Business Center
CARES Act               Coronavirus Aid, Relief, and Economic Security Act
CBP                     U.S. Customs and Border Protection
CDFI                    Community Development Financial Institutions
CIGFO                   Council of Inspectors General on Financial Oversight
CIGIE                   Council of the Inspectors General on Integrity and Efficiency
CISA                    Cybersecurity Information Sharing Act
Comerica                Comerica Bank
Council                 Gulf Coast Ecosystem Restoration Council
DAIMS                   DATA Act Information Model Schema
DAS                     data analytics services
DASHR/CHCO              Deputy Assistant Secretary for Human Resources and Chief
                        Human Capital Officer
DATA Act                Digital Accountability and Transparency Act of 2014
DCA                     Georgia Department of Community Affairs
DCF                     Washington, DC Facility
DIF                     Deposit Insurance Fund
DO                      Departmental Offices
FAA                     financial agency agreement
Fiscal Service          Bureau of the Fiscal Service
FISMA                   Federal Information Security Modernization Act of 2014
FPDS-NG                 Federal Procurement Data System-Next Generation
FRB-STL                 Federal Reserve Bank of St. Louis
FSOC                    Financial Stability Oversight Council
IG                      Inspector General
IRS                     Internal Revenue Service
JAMES                   Joint Audit Management Enterprise System
KPMG                    KPMG LLP
Mint                    United States Mint
MOU                     memorandum of understanding
NexGen                  Next Generation
OER                     Office of Executive Resources
OFAC                    Office of Foreign Assets Control
OFR                     Office of Financial Research

      Treasury Office of Inspector General Semiannual Report—March 2020       59
                                                                         Abbreviations

OIG                    Office of Inspector General
OMB                    Office of Management and Budget
OMS-II                 Order Management System
OPM                    Office of Personnel Management
PMO                    DATA Act Project Management Office
QASP                   Quality Assurance Surveillance Plan
RESTORE Act            Resources and Ecosystems Sustainability, Tourist
                       Opportunities, and Revived Economies of the Gulf Coast States
                       Act of 2012
RMA                    RMA Associates, LLC
SBLF                   Small Business Leading Fund
Science Program        Gulf Coast Ecosystem Restoration Science, Observation,
                       Monitoring, and Technology Program
SES                    Senior Executive Service
SOP                    standard operating procedure
TD P 85-01             Treasury Directive Publication 85-01, Department of the
                       Treasury Information Technology Security Program
TFFC                   Office of Terrorist Financing and Financial Crimes
TIGTA                  Treasury Inspector General for Tax Administration
Treasury               Department of the Treasury
USAO                   United States Attorney’s Office




     Treasury Office of Inspector General Semiannual Report—March 2020        60
                        SPRING BLOSSOMS AT TREASURY




Pictured above is a magnolia tree in bloom at the Treasury Building in Washington, DC
                         Source: Treasury Graphics Branch
             Treasury Office of Inspector General Locations
                        1500 Pennsylvania Avenue, N.W., Room 4436
                                  Washington, DC 20220
                              875 15th Street, N.W., Suite 200
                                  Washington, DC 20005
                               408 Atlantic Avenue, Room 330
                                Boston, Massachusetts 02110




                               Treasury OIG Website
                  Access Treasury OIG reports and other information online:
         http://www.treasury.gov/about/organizational-structure/ig/Pages/default.aspx



                       Report Waste, Fraud, and Abuse
  Treasury Whistleblower Ombudsman – For information about whistleblowing and reprisal and
 about your rights and responsibilities as a Treasury employee or contractor, please contact the
OIG Whistleblower Ombudsman Program at 202-927-0650 or Email: OIGCounsel@oig.treas.gov


Treasury OIG Hotline for Treasury Programs and Operations – Call toll free: 1-800-359-3898 or
                           Submit a complaint using our online form:
 https://www.treasury.gov/about/organizational-structure/ig/Pages/OigOnlineHotlineForm.aspx

                                 Gulf Coast Restoration Hotline
                       Email: GulfCoastRestorationHotline@oig.treas.gov


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