Treasury Office of Inspector General Semiannual Report—March 2024 (Report to Congress)
Summary
The Treasury Office of Inspector General's Semiannual Report for March 2024 states that during the period the Office of Audit issued 39 products and identified $300,000 in questioned costs, and Office of Investigations work resulted in 7 indictments and 13 convictions. A desk review found the City of Springfield, Massachusetts Department of Health and Human Services did not maintain adequate supporting documentation for $300,000 in Coronavirus Relief Fund proceeds. An investigation found the Houston-Harris County Emergency Rental Assistance Program was defrauded of approximately $83,000; the individual was indicted for Felony Theft and is considered a fugitive. The message from Acting Inspector General Richard K. Delmar reports 26 audits and 13 additional evaluation and other oversight products.
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“Treasury Office of Inspector General Semiannual Report—March 2024 (Report to Congress).”
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Highlights
During this semiannual reporting period, the Office of Audit issued 39 products. The
office also identified $300,000 in questioned costs. Work by the Office of Investigations
resulted in 7 indictments and 13 convictions. Some of our more significant results for the
period are described below:
• Our Office of Audit performed a desk review of the use of Coronavirus Relief Funds
proceeds for the City of Springfield, Massachusetts. We found the City’s Department
of Health and Human Services did not maintain adequate supporting documentation
for the use of $300,000 in Coronavirus Relief Fund proceeds it received from the
Commonwealth of Massachusetts. We determined there were $300,000 in total
questioned costs.
• Our Office of Audit performed an audit of Terrorism and Financial Intelligence’s
Ukraine-/Russia-related Sanctions Program. We found the sanctions program
complied with applicable laws and regulations, including the Countering America’s
Adversaries Through Sanctions Act of 2017, and sanctions decisions and
deliberations were properly approved, but not always properly documented.
• Our Office of Audit performed an audit of the U.S. Customs and Border Protection’s
(CBP) underpayment duties to meet our biennial requirement to report on the
effectiveness of measures taken by CBP to protect revenue in accordance with
Section 112 of the Trade Facilitation and Trade Enforcement Act of 2015. Our audit
found CBP needs to enhance its monitoring and tracking of the outcomes of
investigations into the underpayment of duties, and we issued 6 recommendations
related to our concerns.
• An investigation conducted by our Office of Investigations revealed that the
Houston-Harris County Emergency Rental Assistance Program was defrauded of
approximately $83,000 by means of fraudulent applications for assistance submitted
by an individual. The individual was indicted for Felony Theft in Harris County Court
and a warrant issued for subject’s arrest is currently active. The subject is considered
a fugitive from justice and Treasury OIG will re-open the investigation when the
subject is located.
Treasury Office of Inspector General Semiannual Report—March 2024 i
Message from the Acting Inspector General
During this reporting period, the Department of the Treasury (Treasury) Office of Inspector
General (OIG) continued its in-depth oversight of the 12 pandemic recovery programs
administered by Treasury. We issued a total of 26 audits, and 13 additional evaluation and
other oversight products. In addition, we continued to address the large and complex body of
complaints about implementation and uses of Emergency Rental Assistance funding programs.
In response to a Congressional request, our Office of Audit conducted an inquiry regarding the
policies in place at Treasury to protect the Department and agency tax policies and revenue
rulings from being unduly influenced by employees with potential conflicts of interest. We
found that Treasury has policies and procedures in place to protect the Department.
Specifically, Treasury’s tax guidance process includes numerous stages of review and approval
of tax guidance before publication. Due to the various levels of review and segregation of
duties, absent collusion, the risk that tax guidance could be influenced by an employee with
potential conflicts of interest is low. Our inquiry did not identify any Treasury policies and
procedures related to ethics and conflicts of interest that did not comply with applicable ethics
laws and regulations. However, in reviewing Treasury’s policies and procedures related to
ethics and conflicts of interest, we determined that the tracking process for providing advice
and counsel could be enhanced. We made two recommendations to the Department to
enhance the ethics tracking process.
Treasury OIG continues to provide leadership and administrative support to the Council of
Inspectors General on Financial Oversight, the organization established by the Dodd-Frank Wall
Street Reform and Consumer Protection Act to oversee and monitor the activities of the
Financial Stability Oversight Council, which is chaired by the Secretary of the Treasury.
Treasury OIG also continues to investigate fraud, waste, and abuse of Treasury programs, to
include pandemic programs, employee misconduct, and various cyber related fraud. Treasury
OIG participates in several law enforcement working groups and task forces to investigate
external fraud that effects Treasury.
In closing, I would like to express my appreciation to Treasury OIG staff for making the
significant audit and investigative results that are summarized in this Semiannual Report
possible, and to Congress and Treasury for their sustained commitment to the important work
of our office.
Richard K. Delmar
Acting Inspector General
Treasury Office of Inspector General Semiannual Report—March 2024 ii
Contents
Highlights ......................................................................................... i
Message from the Acting Inspector General .......................................... ii
Treasury Office of Inspector General Overview .................................... 1
Management and Performance Challenges ........................................... 4
Office of Audit – Significant Audits and Other Products ........................ 5
Financial Management ............................................................................................ 5
CARES Act Oversight ............................................................................................. 9
Cyber/Information Technology ............................................................................... 10
Manufacturing and Revenue .................................................................................. 11
Anti-Money Laundering/Terrorist Financing and Intelligence ....................................... 13
Other Audits of Treasury Programs and Operations ................................................... 15
Office of Investigations – Significant Investigations ............................ 16
CARES Act Investigations ..................................................................................... 16
Other Significant Investigations .............................................................................. 16
Treasury OIG Accomplishments and Activities ................................... 20
Statistical Summary ........................................................................ 21
Summary of Treasury OIG Activities ....................................................................... 21
Metrics Used for Office of Investigations Activities ................................................... 21
Reports with Unimplemented Recommendations ...................................................... 22
Closed Investigations of Senior Government Employees Not Publicly Disclosed ............ 42
Trafficking Victims Prevention and Protection Reauthorization Act of 2022 ................. 42
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............................................. 43
Listing of Audit Products Issued ............................................................................. 44
Audit Reports Issued With Questioned Costs ........................................................... 49
Audit Reports Issued With Recommendations that Funds Be Put to Better Use ............. 50
Reports for Which No Management Comment was Returned Within 60 Days ............... 51
Reports Issued Over 6 Months for Which No Management Decision Has Been Made ..... 51
Significant Revised Management Decisions .............................................................. 53
Treasury Office of Inspector General Semiannual Report—March 2024 iii
Contents
Significant Disagreed Management Decisions ........................................................... 53
Peer Reviews ....................................................................................................... 54
Other Reporting Requirements and Requests ...................................... 55
References to the Inspector General Act............................................ 57
Abbreviations ................................................................................. 59
Treasury Office of Inspector General Semiannual Report—March 2024 iv
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 1.
Treasury OIG is headed by an Acting Inspector General since summer 2019.
Treasury OIG performs independent, objective reviews of Treasury programs and
operations, except for those of the Internal Revenue Service and certain pandemic-
related loans, loan guarantees, and other investments, and keeps the Secretary of the
Treasury and Congress fully informed of problems, deficiencies, and the need for
corrective actions. The Treasury Inspector General for Tax Administration and the
Government Accountability Office (GAO) perform oversight related to the Internal
Revenue Service. The Special Inspector General for Pandemic Recovery and GAO
perform oversight of loans, loan guarantees, and other investments under the
Coronavirus Economic Stabilization Act of 2020.
Treasury OIG also performs independent oversight of programs and operations funded
by the Gulf Coast Restoration 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 National Oceanic and
Atmospheric Administration’s (NOAA) Gulf Coast Ecosystem Restoration Science,
Observation, Monitoring, and Technology Program. With regard to the Council and the
RESTORE Science Program, Treasury OIG keeps the appointed Chairperson of the
Council, the NOAA RESTORE 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.
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
Deputy Inspector General for Small Business Lending Fund (SBLF) Program Oversight.
Under the Assistant Inspector General for Audit, there are four deputies. The first
1
5 U.S.C. §§401-424
Treasury Office of Inspector General Semiannual Report—March 2024 1
Treasury Office of Inspector General Overview
deputy is primarily responsible for financial sector audits to include audits of banking
supervision, manufacturing of currency and coins, alcohol and tobacco excise tax
revenue collection activities, SBLF programs, and the State Small Business Credit
Initiative authorized by the American Rescue Plan Act of 2021 (ARP). 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; audits of anti-money laundering/terrorist financing, foreign sanctions,
intelligence programs and operations, and international programs; and audits of
Emergency Rental Assistance (ERA) and Homeowner Assistance Fund programs
authorized by the Consolidated Appropriations Act, 2021 and ARP. The third deputy is
primarily responsible for cybersecurity and financial assistance audits to include audits
of Treasury and Council information systems performed by Treasury OIG staff and
contractors; RESTORE Act programs and operations; the Emergency Capital
Investment program, the Community Development Financial Institutions (CDFI) Fund’s
CDFI Rapid Response program, and the CDFI Equitable Recovery program, authorized
by the Consolidated Appropriations Act, 2021; and the State and Local Fiscal
Recovery Funds authorized by ARP. The fourth deputy is primarily responsible for the
Coronavirus Relief Fund and the Air Carrier Worker Support programs authorized by
the Coronavirus Aid, Relief, and Economic Security Act, and other pandemic
legislation.
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 within Treasury OIG’s
jurisdictional boundaries, and investigates 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 reporting
of allegations involving these programs and operations.
The Office of Counsel, under the leadership of the Acting 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 2 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
2
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 2024 2
Treasury Office of Inspector General Overview
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
administrative infrastructure, including facilities, human resources, information
technology, procurement, records management, and security.
Treasury OIG’s fiscal year 2024 appropriation is $48.3 million, which includes up to
$2.8 million of 2-year funding for the RESTORE Act programs. Treasury OIG’s
oversight of the State Small Business Credit Initiative and SBLF programs is funded on
a reimbursable basis. In addition to the annual fiscal year appropriation, Treasury OIG
carried over additional multi-year and no-year funding from the previous fiscal year for
oversight of pandemic relief programs, which included $17 million for the Coronavirus
Relief Fund, $1.2 million for ERA-Oversight, $1.2 million for ERA-Monitoring, and
$821 thousand for the Homeowner Assistance Fund. As of March 31, 2024, Treasury
OIG had 237 full-time staff.
Treasury Office of Inspector General Semiannual Report—March 2024 3
Management and Performance Challenges
The Reports Consolidation Act of 2000 requires that the Department of the Treasury
(Treasury) Inspector General annually provide information 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 10, 2023, memorandum to Secretary of the Treasury,
Janet Yellen, OIG reported the following six challenges facing the Department, of
which one was new.
• COVID-19 Pandemic Relief (Repeat)
• Cyber Threats (Repeat)
• Anti-Money Laundering/ Terrorist Financing and Bank Secrecy Act
Enforcement (Repeat)
• Information Technology Acquisition and Project Management (Repeat)
• Climate Initiatives Risk (Repeat)
• Operating in an Uncertain Environment (New)
Gulf Coast Ecosystem Restoration Council
In an October 11, 2023, letter to the Honorable Michael Regan, Administrator of
the U.S. Environmental Protection Agency, as Chairperson of the Council, OIG
reported three challenges, one of which was new.
• Recruiting and Retaining a Highly Skilled Workforce (New)
• Federal Statutory and Regulatory Compliance (Repeat)
• Grant and Interagency Agreement Compliance Monitoring (Repeat)
.
Treasury Office of Inspector General Semiannual Report—March 2024 4
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 2023 and 2022 consolidated
financial statements. KPMG reported 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 related to federal
financial management systems requirements. KPMG found no other instances of
reportable noncompliance with laws, regulations, contracts, and grant agreements
tested. (OIG-24-007)
In connection with its audit of Treasury’s consolidated financial statements, KPMG
issued a management letter recommending improvements to strengthen information
technology and financial reporting controls at the Departmental Offices. (OIG-24-008)
Additionally, KPMG issued a management letter recommending improvements to
strengthen internal control over cash management systems at the Bureau of the Fiscal
Service. (OIG-24-009)
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
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 2023 and 2022.
Treasury Office of Inspector General Semiannual Report—March 2024 5
Office of Audit – Significant Audits and Other Products
Treasury-audited financial statements and related audits
Fiscal year 2023 audit results Fiscal year 2022 audit results
Material
Material Significant weakness Significant
Entity Opinion weaknesses deficiencies Opinion es deficiencies
Government Management Reform Act/Chief Financial Officers Act requirements
Department of the Treasury U 0 1 U 0 2
Internal Revenue Service (A) U 0 2 U 0 2
Other required audits
Office of Financial Stability
(TARP) (A) U 0 0 U 0 0
Bureau of Engraving and
Printing U 0 0 U 0 2
Community Development
Financial Institutions Fund U 1 0 U 0 0
Office of D.C. Pensions U 0 1 U 0 1
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 0
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 0 U 0 0
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.
In connection with the fiscal year 2023 financial statement audits, the auditors issued
management letters on other matters involving deficiencies in internal control at the
United States Mint (Mint) (OIG-24-012), Office of the Comptroller of the Currency
(OCC) (OIG-24-014), Exchange Stabilization Fund’s (OIG-24-017), and the Bureau of
Engraving and Printing (BEP) (OIG-24-019).
Treasury Office of Inspector General Semiannual Report—March 2024 6
Office of Audit – Significant Audits and Other Products
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
2023 and 2022 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-24-006)
Attestation Engagements
KPMG, under a contract monitored by our office, completed the reports described
below in support of the audit of Treasury’s fiscal year 2023 consolidated financial
statements and the financial statement audits of certain other Federal agencies.
Reports on the Processing of Transactions by Fiscal Service
KPMG examined general computer and investment/redemption processing
controls used for processing various Federal agencies’ transactions by Fiscal
Service’s Federal Investments and Borrowings Branch, and general computer
and trust funds management processing controls used for processing various
Federal and State agencies’ transactions by the Fiscal Service’s Funds
Management Branch for the period beginning August 1, 2022, and ending
July 31, 2023. KPMG found, in all material respects, that the controls were
fairly presented in the description of controls for these activities and suitably
designed. KPMG also found that controls tested operated effectively throughout
the period. (OIG-24-002, OIG-24-003)
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 2023 consolidated financial statements.
Treasury Office of Inspector General Semiannual Report—March 2024 7
Office of Audit – Significant Audits and Other Products
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)
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 2024
consolidated financial statements.
Treasury Office of Inspector General Semiannual Report—March 2024 8
Office of Audit – Significant Audits and Other Products
CARES Act Oversight
Our office’s oversight of the Air Carrier Payroll Support Program (PSP1) was mandated
by Title IV, Subtitle B, Air Carrier Worker Support, of the Coronavirus Aid, Relief, and
Economic Security Act (CARES Act). Under the CARES Act, the Department of the
Treasury (Treasury) was to provide $32 billion in financial assistance to passenger air
carriers, cargo air carriers, and certain contractors to be used exclusively for the
continuation of payment of employee wages, salaries, and benefits, in response to the
economic impact of the Coronavirus Disease 2019 (COVID-19). The Consolidated
Appropriations Act, 2021 created the Airline Worker Support Extension for passenger
air carriers and certain contractors. Treasury refers to this as Payroll Support Program
Extension (PSP2). The American Rescue Plan of 2021 created the Air Transportation
Payroll Support Program Extension authorizing Treasury to provide additional
assistance to passenger air carriers and contractors that received financial assistance
under PSP2. Treasury refers to this as Payroll Support Program 3 (PSP3).
We are required to audit certifications made by passenger and cargo air carriers that
do not report salaries and benefits to the Department of Transportation (referred to as
“non-241 air carriers”) and contractors.
Additionally, under Title V of the CARES Act, Treasury OIG was mandated
responsibility to conduct monitoring and oversight of the receipt, disbursement, and
uses of Coronavirus Relief Fund (CRF) payments. Treasury OIG also has authority to
recover funds if it is determined a recipient of a CRF payment failed to comply with
requirements. As part of carrying out this function, we established the CRF portal via
GrantSolutions into which recipients of CRF direct payments must report quarterly.
During this semiannual period, we issued the following desk review on recipients’ use
of CRF proceeds reported via GrantSolutions.
City of Springfield, Massachusetts – Use of Coronavirus Relief Fund
Proceeds
We found the City of Springfields’ use of CRF generally complied with the
CARES Act, Department of Treasury (Treasury) Guidance, and Treasury Office
of Inspector General (OIG) guidance; however, the City’s Department of Health
and Human Services (HHS) did not maintain adequate supporting documentation
for the use of $300,000 in CRF proceeds it received from the Commonwealth
of Massachusetts. Treasury OIG guidance clarified that recipients of CRF
Treasury Office of Inspector General Semiannual Report—March 2024 9
Office of Audit – Significant Audits and Other Products
proceeds should maintain and make available all documents and financial
records sufficient to establish compliance with eligible use requirements to
Treasury OIG, upon request.
We recommended Treasury’s Acting Chief Recovery Officer work with Treasury
OIG to obtain adequate documentation from the Commonwealth of
Massachusetts for HHS’s $300,000 in expenditures or begin recoupment
proceedings for the disallowed costs.
Treasury management noted they were not able to confirm Treasury OIG’s
findings because they did not review any materials submitted to Treasury OIG
by the City of Springfield or the Commonwealth of Massachusetts. Treasury
management’s planned corrective actions meet the intent of our
recommendation. (OIG-CA-24-003) $300,000 Questioned Costs
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 the following reports on the Department of the Treasury’s (Treasury)
compliance with FISMA.
Fiscal Year 2023 Audit of Treasury’s Information Security Program
for its Unclassified Systems
KPMG LLP (KPMG), a certified independent public accounting firm, working
under a contract with and supervised by our office, performed an audit of
Treasury’s unclassified systems, for the period April 1, 2022, through
March 31,2023. The Treasury Inspector General for Tax Administration (TIGTA)
performed the annual FISMA evaluation of the IRS’ unclassified systems. For
fiscal year 2023, KPMG reported Treasury’s information security program and
practices for its unclassified systems were established and have been
maintained for the 5 Cybersecurity Functions and 9 FISMA Metric Domains.
However, the program was ineffective according to U.S. Department of
Homeland Security criteria. KPMG identified 3 deficiencies within 2 of the 5
Cybersecurity Functions and within 3 of the 9 FISMA Metric Domains. KPMG
Treasury Office of Inspector General Semiannual Report—March 2024 10
Office of Audit – Significant Audits and Other Products
made 5 recommendations to the responsible officials to address the identified
deficiencies. Treasury management agreed with the recommendations and
prepared corrective actions that were responsive to the intent of KPMG’s
recommendations. Due to the sensitive nature of these findings, this report is
designated Sensitive But Unclassified. (OIG-24-022, Sensitive But Unclassified)
Fiscal Year 2023 Audit of Treasury’s Information Security Program
for its Collateral National Security Systems
KPMG, working under a contract with and supervised by our office, performed
an audit of Treasury’s information security program and practices for its
collateral National Security Systems for the period April 1, 2022, through
March 31, 2023. For fiscal year 2023, KPMG reported that Treasury established
and maintained its information security program and practices for its collateral
national security systems for the 5 Cybersecurity Functions and 9 FISMA Metric
Domains. However, the program was ineffective according to U.S. Department
of Homeland Security criteria. KPMG identified 2 deficiencies within 2 of the 5
Cybersecurity Functions and within 2 of the 9 FISMA Metric Domains. KPMG
made 2 recommendations to responsible officials to address the identified
deficiencies. Treasury management agreed with the recommendations and
prepared planned corrective actions that were responsive to the intent of
KPMG’s recommendations. Due to the sensitive nature of these systems, this
report is designated Sensitive But Unclassified. (OIG-24-023, Sensitive But
Unclassified)
Manufacturing and Revenue
We conduct audits of Treasury’s coin and currency, and revenue programs. In
addition, as required under Section 112 of the Trade Facilitation and Trade
Enforcement Act of 2015, we report biennially the effectiveness of measures taken by
U.S. Customs and Border Protection (CBP) to protect revenue. During this semiannual
period, we issued the following report.
U.S. Customs and Border Protection Needs to Enhance its
Monitoring and Tracking of the Outcomes of Investigations into the
Underpayment of Duties
We assessed the number and outcomes of investigations into the underpayment
of duties with respect to the following four investigative areas: Enforce and
Treasury Office of Inspector General Semiannual Report—March 2024 11
Office of Audit – Significant Audits and Other Products
Protect Act (EAPA) Allegations, e-Allegations, referrals to Immigration and
Customs Enforcement Homeland Security Investigations (ICE HSI), and referrals
to the Department of Justice (DOJ). There were 278 EAPA allegations
submitted to CBP during Fiscal Years (FY) 2019 and 2020, resulting in 83
affirmed allegations protecting nearly $298 million in revenue. CBP also received
and reviewed 934 new underpayment of duty e-Allegations during FYs 2019
and 2020 and confirmed 68 of the e-Allegations, with revenue associated
totaling more than $65 million. CBP coordinated with ICE HSI through the
Commercial Enforcement Analysis and Response (CEAR) and referred 75
commercial fraud penalty cases, e-Allegations, and EAPA allegations to ICE HSI
during FYs 2019 and 2020; resulting in ICE HSI opening 22 cases based on
those referrals. These cases resulted in various actions taken by ICE HSI,
including seizures, arrests, indictments, and search warrants. CBP referred 21
delinquent duty, liquidated damage, and penalty cases to DOJ during FYs 2019
and 2020 resulting in the recovery of over $1.5 million in duties, liquidated
damages, and penalties.
We found the statuses and outcomes of e-Allegations were not recorded
accurately nor completely in the Commercial Allegations Recording System,
including many e-Allegations that CBP closed before the outcome of the review
was completed. We also found the Trade Remedy Law Enforcement
Directorate's (TRLED) Operations Reporting and Outreach Branch, responsible
for overseeing the e-Allegations program, did not monitor the statuses of e-
Allegations referred and that monitoring of the e-Allegations program needed
improvement. Furthermore, we found that CBP’s Operations Reporting and
Outreach Branch did not track the monetary impact of e-Allegations
investigations and could not report if any revenue associated with a confirmed
e-Allegation was recovered or lost.
Additionally, CBP did not adequately monitor referrals forwarded to ICE HSI or
use mechanisms established in its standard operating procedures (SOP) to
monitor those referrals. CBP’s main mechanism to monitor referrals is through
CEAR meeting minutes. However, we found the CEAR meeting minute reports
were not consistent and using them to identify the cases that CBP referred to
ICE HSI, or their status, was difficult. Finally, regarding referrals to DOJ, Office
of Chief Counsel offices responsible for providing legal assistance in connection
with processing delinquent duty, liquidated damage, and penalty cases lacked
documented policies and procedures for attorneys on processing those cases.
Treasury Office of Inspector General Semiannual Report—March 2024 12
Office of Audit – Significant Audits and Other Products
We recommended that that the CBP Commissioner ensures (1) TRLED officials
enhance its procedures to ensure that the statuses of e-Allegations cases are
timely, accurate, and complete in its information system; monitor those
procedures to ensure that they are working as intended, and assess the need for
related training; (2) TRLED staff coordinates with appropriate internal offices to
track revenue recovered from the e-Allegations program and uses the
information to evaluate the program’s performance in achieving objectives;
(3) Office of Trade (OT) and Office of Field Operations (OFO) officials
responsible for oversight of the CEAR process monitor referrals to ICE HIS and
ensure established mechanisms to track ICE HSI referrals are followed; (4) OT
and OFO officials review and update the CEAR SOPs to ensure the SOPS
continue to be relevant and effective in meeting objectives and addressing risks;
(5) OT and OFR officials assess the need for performance metrics once the
CEAR SOPs are updated; and (6) Office of Chief Counsel, in regards to the
referrals to DOJ, establishes documented policies for processing delinquent
duty, liquidated damage, and penalty cases; and include its organization
structure, roles and responsibilities, and delegations of authority. CBP concurred
with our recommendations and management’s planned corrective actions met
the intent of our recommendations. (OIG-24-026)
Anti-Money Laundering/Terrorist Financing and Intelligence
We conduct audits of Treasury’s anti-money laundering and terrorist financing
programs. We issued the following report during this semiannual period.
TFI’s Ukraine-/Russia-related Sanctions Program Complied With
Requirements But Designation Decision Records Were Not
Consistently Complete and Closed Timely
We found that the Office of Terrorism and Financial Intelligence’s
Ukraine-/Russia-related sanctions program (1) complied with applicable laws and
regulations, including the Countering America’s Adversaries Through Sanctions
Act of 2017, and (2) sanctions decisions and deliberations were properly
approved, but not always properly documented. The Office of Foreign Assets
Control (OFAC) maintained an effective process of review and approval of
designation decisions, and general license decisions were properly approved and
documented. The records related to designation decisions lacked complete
documentation of review, signatures, and/or documents required by OFAC’s
Treasury Office of Inspector General Semiannual Report—March 2024 13
Office of Audit – Significant Audits and Other Products
Office of Global Targeting standard operating procedure (SOP). In addition,
designation case files were not always administratively closed timely.
We recommended that the OFAC Director (1) develop and implement a
close-out checklist for the evidentiary memoranda and OFAC’s Administrative
System for Investigations and Sanctions (OASIS) case files that encompasses all
necessary documentation to ensure they are complete and closed timely, and
(2) update the Office of Global Targeting SOP to establish responsibilities and
expected timeframes for review of evidentiary memoranda and OASIS case files
to ensure they are complete and closed timely. OFAC management stated that
the implementation of our recommendations will support the continued success
of OFAC’s mission. OFAC management told us they are committed to reviewing
and making modifications, including a close-out checklist, to relevant SOPs.
OFAC also plans to update and replace its current OASIS case management
system and incorporate design features not currently feasible, including requiring
certain documents to be uploaded prior to closing out a case and automating
the closure of cases following publication of target names on the Specially
Designated Nationals and Blocked Persons List. (OIG-24-025)
Treasury Office of Inspector General Semiannual Report—March 2024 14
Office of Audit – Significant Audits and Other Products
Other Audits of Treasury Programs and Operations
Inquiry on Revolving Door Between the Largest Accounting Firms
and the Department of the Treasury
We performed an inquiry in response to a Congressional request to the Deputy
Inspector General for Treasury and the Inspector General for the Treasury
Inspector General for Tax Administration on the “revolving door between the
largest accounting firms and Treasury.”
We found that Treasury has policies and procedures in place to protect Treasury
and its tax policies and revenue rulings from undue influence by employees with
potential conflicts of interest. Specifically, Treasury’s tax guidance process
includes numerous stages of review and approval of tax guidance before
publication. Due to the various levels of review and segregation of duties,
absent collusion, the risk that tax guidance could be influenced by an employee
with potential conflicts of interest is low. We did not identify any Treasury
policies and procedures related to ethics and conflicts of interest that did not
comply with applicable ethics laws and regulations. However, in reviewing
Treasury's Office of the Assistant General Counsel for General Law, Ethics, and
Regulation’s (GLER) policies and procedures related to ethics and conflicts of
interest, we determined that the GLER ethics tracking process for providing
advice and counsel could be enhanced.
We recommended that GLER: (1) develops and implements standard operating
procedures, including monitoring, to ensure ethics officials fully utilize the Ethics
Tracker database to track requests, substantive advice and counsel provided, as
well as documentation of final resolution of issues; and (2) considers completing
a cost-benefit analysis to determine if a fully integrated and automated tracking
system would benefit GLER with its ethics responsibilities. Treasury
management concurred with all recommendations. Management’s planned
corrective actions met the intent of our recommendations. (OIG-CA-24-015)
Treasury Office of Inspector General Semiannual Report—March 2024 15
Office of Investigations – Significant Investigations
CARES Act Investigations
Coronavirus Relief Fund Grant Fraud Unsubstantiated
On March 12, 2024, the Office of Inspector General (OIG) completed its report of
investigation for a joint case with the Federal Bureau of Investigation initiated after
developing information regarding possible Coronavirus Relief Fund (CRF) grant fraud
committed by a business in South Dakota and disbursed by the South Dakota Bureau
of Finance and Management. Allegedly, the business obtained $710,000 in CRF funds
by certifying to be in South Dakota despite being owned and operated in Texas.
Department of the Treasury (Treasury) OIG unsubstantiated the allegations when the
investigation revealed the business to be active and operating in South Dakota, to
include a business bank account with financial transactions processed in South Dakota.
Unsubstantiated Collusion Between a Private Business and a Tribe
On February 21, 2024, the OIG completed its report of investigation for a joint case
with the Federal Bureau of Investigation initiated upon an anonymous complaint
alleging collusion between a private business and a tribe in which the tribe paid the
business approximately $1.5million in Coronavirus Disease 2019 (COVID-19) funds for
sanitizing and cleaning tribal buildings. The complaint alleged these cleaning services
were not provided. The investigation revealed the business competitively bid for the
cleaning contract and provided COVID-19 sanitizing and cleaning services for the tribal
buildings.
Other Significant Investigations
Sovereign Citizen Fabricated Money Order to Pay for Child Support
On December 19, 2023, the OIG completed its report of investigation that residents of
Louisiana attempted to defraud the Louisiana Child Support Department using
fabricated money orders referencing the Department of the Treasury and containing
sovereign citizen language. The investigation revealed that the fabricated money orders
totaled $712,000, but none of them were negotiated, therefore there was no dollar
loss. The case was presented for review of potential criminal prosecution to the U.S.
Attorney’s Office (USAO) for the Middle District of Louisiana and declined due to no
monetary loss.
Treasury Office of Inspector General Semiannual Report—March 2024 16
Office of Investigations – Significant Investigations
Emergency Rental Assistance Funds Disbursement Unsubstantiated
On October 5, 2023, OIG completed its investigation from a complaint received from
the California Department of Housing and Community Development. The complaint
alleged that approximately $280,000 in Emergency Rental Assistance (ERA) funds
were disbursed because of specifically identified fraudulent applications. Treasury OIG
unsubstantiated the complaint through reviews of supporting documentation provided
by the complainant and witness and subject interviews.
Stolen Emergency Rental Assistance Funds
On January 10, 2024, the OIG completed its report of investigation for a case initiated
upon information that $121,000 in ERA funds were stolen through a business email
compromise scheme. Treasury OIG substantiated that a subject scammed a victim
business into transferring business funds to an account owned and operated by the
subject. Extensive Treasury OIG efforts to identify the subject ultimately were not
successful.
Active Fugitive Stole Emergency Rental Assistance Funds in Texas
Our Office of Investigations completed its report of investigation for a case initiated
upon notification that the Houston-Harris County Emergency Rental Assistance
Program was defrauded of approximately $83,000 by means of fraudulent applications
for assistance submitted by a known subject. Following the initial investigation, it was
determined this matter did not meet the federal prosecution thresholds for the USAO,
District of Texas, and prosecution was deferred to Harris County, Texas. The subject
was indicted for Felony Theft in Harris County Court and a warrant issued for the
subject’s arrest is currently active. The subject is considered a fugitive from justice
and Treasury OIG will re-open the investigation when the subject is located, and an
arrest is made.
Emergency Rental Assistance Fraud Substantiated in Ohio
On February 28, 2024, the OIG completed an ERA fraud investigation into properties
located in Columbus, Ohio. The subject of the investigation utilized identities of
individuals who did not reside at the residences in which applications were funded.
Tenant verification was conducted and four (4) of the total 31 listed tenants on ERA
applications were confirmed to have been submitted fraudulently totaling $16,000.
Due to the transient nature of many of the listed tenants, additional witness contacts
Treasury Office of Inspector General Semiannual Report—March 2024 17
Office of Investigations – Significant Investigations
were unsuccessful. This matter was presented to the Southern District of Ohio’s
USAO and presented to the Franklin County District Attorney’s Office, in which both
offices declined prosecution, due to the loss amount being below threshold and lack of
witnesses.
Theft of Pandemic Funds Unsubstantiated
On November 15, 2023, the OIG completed its report of investigation into allegations
from the Pandemic Response Accountability Committee task force that a private citizen
used their daughter’s Personally Identifiable Information (PII) to apply for Paycheck
Protection Program loans and Economic Injury Disaster Loans for a company that she
was not affiliated with. The investigation unsubstantiated the allegations. The
investigation revealed that the daughter was affiliated with the company and listed as
a registered agent for the company on bank documents dated several years prior to the
Paycheck Protection Program or Economic Injury Disaster Loan programs creation.
FinCEN Employee Sent Classified Information Through a Non-Secure
Network
During this reporting period, the OIG completed its investigation for a case initiated
upon receipt of information from the Office of Intelligence and Analysis (OIA) that an
email containing information at the Confidential level was sent by an Office of Foreign
Assets Control (OFAC) employee to several other Treasury users through an
unclassified Treasury email system. The OIG substantiated the allegation based on
interviews with OIA employees and the OFAC employee who sent the email. The
information in the email was open-source research conducted by the OFAC employee,
that when aggregated, likely resulted in classified information, as detailed in the
Department of the Treasury, Security Classification Guide. A report was issued to OIA
for their information.
Personally Identifiable Information Disclosed by FinCEN Employee
During this reporting period, the OIG completed its report of investigation that a
Financial Crimes Enforcement Network (FinCEN) employee disclosed several instances
of PII in an attachment to their informal Equal Employment Opportunity complaint. The
OIG investigation substantiated that the employee disclosed PII in violation of policy.
The OIG also confirmed that an email containing the PII was sent to an Equal
Employment Opportunity counselor at the U.S. Postal Service. Once notified, the U.S
Postal Service counselor destroyed the email and confirmed that it had not been shared
Treasury Office of Inspector General Semiannual Report—March 2024 18
Office of Investigations – Significant Investigations
with anyone else. Criminal prosecution of the FinCEN employee was presented and
declined by the USAO for the Eastern District of Virginia. Treasury OIG provided a
report to FinCEN for their information.
Time and Attendance Fraud of Treasury OIG Employee Substantiated
During this reporting period, the OIG completed its report of investigation on possible
time and attendance fraud involving a Treasury OIG employee. The OIG employee
failed to submit the proper paperwork to request temporary telework from an
unapproved location. The investigation substantiated that the OIG employee engaged
in unapproved temporary telework on two separate occasions. The employee was
given a written reprimand and re-trained on proper procedures.
Lack of Candor of Treasury OIG Employee Substantiated
During this reporting period, the OIG completed its report of investigation that a
Treasury OIG employee potentially engaged in time and attendance fraud and
teleworked from an unauthorized location without an approved temporary telework
agreement. The OIG unsubstantiated both allegations; however, the investigation
discovered that the OIG employee altered and forwarded a coworker’s training
confirmation email to their supervisor, purporting it to be their own because they did
not attend the training. The OIG substantiated the allegation of a lack of candor based
on interviews and computer forensics examinations. The OIG employee resigned from
their position.
Treasury Office of Inspector General Semiannual Report—March 2024 19
Treasury OIG Accomplishments and Activities
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, served as the Chair of the
Council of the Inspectors General on Integrity and Efficiency (CIGIE) Federal Audit
Executive Council.
Pauletta Battle, Deputy Assistant Inspector General for Financial Management and
Transparency Audits, serves as CIGIE’s Accounting and Auditing Policy Committee
member on the Federal Accounting Standards Advisory Board.
Cecilia Howland, Deputy Assistant Inspector General for Cyber and Financial
Assistance Audits, is the National Single Audit Coordinator for Treasury.
Treasury Office of Inspector General Semiannual Report—March 2024 20
Statistical Summary
Summary of Treasury OIG Activities
October 1, 2023, through March 31, 2024
Number or
OIG Activity Dollar Value
Office of Counsel Activities
Regulation and legislation reviews 15
Instances where information was refused 0
Office of Audit Activities
Reports issued and other products 39
Disputed audit recommendations 0
Significant revised management decisions 0
Management decision in which the Inspector General disagrees 0
Monetary benefits (audit)
Questioned costs $300,000
Funds put to better use $0
Total monetary benefits $300,000
Office of Investigations Activities*
Criminal and judicial actions (including joint investigations)
Investigative reports issued 96
Cases referred for prosecution and/or litigation 32
Individuals referred for criminal prosecution to the Department of Justice 33
Individuals referred for criminal prosecution to state and local authorities 7
Cases accepted for prosecution and/or litigation 6
Arrests 1
Indictments/information 7
Convictions (by trial and plea) 13
*During the reporting period, subjects were sentenced to 1456 months of prison time, 342 months of
probation, 10 days of community service, and ordered to pay fines, restitution, and court fees in the
amount of $7,160,330.
Metrics Used for Office of Investigations Activities
Department of the Treasury (Treasury) Office of Inspector General (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 2024 21
Statistical Summary
Reports with Unimplemented Recommendations
Issued prior to October 1, 2023
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 (NOAA) Gulf Coast Ecosystem Restoration Science, Observation,
Monitoring, and Technology Program; and of U.S. Department of Homeland Security,
U.S. Customs and Border Protection’s (CBP) programs and activities related to
protecting revenue.
Treasury OIG is reporting 101 open and unimplemented recommendations for
45 reports issued prior to October 1, 2023, with over $2.2 billion in potential cost
savings.
Treasury OIG considers all unimplemented recommendations for reports issued over
6 months to be significant.
Treasury Programs and Operations
Fiscal Report Number Report Title Date Issued
Year
2016 OIG-16-059 GENERAL MANAGEMENT: Treasury Has 09/16
Policies and Procedures to Safeguard
Classified Information But They Are Not
Effectively Implemented
1. 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 recommendation.
Treasury Office of Inspector General Semiannual Report—March 2024 22
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2018 OIG-18-044 TERRORIST FINANCING/MONEY 04/18
LAUNDERING: Audit of the Office of
Intelligence and Analysis’ Authorities and
Actions Related to U.S. Persons’
Financial Information
1. The Under Secretary for Terrorism and Financial Intelligence, as
expeditiously as possible, should implement a compliance monitoring
program to assess whether intelligence analysts’ activities are conducted in
accordance with Office of Intelligence and Analysis 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
recommendation.
Fiscal Report Number Report Title Date Issued
Year
2019 OIG-19-007 INFORMATION TECHNOLOGY: 10/18
Department of the Treasury Federal
Information Security Modernization Act
Fiscal Year 2018 Performance Audit
1. Treasury Inspector General for Tax Administration (TIGTA) management
should establish a current enterprise baseline of software and related
configurations for the TIGTA System. Management agreed with the
recommendation.
Fiscal Report Number Report Title Date Issued
Year
2020 OIG-20-003 INFORMATION TECHNOLOGY: 10/19
Department of the Treasury Federal
Information Security Modernization Act
Fiscal Year 2019 Performance Audit
1. U.S. Mint (Mint) management should finalize and implement its bureau-wide
privacy program that includes a strategic organizational privacy plan for
implementing applicable privacy control and procedures in
accordance with National Institute of Standards and Technology 800-53.
Management agreed with the recommendation.
Treasury Office of Inspector General Semiannual Report—March 2024 23
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2020 OIG-20-007 DATA ACT: Treasury Continues to Make 11/19
Progress in Meeting its DATA Act
Reporting Requirements
1. Treasury’s Assistant Secretary for Management, working as needed with
Treasury’s Senior Accountable Official, the Senior Procurement Executive,
reporting entities, the Program Management Office, and the Office of
Management and Budget should 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 Digital Accountability
and Transparency Act (DATA Act) Information Model Schema. Management
agreed with the recommendation.
Fiscal Report Number Report Title Date Issued
Year
2020 OIG-20-022 FINANCIAL MANAGEMENT: 12/19
Management Report for the Audit of
the Department of the Treasury’s
Consolidated Financial Statements for
Fiscal Years 2019 and 2018
1. Bureau of the Fiscal Service (Fiscal Service) management finalize policies
and procedures to review audit logs of production DB2 servers.
2. Implement an oversight process to ensure that designated Fiscal Service
personnel:
a. Reviews the security logs for the UNIX and DB2 servers hosting the
Payment Information Repository, Judgment Fund Internet Claim System,
and Security Payment System applications on a pre-defined frequency, as
indicated in the Fiscal Service Baseline Security Requirements,
b. Formally documents completion of their reviews and any escalations to
the Information System Security Office, and
c. Retains the audit logs and documentation of its reviews for 18 months,
as required by the Baseline Security Requirements.
3. Periodically review Fiscal Service management’s implementation and
operation of the review the security audit logs for the UNIX and DB2 servers
hosting the Payment Information Repository, Judgment Fund Internet Claim
System, and Security Payment System applications to determine that Fiscal
Service management completes the reviews on a pre-defined basis,
documents completion of the reviews and escalations, and maintains such
documentation.
Treasury Office of Inspector General Semiannual Report—March 2024 24
Statistical Summary
4. Establish an effective enforcement process or mechanism to ensure that (a)
UNIX and DB2 events and monitoring controls are followed, and (b) Fiscal
Service management has confidence it consistently reviews for potential
unauthorized or inappropriate activity.
5. Develop and implement documentation to assign responsibility for ensuring
adequacy of UNIX and database security and baseline settings.
6. Update existing UNIX and database configuration security baseline
documents to ensure that these documents fully incorporate and enforce
the components of the Defense Information Systems Agency Security
Technical Implementation Guides. Management should document any
deviations from the Security Technical Implementation Guides and note
compensating controls that mitigate the security risk to an acceptable level.
7. Develop, document, and implement policies, procedures, and controls to
conduct periodic reviews of actual UNIX and database settings against the
security configuration baselines.
8. Provide logging and monitoring of security related events to include the
retention of evidence of reviews performed.
9. Develop a baseline of essential security settings and specifying that baseline
as the standard to be observed.
10. Implement corrective actions to address all vulnerabilities associated with
the baseline enforcement to include removing the three default user
accounts on UNIX servers. Management agreed with the recommendations.
Fiscal Report Number Report Title Date Issued
Year
2020 OIG-20-023 BILL AND COIN MANUFACTURING: BEP 12/19
Improved Governance and Oversight over
Note Development and Production But
Challenges Remain
1. The Director of the Bureau of Engraving and Printing (BEP) should finalize
the required 5-year update of the memorandum of understanding with the
Board of Governors of the Federal Reserve System (Board) to formalize BEP
and the Board's responsibilities and authorities related to notes including
activities, procedures, and obligations related to the annual production,
destruction, and research and development of notes. Management agreed
with the recommendation.
Treasury Office of Inspector General Semiannual Report—March 2024 25
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2020 OIG-20-027 RESOURCE MANAGEMENT: Audit of the 02/20
Department of the Treasury
Departmental Offices Executive Pay
Adjustments, Bonuses, and Awards
1. Office of the Deputy Assistant Secretary for Human Resources and Chief
Human Capital Officer and Office of Executive Resources calculate the
overpayment amounts for the two Departmental Office Senior Executive
Service members whose pay was set higher than allowed by regulation.
Management agreed with the recommendation.
Fiscal Report Number Report Title Date Issued
Year
2020 OIG-20-029 GULF COAST RESTORATION: Jefferson 03/20
Parish's Internal Control Over Federal
Awards
1. & 2. The Fiscal Assistant Secretary should ensure that deficiencies identified in
Jefferson Parish, Louisiana's controls over Federal awards are considered as
part of the Treasury's oversight of future awards as well as risk
assessments of Jefferson Parish as required by the Uniform Administrative
Requirements, Cost Principals, and Audit Requirements for Federal Awards
(2 CFR Part 200). This recommendation is counted as two
recommendations because it applies to both findings in the report.
Management agreed with the recommendations.
Fiscal Report Number Report Title Date Issued
Year
2020 OIG-20-040 BILL AND COIN MANUFACTURING: 06/20
Audit of Bureau of Engraving and
Printing’s Implementation of Security
Features and Meaningful Access for the
Blind and Visually Impaired into New
Note Design
1. The Director of BEP in collaboration, as necessary, with members of the
United States Currency Program, should ensure the Advanced Counterfeit
Deterrence Steering Committee charter is updated in a timely manner, and
as needed, to ensure roles, responsibilities, and current practices, such as
the attendance of Advanced Counterfeit Deterrence Steering Committee
monthly meetings by appropriate personnel, are clearly defined and
Treasury Office of Inspector General Semiannual Report—March 2024 26
Statistical Summary
communicated to its members. Management agreed with the
recommendation.
Fiscal Report Number Report Title Date Issued
Year
2020 OIG-20-042 MANUFACTURING AND REVENUE: Mint 08/20
Controls Over Raw Materials and Coin
Exchange Programs Need Improvement
1. The Mint Director should strengthen and finalize SOPs for all coin exchange
programs before accepting any redemptions. This would include using tests
and subject matter experts to authenticate the genuineness of coins
redeemed, as well as working with the Board to develop appropriate
interagency procedures to assure the integrity of the coin redemption
process for uncurrent coins.
2. Follow all SOPs, including but not limited to, procedures related to
sampling, inspecting, and testing coins, and appropriately document
redemptions. Additionally, ensure that adequate background investigations
are conducted on bulk redeemers and decisions to allow participation into
the Mutilated Coin Redemption Program are based on relevant data from the
background investigation. The Mint should add criteria, such as obtaining
financial statements for analyses of the potential bulk redeemers and
performing site visits at their premises, as part of the background
investigation process for entry into the program. The Mint should document
how this criteria was met, and if these steps were not performed, the
reasons why.
3. Ensure that all coins returned to the Mint and removed from circulation are
destroyed timely and sufficiently accounted for. Management agreed with
the recommendations.
Treasury Office of Inspector General Semiannual Report—March 2024 27
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2021 OIG-21-021 FINANCIAL MANAGEMENT: 02/21
Management Report for the Audit of
the Department of the Treasury's
Consolidated Financial Statements for
Fiscal Years 2020 and 2019
1. Fiscal Service management should perform a review of the current system
environment against the Configuration Management Database to ensure
that all information system components are inventoried.
2. Perform a risk assessment over the subject matter and determine the
appropriate personnel to be responsible for monitoring and updating the
Configuration Management Database.
3. Update policy and procedures related to the above recommendations and
disseminate the documentation to enforce such policy and procedures.
Management agreed with the recommendations.
Fiscal Report Number Report Title Date Issued
Year
2021 OIG-21-026 BILL AND COIN MANUFACTURING: 04/21
Audit of Physical Security at U.S. Mint
Production Facilities (Sensitive But
Unclassified)
1&2. These recommendations are Sensitive But Unclassified. Management agreed
with the recommendations.
Fiscal Report Number Report Title Date Issued
Year
2022 OIG-22-004 INFORMATION TECHNOLOGY: 10/21
Department of the Treasury Federal
Information Security Modernization Act
Fiscal Year 2021 Performance Audit for
Collateral National Security Systems
(Sensitive But Unclassified)
1-5. These recommendations are Sensitive But Unclassified. Management agreed
with the recommendations.
Treasury Office of Inspector General Semiannual Report—March 2024 28
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2022 OIG-22-005 CYBERSECURITY/INFORMATION 10/21
TECHNOLOGY: Department of the
Treasury Federal Information Security
Modernization Act Fiscal Year 2021
Performance Audit (Sensitive But
Unclassified)
1&2. These recommendations are Sensitive But Unclassified. Management agreed
with the recommendations.
Fiscal Report Number Report Title Date Issued
Year
2022 OIG-22-008 DATA ACT: Treasury Submitted Higher 11/21
Quality Non-IRS Data in its Fiscal Year
2020 Third Quarter DATA Act
Submission, However Improvements are
Still Needed
1. Treasury should continue working with the Treasury Executive Office for
Asset Forfeiture to ensure proper submission of Equitable Sharing financial
assistance awards on USAspending.gov. Management agreed with the
recommendation.
Fiscal Report Number Report Title Date Issued
Year
2022 OIG-22-037 CYBERSECURITY/INFORMATION 09/22
TECHNOLOGY: Federal Information
Security Modernization Act Fiscal Year
2022 Performance Audit for the
Unclassified Systems (Sensitive But
Unclassified)
1. This recommendation is Sensitive But Unclassified. Management agreed
with the recommendation.
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-003 Inquiry Into Allegations of Racially 10/22
Disparate Treatment of U.S. Mint
Employee
1. Mint leadership should proactively evaluate patterns and trends in
Administrative Investigations, Management Inquiries, and Equal Employment
Opportunity complaints as it pertains to demographic characteristics
including, but not necessarily limited to, race and ethnicity. To facilitate this
type of analysis, the data collection process for Administrative
Investigations and Management Inquiries should be improved to ensure the
Treasury Office of Inspector General Semiannual Report—March 2024 29
Statistical Summary
capture of necessary information and to ensure consistency of data
collected.
2. Enhance efforts to proactively evaluate patterns and trends in Mint
workforce statistics such as hiring and promotion practices as it pertains to
demographic characteristics including, but not necessarily limited to, race
and ethnicity. As part of this proactive evaluation, steps should be taken to
identify potential adverse trends, understand why they exist, and review
whether there are opportunities to address them.
3. Ensure that the Mint workforce has the proper policies, resources, and tools
to aid employee understanding of how to file complaints pertaining to
harassment, employee misconduct, and potential deficiencies and/or
vulnerabilities in Mint operations, programs, and/or systems. This also
pertains to ensuring that policies for Management Inquiries and
Administrative Investigations are clearly written so that employees
understand the distinction between the two processes. To ensure that
efforts are effective, consideration should be given to conducting surveys
and/or other forms of outreach among the workforce as it pertains to the
complaint process. Management agreed with the recommendations.
Treasury Office of Inspector General Semiannual Report—March 2024 30
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-23-023 Audit of Air Carrier Worker Support 03/23
Certifications - Wings Air Helicopters,
LLC.
1. The Chief Recovery Officer seek reimbursement of the overpayment of Air
Carrier Payroll Support Program (PSP1) financial assistance. The amount is
sensitive information.
2. Review Wings Air Helicopters' requested amount for unallowable expenses,
under Payroll Support Program Extension (PSP2) and Payroll Support
Program 3 (PSP3), and seek reimbursement for the overpayment, if
applicable. Management agreed with the recommendations.
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-23-024 CORONAVIRUS DISEASE 2019 04/23
PANDEMIC RELIEF PROGRAMS: Audit
of Air Carrier Worker Support
Certifications - Constant Aviation, LLC
1. The Chief Recovery Officer should seek reimbursement of the $52,003
overpayment of the PSP1 financial assistance.
2. Review Constant's requested amount for unallowable expenses under PSP2
and PSP3, and seek reimbursement for the overpayment, if applicable.
Management agreed with the recommendations.
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-23-026 FINANCIAL MANAGEMENT: Audit of 05/23
Treasury's Compliance with the PIIA
Requirements for Fiscal Year 2022
1. Treasury's Risk and Control Group work with management at the Bureau of
the Fiscal Service, Treasury Forfeiture Fund, and the Special Inspector
General for Troubled Assets Relief Program to complete sufficient review of
the program-specific risk assessments to better ensure management
responses and justifications to risk assessment questions are accurate and
justifications properly support the responses to the questions. Management
agreed with the recommendation.
Treasury Office of Inspector General Semiannual Report—March 2024 31
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-23-027 CORONAVIRUS DISEASE 2019 06/23
PANDEMIC RELIEF PROGRAMS: Audit
of Air Carrier Worker Support
Certifications - Paradigm Jet
Management, Inc.
1. The Chief Recovery Officer seek reimbursement of the $71,023
overpayment of PSP1 financial assistance.
2. Review Paradigm Jet Management, Inc. requested amount for unallowable
expenses, under PSP2 and PSP3, and seek reimbursement for the
overpayment, if applicable. Management agreed with the recommendations.
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-23-028 CORONAVIRUS DISEASE 2019 06/23
PANDEMIC RELIEF PROGRAMS: Audit
of Air Carrier Worker Support
Certifications - Ground Services
International, Inc.
1. The Chief Recovery Officer should review Ground Services International,
Inc.'s and Inflight Catering's requested amount for unallowable expenses,
under PSP2 and PSP3, and seek reimbursement for the overpayment, if
applicable. Management agreed with the recommendation.
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-23-029 Audit of Air Carrier Worker Support 06/23
Certifications - Bird Acquisition, LLC
1. The Chief Recovery Officer should (1) seek reimbursement of the $115,626
overpayment of PSP1 financial assistance
2. Review the contractor's requested amount for unallowable expenses under
PSP2 and PSP3, and seek reimbursement for the overpayment, if
applicable. Management agreed with the recommendations.
Treasury Office of Inspector General Semiannual Report—March 2024 32
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-23-030 ANTI-MONEY LAUNDERING/TERRORIST 08/23
FINANCING: Audit of FinCEN's
Management of BSA Data - Suppression
Report
1. The Director of FinCen should require agencies that receive bulk data to
remove suppressed records as a condition of their MOUs.
2. Publish and communicate guidance explaining how FinCEN will notify bulk
data agencies of records to be suppressed within bulk data files and
specifying the timelines for FinCEN and the agencies’ required actions
regarding the suppression of the records. Management agreed with the
recommendations.
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-018 Desk Review of Chippewa Cree Tribe’s 06/23
Use of Coronavirus Relief Fund Proceeds
1. Treasury OIG should pursue obtaining documentation from the Chippewa
Cree Tribe's management and ensure reporting corrections are made within
the GrantSolutions portal. Further, based on Chippewa Cree Tribe's
responsiveness to Treasury OIG’s requests and its ability to provide
documentation, Treasury OIG should determine if a focused audit is feasible
for Grants greater than or equal to $50,000 and Direct Payments greater
than or equal to $50,000. Management agreed with the recommendation.
($75,091 Questioned Costs)
Treasury Office of Inspector General Semiannual Report—March 2024 33
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-024 Desk Review of Lancaster County, 06/23
Pennsylvania’s Use of Coronavirus Relief
Fund Proceeds
1. Treasury OIG should pursue obtaining documentation from Lancaster
County personnel and ensure reporting corrections are made. Further, based
on Lancaster County’s responsiveness to Treasury OIG’s requests and its
ability to provide documentation, Treasury OIG should determine if a full-
scope audit is feasible. Management agreed with the recommendation.
($38,793,071 Questioned Costs)
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-025 Desk Review of State of California’s Use 07/23
of Coronavirus Relief Fund Proceeds
1. Treasury OIG should confirm that appropriate corrections have been made,
or if not, determine whether the ineligible expenditures have been returned
to Treasury. Management agreed with the recommendation.
($6,952 Questioned Costs)
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-026 Desk Review of Turtle Mountain Band of 07/23
Chippewa Indians’ Use of Coronavirus
Relief Fund Proceeds (Redacted)
1. Treasury OIG should pursue obtaining supporting documentation from the
Turtle Mountain Band of Chippewa Indians’ (TMBCI) personnel and ensure
reporting corrections are made. Further, based on TMBCI’s responsiveness
to Treasury OIG’s requests and its ability to provide documentation,
Treasury OIG should determine if a full-scope audit is feasible.
($32,333,620 Questioned Costs)
2. Follow-up with TMBCI personnel to obtain sufficient support to quantify
expenditures related to these allegations and determine whether the
amounts represent eligible CRF costs. Management agreed with the
recommendations.
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-027 Desk Review of Los Angeles County, 07/23
California’s Use of Coronavirus Relief
Fund Proceeds
1. Treasury OIG should pursue obtaining documentation from LA County
management and ensure reporting corrections are made. Further, based on
LA County’s responsiveness to Treasury OIG’s requests and its ability to
provide documentation, Treasury OIG should determine if a focused audit is
Treasury Office of Inspector General Semiannual Report—March 2024 34
Statistical Summary
feasible over LA County’s Contracts greater than or equal to $50,000 and
Aggregate Reporting less than $50,000. Management agreed with the
recommendation. ($249,052,032 Questioned Costs)
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-028 Desk Review of City of Dallas, Texas’s 07/23
Use of Coronavirus Relief Fund Proceeds
1. Treasury OIG pursue obtaining documentation from Dallas management
related to the Aggregate Payments to Individuals and ensure that
expenditures reported are properly supported. Further, based on Dallas’
responsiveness to Treasury OIG’s requests and its ability to provide
documentation, we recommend Treasury OIG determine if a focused audit
on Aggregate Payments to Individuals is feasible. Management agreed with
the recommendation. ($2,211,594 Questioned Costs)
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-029 Desk Review of State of Florida’s Use of 07/23
Coronavirus Relief Fund Proceeds
1. Treasury OIG should pursue obtaining missing documentation from Florida
management and ensure reporting corrections are made, or whether
recoupment of funds is necessary. Further, based on Florida's
responsiveness to Treasury OIG's requests and its ability to provide
sufficient documentation, Treasury OIG should determine if a full-scope
audit over Florida's use of its CRF proceeds is feasible. Management agreed
with the recommendation. ($893,154,398 Questioned Costs)
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-030 Desk Review of San Bernardino County, 07/23
California’s Use of Coronavirus Relief
Fund Proceeds
1-3. San Bernardino County management should provide missing supporting
documentation and make necessary reporting corrections. Additionally,
Treasury OIG should determine if a focused audit over Grants Greater Than
or Equal to $50,000 is feasible. Management agreed with the
recommendations. ($4,151,612 Questioned Costs)
Treasury Office of Inspector General Semiannual Report—March 2024 35
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-032 Desk Review of Phoenix, Arizona’s Use 07/23
of Coronavirus Relief Fund Proceeds
1. Treasury OIG follow-up with Phoenix management on the finalization of its
reconciliation and reporting corrections. Based on Phoenix management’s
responsiveness to Treasury OIG’s requests, and its ability to provide
sufficient documentation, we recommend that Treasury OIG determine if a
focused audit is feasible for Grants greater than or equal to $50,000.
Management agreed with the recommendation. ($147,379 Questioned
Costs)
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-033 Desk Review of Pleasant Point Indian 07/23
Reservation, Maine’s Use of Coronavirus
Relief Fund Proceeds
1. Treasury OIG follow-up on necessary reporting corrections for Contracts
greater than or equal to $50,000, Transfers greater than or equal to
$50,000, and Aggregate Payments to Individuals. Management agreed with
the recommendation. ($339,672 Questioned Costs)
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-034 Desk Review of State of Texas’ Use of 07/23
Coronavirus Relief Fund Proceeds
1. Treasury OIG obtain documentation from Texas management and follow-up
on necessary reporting corrections. Further, based on Texas’
responsiveness to Treasury OIG’s requests and its ability to provide
sufficient documentation, we recommend Treasury OIG determine if a
focused audit is feasible for Contracts greater than or equal to $50,000 and
Grants greater than or equal to $50,000. Management agreed with the
recommendation. ($17,288,575 Questioned Costs)
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-035 Desk Review of the State of 07/23
Tennessee’s Use of Coronavirus Relief
Fund Proceeds
1. Treasury OIG should pursue obtaining documentation from Tennessee
personnel and ensure reporting corrections are made. Further, based on
Tennessee's responsiveness to Treasury OIG's requests and its ability to
provide documentation and remove ineligible transactions, Treasury OIG
should determine if a focused audit is feasible for Grants greater than or
equal to $50,000 and Aggregate payments to individuals. Management
agreed with the recommendation. ($1,162,364 Questioned Costs)
Treasury Office of Inspector General Semiannual Report—March 2024 36
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-037 Desk Review of State of Ohio’s Use of 07/23
Coronavirus Relief Fund Proceeds
1&2. State of Ohio management should provide missing supporting
documentation and make necessary reporting corrections.
3. Provide missing supporting documentation and make necessary reporting
corrections. Additionally, Treasury Office of Inspector General should obtain
information to determine if there are other ineligible severance pay
transactions in addition to those already identified as part of the desk
review. Management agreed with the recommendations. ($86,801
Questioned Costs)
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-038 Desk Review of Native Village of Point 07/23
Hope’s Use of Coronavirus Relief Fund
Proceeds
1. Treasury OIG follow-up on the missing documentation and make a
determination whether to conduct a full-scope audit of Point Hope. In
addition, Treasury OIG personnel determine whether to take further action,
up to and including recoupment of Point Hope’s CRF proceeds, based on
the scope limitation and potential noncompliance with the records retention
requirement. Management agreed with the recommendation. ($2,348,064
Questioned Costs)
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-039 Desk Review of the Commonwealth of 08/23
the Northern Mariana Islands’ Use of
Coronavirus Relief Fund Proceeds
1. Treasury OIG should request missing documentation from the
Commonwealth of the Northern Mariana Islands management and follow-up
on necessary reporting corrections. Further, based on Commonwealth of
the Northern Mariana Islands responsiveness to Treasury OIG’s requests
and its ability to provide sufficient documentation, Treasury OIG should
determine if a full scope audit is feasible. Management agreed with the
recommendation. ($33,681,692 Questioned Costs)
Treasury Office of Inspector General Semiannual Report—March 2024 37
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-040 Desk Review of the Commonwealth of 08/23
Puerto Rico’s Use of Coronavirus Relief
Fund Proceeds
1. Treasury OIG should follow-up to obtain the status of these Single Audits.
Treasury OIG should pursue obtaining missing documentation from Puerto
Rico’s management and follow-up on necessary reporting corrections within
the GrantSolutions portal. Based on Puerto Rico’s responsiveness to
Treasury OIG’s requests and management’s ability to provide
documentation, Treasury OIG should determine if a full scope audit is
feasible. Management agreed with the recommendation. ($33,681,692
Questioned Costs)
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-041 Desk Review of Navajo Nation Tribal 08/23
Government's Use of Coronavirus Relief
Fund Proceeds (Redacted)
1. Treasury OIG should follow-up on Navajo Nation management's corrective
action related to $141,187 in questioned costs reported in Single Audit
finding number 2020-009.
2. Follow-up to obtain the status of the Navajo Nation's 2021 Single Audit.
3-5. Follow-up with Navajo Nation management to obtain missing
documentation to support expenditures and that Navajo Nation has made
necessary reporting corrections; and determine the feasibility of performing
a focused audit for Grants greater than or equal to $50,000.
6. Follow-up with Navajo Nation management to obtain missing
documentation to support expenditures and that Navajo Nation has made
necessary reporting corrections; and determine the feasibility of performing
a focused audit for Aggregate Payments to individuals with a specific focus
on Navajo Nation's non-payroll COVID-19 hardship claims and payroll
expenditures for employees substantially dedicated to COVID-19 recovery
efforts. ($80,844,219 Questioned Costs)
7. Confirm that Navajo Nation management has reversed $(Amount Redacted)
in duplicate hardship check payments that were fraudulently cashed by
tribal citizens and recorded by management within the Aggregate Payments
to Individuals payment type in the Cycle 3 GrantSolutions submission.
8. Ensure Navajo Nation management re-issued stale-dated checks before the
end of December 31, 2022, and ensure that checks were cashed by the
beneficiaries, or funds are returned to Treasury.
9. Ensure Navajo Nation management has reversed the sub-recipient incurred
costs that they determined to be ineligible as a result of their internal
investigation. Management agreed with the recommendations.
Treasury Office of Inspector General Semiannual Report—March 2024 38
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-042 Desk Review of the Commonwealth of 08/23
Virginia’s Use of Coronavirus Relief
Fund Proceeds
1. Treasury OIG should follow-up with the Commonwealth of Virginia (Virginia)
management on necessary reporting corrections. Specifically, Items Not
Listed Above description corrections are needed in the Contracts greater
than or equal to $50,000, Grants greater than or equal to $50,000,
Transfers greater than or equal to $50,000, and Direct Payments greater
than or equal to $50,000 payment types. In addition, Treasury OIG should
pursue obtaining documentation from Virginia management for Contracts
greater than or equal to $50,000, Transfers greater than or equal to
$50,000, Direct Payments greater than or equal to $50,000, Aggregate
Reporting less than $50,000, and Aggregate Payments to Individuals.
Based on Virginia’s responsiveness to Treasury OIG’s requests and its
ability to provide documentation, Treasury OIG should determine if a
focused audit is feasible for Contracts, Transfers, and Direct Payments
greater than or equal to $50,000, as well as Aggregate Reporting less than
$50,000 and Aggregate Payments to Individuals. In addition, Treasury OIG
should work with Virginia management to determine whether there are any
additional costs attributable to Virginia Department of Emergency
Management and Virginia Department of Health and to ensure that Virginia
management makes any necessary corrections to those balances. Also,
Treasury OIG should follow-up to obtain the status of the 2021 Single Audit
Annual Comprehensive Financial Report finding. Management agreed with
the recommendation. ($870,559,763 Questioned Costs)
Treasury Office of Inspector General Semiannual Report—March 2024 39
Statistical Summary
Other Federal Agencies
Fiscal Report Number Report Title Date Issued
Year
2022 OIG-22-033 REVENUE COLLECTION: The U.S. 03/22
Customs and Border Protection’s
Oversight of the Merchandise
Transported In-Bond Program Needs
Improvement to Better Ensure the
Protection of Revenue
1. Ensure Cargo Security and Controls Division (CSC) officials develop and
disseminate performance measures specific to the In-Bond Program so that
CSC, field offices, and port personnel are aware of program expectations.
These measures should be used to regularly assess port performance and
hold ports accountable.
2. Ensure CSC officials develop written procedures for CSC’s oversight of port
performance relating to the In-Bond Program to include, but not be limited
to, regular data analytics and review of Automated Commercial Environment
(ACE) reports.
3. Ensure CSC officials work with Trade Transformation Office (TTO) officials
to implement a central repository to store ACE reports, compliance
examination documentation, and other in-bond related information, including
training materials, maintained by the ports so that CSC can oversee in-bond
activity. Additionally, CSC should regularly notify field offices and ports that
these documents are available in this repository.
4. Ensure CSC officials expand the Self-Inspection Program in-bond Self-
Inspection Worksheet questions to cover key program areas, such as the
ports’ use of ACE reporting to oversee overdue in-bond shipments and
training for CBP officers on in-bond compliance examinations and audits.
5. Ensure CSC officials provide guidance to the ports on how to respond to in-
bond Self-Inspection Worksheet questions to include scenarios and the
appropriate response given those scenarios.
6. Ensure CSC officials issue policies and procedures for ports on ACE reports
they are expected to run regularly to oversee in-bond shipments and ensure
in-bonds are closed out. This should include guidance necessary to monitor
shipments in ACE as well as review proof of exports.
7. Ensure CSC officials issue policies and procedures for CSC to regularly
review the monitoring and tracking of in-bond shipments conducted by the
ports.
8. Ensure CSC officials update in-bond regulations to require a standardized
proof of export to be uploaded to ACE for all cargo exported.
Treasury Office of Inspector General Semiannual Report—March 2024 40
Statistical Summary
9. Ensure CSC officials provide TTO official’s business requirements after
regulations are updated so that TTO can update ACE to require proof of
export for closure of in-bonds that are exported.
10. Ensure Office of Trade officials, with input from CSC officials, update
regulations to support ACE functionality and data quality to modernize the
in-bond process. This includes improving the report processing time,
improving the quality of reports, and addressing Commercial Customs
Operations Advisory Committee concerns regarding the system.
11. Ensure CSC officials provide TTO officials with business requirements after
regulations are updated so that TTO can implement changes in ACE to
modernize in-bond tracking and automation processes and enhance data
quality to meet user needs.
12. Direct CSC officials to consider updating guidance on compliance
examinations to require ports to examine a statistically valid sample of in-
bond shipments so that cargo reviewed is more representative of all in-bond
shipments. Additionally, the guidance should contain instructions on waivers
of examination including documenting the justification for these waivers.
13. Ensure CSC officials provide the ports with written policies and procedures
to ensure compliance examinations are adequate and consistent. These
procedures should include selecting cargo for review, conducting
examinations, documenting the process used for the review and the results,
and storing the records.
14. Ensure CSC and TTO officials require ACE training related to the oversight of
in-bond cargo for all CBP officers.
15. Ensure the Commercial Operations Revenue & Entry Division coordinates
with the Revenue Division and CSC officials to improve custodial bonding to
address the risks of merchandise transported in-bond and update CBP’s
bonding policy. The policy should improve the connectivity between in-bond
shipments and respective duties, taxes, and fees by considering estimated
duties when determining the appropriate bond coverage.
16. Ensure the Commercial Operations Revenue & Entry Division provides
general bond training to include setting the appropriate bond amounts.
Management agreed with the recommendations.
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-23-025 FINANCIAL MANAGEMENT: Audit of 05/23
the Gulf Coast Ecosystem Restoration
Council's Compliance with PIIA of
2019 for Fiscal Year 2022
1. The Gulf Coast Ecosystem Restoration Council should consult OMB’s
Payment Integrity Annual Data Call Instructions or its subsequent revisions
to determine how to report its payment integrity information.
Treasury Office of Inspector General Semiannual Report—March 2024 41
Statistical Summary
2. Review payment integrity information submitted to the OMB Annual Data
Call for accuracy prior to live publication to ensure accuracy of data
reported. Management agreed with the recommendations.
Closed Investigations of Senior Government Employees Not
Publicly Disclosed
October 1, 2023, through March 31, 2024
Treasury OIG did not close any investigations involving senior Government employees
during the period that were not publicly disclosed.
Trafficking Victims Prevention and Protection Reauthorization
Act of 2022
October 1, 2023, through March 31, 2024
Number of Suspected Violation Reported: 0
Number of Investigations: 0
Status and Outcome of Investigations: N/A
Recommended Actions to Improve: None
Summary of Instances of Whistleblower Retaliation
October 1, 2023, through March 31, 2024
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 2024 42
Statistical Summary
Summary of Attempts to Interfere With Treasury OIG
Independence, Including Instances Where Information or
Assistance Request was Refused
October 1, 2023, through March 31, 2024
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 2024 43
Statistical Summary
Listing of Audit Products Issued
October 1, 2023, through March 31, 2024
Office of Audit
Report Title Report Number
October 2023
Management and Performance Challenges OIG-CA-24-001
Facing the Department of the Treasury FY
2024
Letter to the Honorable Michael Regan, OIG-CA-24-002
Administrator, Environmental Protection
Agency and Chairperson, Gulf Coast
Ecosystem Restoration Council: 2024
Management and Performance Challenges
City of Springfield, Massachusetts – Use of OIG-CA-24-003
Coronavirus Relief Fund Proceeds
FINANCIAL MANAGEMENT: Audit of the OIG-24-001
United States Mint’s Schedules of Custodial
Deep Storage Gold and Silver Reserves as of
September 30, 2023 and 2022
FINANCIAL MANAGEMENT: Report on the OIG-24-002
Bureau of the Fiscal Service’s Description of its
Investment and Redemption Shared Services
System and the Suitability of the Design and
Operating Effectiveness of its Controls for the
Period August 1, 2022 to July 31, 2023
FINANCIAL MANAGEMENT: Report on the OIG-24-003
Bureau of the Fiscal Service's Description of its
Trust Funds Management Shared Services
System and the Suitability of the Design and
Operating Effectiveness of its Controls for the
Period August 1, 2022 to July 31, 2023
FINANCIAL MANAGEMENT: Audit of the OIG-24-004
Department of the Treasury's Schedules of
United States Gold Reserves Held by Federal
Treasury Office of Inspector General Semiannual Report—March 2024 44
Statistical Summary
Reserve Banks as of September 30, 2023 and
2022
November 2023
FINANCIAL MANAGEMENT: Audit of the OIG-24-005
Federal Financing Bank’s Financial Statements
for Fiscal Years 2023 and 2022
FINANCIAL MANAGEMENT: Audit of the Gulf OIG-24-006
Coast Ecosystem Restoration Council’s
Financial Statements for Fiscal Years 2023 and
2022
FINANCIAL MANAGEMENT: Department of the OIG-24-007
Treasury’s Consolidated Financial Statements
for Fiscal Years 2023 and 2022
Overseas Contingency Operations - Summary OIG-CA-24-005
of Work Performed by the Department of the
Treasury Related to Terrorist Financing and
Anti-Money Laundering for the Fourth Quarter
Fiscal Year 2023
December 2023
FINANCIAL MANAGEMENT: Management OIG-24-008
Letter for the Audit of the Department of the
Treasury’s Consolidated Financial Statements
for Fiscal Years 2023 and 2022
FINANCIAL MANAGEMENT: Management OIG-24-009
Letter for the Deficiencies in Internal Control
over Cash Management Systems at the Bureau
of the Fiscal Service Identified during the Audit
of the Department of the Treasury’s
Consolidated Financial Statements for Fiscal
Years 2023 and 2022
FINANCIAL MANAGEMENT: Audit of the OIG-24-010
Office of D.C. Pensions Financial Statements
for Fiscal Years 2023 and 2022
FINANCIAL MANAGEMENT: Audit of the OIG-24-011
United States Mint’s Financial Statements for
Fiscal Years 2023 and 2022
Treasury Office of Inspector General Semiannual Report—March 2024 45
Statistical Summary
FINANCIAL MANAGEMENT: Management OIG-24-012
Letter for the Audit of the United States Mint’s
Financial Statements for Fiscal Years 2023 and
2022
FINANCIAL MANAGEMENT: Audit of the OIG-24-013
Office of the Comptroller of the Currency's
Financial Statements for the Fiscal Years 2023
and 2022
FINANCIAL MANAGEMENT: Management OIG-24-014
Letter for the Audit of the Office of the
Comptroller of the Currency's Financial
Statements for Fiscal Years 2023 and 2022
FINANCIAL MANAGEMENT: Audit of the OIG-24-015
Department of the Treasury Forfeiture Fund’s
Financial Statements for Fiscal Years 2023 and
2022
FINANCIAL MANAGEMENT: Audit of the OIG-24-016
Exchange Stabilization Fund’s Financial
Statements for Fiscal Years 2023 and 2022
FINANCIAL MANAGEMENT: Management OIG-24-017
Letter for the Audit of the Exchange
Stabilization Fund's Financial Statements for
Fiscal Years 2023 and 2022
FINANCIAL MANAGEMENT: Audit of the OIG-24-018
Bureau of Engraving and Printing’s Financial
Statements for Fiscal Years 2023 and 2022
FINANCIAL MANAGEMENT: Management OIG-24-019
Letter for the Audit of the Bureau of Engraving
and Printing’s Financial Statements for Fiscal
Years 2023 and 2022
Annual Plan, Fiscal Year 2024, Office of OIG-CA-24-006
Inspector General, Department of the Treasury
Treasury Office of Inspector General Semiannual Report—March 2024 46
Statistical Summary
January 2024
Grantee Emergency Rental Assistance (ERA) OIG-CA-24-007
Bulk Fraud Reports Processing and Resolution
Standard Operating Procedures, Not Publicly
Disclosed
FINANCIAL MANAGEMENT: Audit of the OIG-24-020
Alcohol and Tobacco Tax and Trade Bureau’s
Financial Statements for Fiscal Years 2023 and
2022
FINANCIAL MANAGEMENT: Management OIG-24-021
Letter for the Audit of the Alcohol and
Tobacco Tax and Trade Bureau’s Financial
Statements for Fiscal Years 2023 and 2022
CYBERSECURITY/INFORMATION OIG-24-022
TECHNOLOGY: Department of the Treasury
Federal Information Security Modernization Act
Fiscal Year 2023 Performance Audit for the
Unclassified Systems (Sensitive But
Unclassified) Not Publicly Disclosed
CYBERSECURITY/INFORMATION OIG-24-023
TECHNOLOGY: Department of the Treasury
Federal Information Security Modernization Act
Fiscal Year 2023 Performance Audit for the
Collateral National Security Systems (Sensitive
But Unclassified) Not Publicly Disclosed
FINANCIAL REGULATION AND OVERSIGHT: OIG-CA-24-008
Treasury OIG Purchase Cards Annual Report
Transmittal to OMB
Memorandum for the Honorable Richard K. OIG-CA-24-009
Delmar, Treasury Deputy Inspector General:
Joint Purchase and Integrated Card Violation
Report (April 1, 2023–September 30, 2023)
Internal Memorandum, Not Publicly Disclosed
FINANCIAL MANAGEMENT: Audit of the OIG-24-024
Community Development Financial Institutions
Fund’s Financial Statements for Fiscal Year
2023
Treasury Office of Inspector General Semiannual Report—March 2024 47
Statistical Summary
Risk Assessment of the Gulf Coast Ecosystem OIG-CA-24-010
Restoration Council’s Charge Card and
Convenience Check Program
2023 Annual Report (Gulf Coast) on Charge OIG-CA-24-011
Card Status of Recommendations Transmittal
to OMB
February 2024
Overseas Contingency Operations - Summary OIG-CA-24-012
of Work Performed by the Department of the
Treasury Related to Terrorist Financing and
Anti-Money Laundering for the First Quarter
Fiscal Year 2024
March 2024
ANTI-MONEY LAUNDERING/TERRORIST OIG-24-025
FINANCING: TFI’s Ukraine-/Russia-related
Sanctions Program Complied With
Requirements But Designation Decision
Records Were Not Consistently Complete and
Closed Timely
Coronavirus Relief Fund Recoupment Standard OIG-CA-24-014
Operating Procedures, Not Publicly Disclosed
Memorandum – Inquiry on Revolving Door OIG-CA-24-015
Between the Largest Accounting Firms and the
Department of the Treasury
CBP Needs to Enhance its Monitoring and OIG-24-026
Tracking of the Outcomes of Investigations
into the Underpayment of Duties
Treasury Office of Inspector General Semiannual Report—March 2024 48
Statistical Summary
Audit Reports Issued With Questioned Costs
October 1, 2023, through March 31, 2024
Total Total
Total No. Questioned Unsupported
Category of Reports Costs Costs
For which no management decision had been made by
beginning of reporting period 23 $2,239,150,475 $2,239,150,475
Which were issued during the reporting period 1 $300,000 $300,000
Subtotals 24 $2,239,450,475 $2,239,450,475
For which a management decision was made during the
reporting period 1 $1,500,000 $1,500,000
Dollar value of disallowed costs 1 $1,500,000 $1,500,000
Dollar value of costs not disallowed 0 $0 $0
For which no management decision was made by the
end of the reporting period 23 $2,237,950,475 $2,237,950,475
For which no management decision was made within 6
months of issuance 22 $2,237,650,475 $2,237,650,475
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 2024 49
Statistical Summary
Audit Reports Issued With Recommendations that Funds Be Put
to Better Use
October 1, 2023, through March 31, 2024
Total
No. of Revenue
Category Reports Total Savings Enhancement
For which no management decision had been
made by beginning of reporting period 1 $42,563 $0 $0
Which were issued during the reporting
period 0 $0 $0 $0
Subtotals 1 $42,563 $0 $0
For which a management decision was made
during the reporting period 1 $42,563 $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 1 $42,563 $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 2024 50
Statistical Summary
Reports for Which No Management Comment was Returned
Within 60 Days
As of March 31, 2024
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, 2024
As of the end of this semiannual reporting period, Treasury management had not
decided on recommendations with monetary benefits for 22 reports issued over 6
months:
CORONAVIRUS DISEASE 2019 PANDEMIC RELIEF PROGRAMS: Audit of Air
Carrier Worker Support Certifications - Wings Air Helicopters, LLC (Redacted)
(OIG-23-023, 03/31/2023) Questioned costs are sensitive information.
CORONAVIRUS DISEASE 2019 PANDEMIC RELIEF PROGRAMS: Audit of Air Carrier
Worker Support Certifications - Constant Aviation, LLC (Redacted) (OIG-23-024,
4/21/2023) $52,003 Questioned Costs
CORONAVIRUS DISEASE 2019 PANDEMIC RELIEF PROGRAMS: Audit of Air Carrier
Worker Support Certifications - Paradigm Jet Management, Inc. (Redacted)
(OIG-23-027, 6/6/2023) $71,023 Questioned Costs
CORONAVIRUS DISEASE 2019 PANDEMIC RELIEF PROGRAMS: Audit of Air Carrier
Worker Support Certifications – Bird Acquisition, LLC (Redacted) (OIG-23-029,
6/13/2023) $115,626 Questioned Costs
Desk Review of Chippewa Cree Tribe’s Use of Coronavirus Relief Fund Proceeds
(OIG-CA-23-018, 6/26/2023) $75,091 Questioned Costs
Treasury Office of Inspector General Semiannual Report—March 2024 51
Statistical Summary
Desk Review of Lancaster County, Pennsylvania’s Use of Coronavirus Relief Fund
Proceeds (OIG-CA-23-024, 6/29/2023) $38,793,071 Questioned Costs
Desk Review of State of California’s Use of Coronavirus Relief Fund Proceeds
(OIG-CA-23-025, 7/7/2023) $6,952 Questioned Costs
Desk Review of Turtle Mountain Band of Chippewa Indians’ Use of Coronavirus Relief
Fund Proceeds (Redacted) (OIG-CA-23-026, 7/7/2023) $32,333,620 Questioned
Costs
Desk Review of Los Angeles County, California’s Use of Coronavirus Relief Fund
Proceeds (OIG-CA-23-027, 7/7/2023) $249,052,032 Questioned Costs
Desk Review of City of Dallas, Texas’s Use of Coronavirus Relief Fund Proceeds
(OIG-CA-23-028, 7/20/2023) $2,211,594 Questioned Costs
Desk Review of State of Florida’s Use of Coronavirus Relief Fund Proceeds
(OIG-CA-23-029, 7/20/2023) $893,154,358 Questioned Costs
Desk Review of San Bernardino County, California’s Use of Coronavirus Relief Fund
Proceeds (OIG-CA-23-030, 7/20/2023) $4,151,612 Questioned Costs
Desk Review of Phoenix, Arizona’s Use of Coronavirus Relief Fund Proceeds
(OIG-CA-23-032, 7/21/2023) $147,379 Questioned Costs
Desk Review of Pleasant Point Indian Reservation, Maine’s Use of Coronavirus Relief
Fund Proceeds (OIG-CA-23-033, 7/21/2023) $339,672 Questioned Costs
Desk Review of State of Texas’ Use of Coronavirus Relief Fund Proceeds
(OIG-CA-23-034, 7/21/2023) $17,288,575 Questioned Costs
Desk Review of the State of Tennessee’s Use of Coronavirus Relief Fund Proceeds
(OIG-CA-23-035, 7/26/2023) $1,162,364 Questioned Costs
Desk Review of State of Ohio’s Use of Coronavirus Relief Fund Proceeds
(OIG-CA-23-037, 7/27/2023) $86,801 Questioned Costs
Desk Review of Native Village of Point Hope’s Use of Coronavirus Relief Fund
Proceeds (OIG-CA-23-038, 7/28/2023) $2,348,064 Questioned Costs
Treasury Office of Inspector General Semiannual Report—March 2024 52
Statistical Summary
Desk Review of the Commonwealth of the Northern Mariana Islands Use of
Coronavirus Relief Fund Proceeds (OIG-CA-23-039, 8/8/2023) $11,146,813
Questioned Costs
Desk Review of the Commonwealth of Puerto Rico’s Use of Coronavirus Relief Fund
Proceeds (OIG-CA-23-040, 8/8/2023) $33,681,692 Questioned Costs
Desk Review of Navajo Nation Tribal Government’s Use of Coronavirus Relief Fund
Proceeds (Redacted) (OIG-CA-23-041, 8/8/2023) $80,844,218 Questioned Costs
Desk Review of the Commonwealth of Virginia’s Use of Coronavirus Relief Fund
Proceeds (OIG-CA-23-042, 8/9/2023) $870,559,763 Questioned Costs
Significant Revised Management Decisions
As of March 31, 2024
There were no significant revised management decisions during the reporting period.
Significant Disagreed Management Decisions
As of March 31, 2024
There were no significant disagreed management decisions during the reporting period.
Treasury Office of Inspector General Semiannual Report—March 2024 53
Statistical Summary
Peer Reviews
October 1, 2023, through March 31, 2024
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 U.S. Department of
Health and Human Services (HHS) OIG. In its report dated September 27, 2021, HHS
OIG rendered a Pass rating for our system of quality control in effect for the year
ended March 31, 2021. External audit peer review reports of our office are available
on Treasury OIG’s website. Treasury OIG did not perform any peer reviews of other
Federal audit organizations during this reporting period.
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 January 5, 2021, the Federal Housing Finance Agency OIG found
our office to be in compliance with all relevant guidelines for fiscal year 2020. During
this reporting period, our office did not perform a peer review of another OIG.
Treasury Office of Inspector General Semiannual Report—March 2024 54
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 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 Federal Deposit Insurance Corporation 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.
There were no banks supervised by OCC that failed during this reporting period.
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
Department of the Treasury’s (Treasury) activities with respect to disrupting the
Islamic State of Iraq and Syria’s finances. The memorandums included specific
examples of activities to disrupt Islamic State of Iraq and Syria’s financing,
information on Treasury programs that combat terrorist financing, and work we
Treasury Office of Inspector General Semiannual Report—March 2024 55
Other Reporting Requirements and Requests
performed or plan to perform to review these programs. (OIG-CA-24-005,
OIG-CA-24-012)
Annual Reports on the Status of Implementation of Purchase and
Travel Card Audit Recommendations
We provided annual reports on the progress made by Treasury and by the
Council in implementing charge card related audit recommendations in
accordance with the Charge Card Act and OMB Memorandum M-13-21,
“Implementation of the Government Charge Card Abuse Prevention Act of
2012” (M-13-21). Our office has not issued any charge card related audit
findings and recommendations to Treasury or the Council and did not have
anything to report for fiscal year 2023. (OIG-CA-24-008, OIG-CA-24-011)
Risk Assessment of the Gulf Coast Ecosystem Restoration Council’s
Charge Card and Convenience Check Program
We conducted a risk assessment of the Gulf Coast Ecosystem Restoration
Council’s (Council) charge card (collectively, purchase cards, travel cards, and
centrally billed accounts) and convenience check program. The objective of our
assessment was to identify and analyze the risk of illegal, improper, or
erroneous purchases and payments in order to determine the scope, frequency,
and number of periodic audits of charge card and/or convenience check
transactions. We reported the overall risk of illegal, improper, or erroneous
purchases and payments in the Council’s charge card program as moderate, and
the Council’s convenience check program as very low. There are no audits of
the Council’s charge card and convenience check program planned at this time;
however, we informed the Council’s management of risk areas identified during
our assessment. (OIG-CA-24-010)
Treasury Office of Inspector General Semiannual Report—March 2024 56
References to the Inspector General Act
Section Requirement Page
Section Review of legislation and regulations 21
404(a)(2)
Section Significant problems, abuses, and deficiencies 5-19
405(b)(1)
Section Recommendations with respect to significant problems, abuses, and deficiencies 5-19
405(b)(2)
Section Significant unimplemented recommendations described in previous semiannual 22-42
405(b)(3) reports
Section Matters referred to prosecutive authorities 21
405(b)(4)
Section Summary of instances where information was refused 43
406(c)(2)
Section List of audit reports 46-48
405(b)(6)
Section Summary of significant reports 7-19
405(b)(7)
Section Audit reports with questioned costs 49
405(b)(8)
Section Recommendations that funds be put to better use 50
405(b)(9)
Section Summary of each audit, inspection, and evaluation report issued before the 51-53
405(b)(8)(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 51
405(b)(10)(B) management comment was returned within 60 days
Section Summary of each audit, inspection, and evaluation report issued before the 22-42
405(b)(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 53
405(b)(11)
Section Management decisions with which the Inspector General is in disagreement 53
405(b)(12)
Section Instances of unresolved Federal Financial Management Improvement Act 7-8
405(b)(13) noncompliance
Section Results of peer reviews conducted of Treasury OIG by another OIG 54
405(b)(14)
Section List of outstanding recommendations from peer reviews 54
405(b)(15)
Section List of peer reviews conducted by Treasury OIG, including a list of outstanding 54
405(b)(16) recommendations from those peer reviews
Section Statistics for the period related to the number of (A) investigative reports issued, 21
405(b)(17)(A- (B) persons referred to the Department of Justice for criminal prosecution,
D) (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) 21
405(b)(18)
Section Summary of each investigation involving a senior Government employee where 42
405(b)(19) allegation of misconduct was substantiated
Section Instances of whistleblower retaliation 42
405(b)(20)
Treasury Office of Inspector General Semiannual Report—March 2024 57
References to the Inspector General Act
Section Summary of attempts to interfere with Treasury OIG independence 43
405(b)(21)
Section Description of each inspection, evaluation, and audit that was closed and not 44-49
405(b)(22)(A) publicly disclosed
Section Description of each investigation closed, involving a senior Government 42
405(b)(22)(B) employee, that was not publicly disclosed
Section 405(e) Serious or flagrant problems, abuses, or deficiencies N/A
Section Report to Secretary when information or assistance is unreasonably refused 43
406(c)(2)
Treasury Office of Inspector General Semiannual Report—March 2024 58
Abbreviations
ACE Automated Commercial Environment
ARP American Rescue Plan Act of 2021
BEP Bureau of Engraving and Printing
Board Board of Governors of the Federal Reserve System
CARES Act Coronavirus Aid, Relief, and Economic Security Act
CBP Customs and Border Protection
CDFI Community Development Financial Institutions
CEAR Commercial Enforcement Analysis and Response
CIGIE Council of the Inspectors General on Integrity and Efficiency
Council Gulf Coast Ecosystem Restoration Council
COVID-19 Coronavirus Disease 2019
CRF Coronavirus Relief Fund
CSC Cargo Security and Controls Division
DATA Act Digital Accountability and Transparency Act
DIF Deposit Insurance Fund
DOJ Department of Justice
EAPA Enforce and Protect Act
ERA Emergency Rental Assistance
FinCen Financial Crimes Enforcement Network
Fiscal Service Bureau of the Fiscal Service
FISMA Federal Information Security Modernization Act of 2014
FY fiscal year
GAO Government Accountability Office
GLER General Law, Ethics and Regulation’s
HHS U.S. Department of Health and Human Services
ICE HSI Immigration and Customs Enforcement Homeland Security
Investigations
IRS Internal Revenue Service
KPMG KPMG LLP
Mint United States Mint
NOAA National Oceanic and Atmospheric Administration’s
OASIS Office of Foreign Assets Control Administrative System for
Investigations and Sanctions
OCC Office of the Comptroller of the Currency
OFAC Office of Foreign Assets Control
OIA Office of Intelligence and Analysis
OIG Office of Inspector General
OMB Office of Management and Budget
OT Office of Trade
Treasury Office of Inspector General Semiannual Report—March 2024 59
Abbreviations
PII Personally Identifiable Information
PSP1 Air Carrier Payroll Support Program
PSP2 Payroll Support Program Extension
PSP3 Payroll Support Program 3
RESTORE Act Resources and Ecosystems Sustainability, Tourist
Opportunities, and Revived Economies of the Gulf Coast
States Act of 2012
RMA RMA Associates
SBLF Small Business Lending Fund
SOP standard operating procedures
TCVS Treasury Check Verification System
TIGTA Treasury Inspector General for Tax Administration
TMBCI Turtle Mountain Band of Chippewa Indians’
TRLED Trade Remedy Law Enforcement Directorate
Treasury Department of the Treasury
TTO Trade Transformation Office
USAO U.S. Attorney’s Office
Virginia Commonwealth of Virginia
Treasury Office of Inspector General Semiannual Report—March 2024 60
Treasury Office of Inspector General Locations
1500 Pennsylvania Avenue, N.W., Room 4436
Washington, DC 20230
875 15th Street, N.W., Suite 200
Washington, DC 20005
Report Waste, Fraud, and Abuse
Submit a complaint regarding Treasury OIG Treasury Programs and Operations and Gulf Coast Restoration using our
online form: https://oig.treasury.gov/report-fraud-waste-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 Website
Access Treasury OIG reports and other information online: https://oig.treasury.gov/
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