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Treasury Office of Inspector General Semiannual Report—September 2023 (Report to Congress)

Summary

The Treasury Office of Inspector General's Semiannual Report for September 2023 states that the Office of Audit issued 47 products and identified $2.2 billion in questioned costs, and investigations resulted in 17 indictments and 19 convictions. Saggar & Rosenberg, P.C. found air carriers incorrectly reported information on their Air Carrier Payroll Support Program applications, totaling $238,652 in questioned costs. Castro & Company, LLC found over $2.2 billion in total questioned costs in Coronavirus Relief Fund use by state, local and tribal governments. One investigation found an individual received $1.8 million in Paycheck Protection Program loans through wire fraud; the sentence was 37 months in prison and $1.795 million in restitution.

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“Treasury Office of Inspector General Semiannual Report—September 2023 (Report to Congress).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/semiannual-report-to-congress-sep-2023-bcbb62801f/, SHA-256 899a6184c67dbb7884706bb0de764d8404b38db0432639e2e2bb13e7b2b70a46.

Full text

Office of Inspector General for Department of the Treasury
Highlights
During this semiannual reporting period, the Office of Audit issued 47 products. The
office also identified $2.2 billion in questioned costs. Work by the Office of
Investigations resulted in 17 indictments and 19 convictions. Some of our more
significant results for the period are described below:

 • Saggar & Rosenberg, P.C. (S&R), a certified independent public accounting firm,
    working under a contract with and supervised by our office, assessed the
    accuracy, completeness, and sufficiency of financial statements and other data
    used to certify the wages, salaries, benefits, and other compensation amounts
    submitted and approved for the Air Carrier Payroll Support Program (PSP1). For
    the following air carriers:
              o Bird Acquisition, LLC
              o Paradigm Jet Management, Inc.
              o Constant Aviation, LLC
              o Ground Services International, Inc.
     S&R determined that the air carriers incorrectly reported information on their
     PSP1 Application to the Department of the Treasury. S&R found Bird Acquisition,
     LLC, had $115,626 in questioned costs, Paradigm Jet Management, Inc. had
     $71,023 in questioned costs, and Constant Aviation, LLC had $52,003 in
     questioned costs resulting in a total of $238,652 in questioned costs.

 • Castro & Company, LLC (Castro), a certified independent public accounting firm,
    working under a contract with and supervised by our office, assessed the use of
    Coronavirus Relief Funds (CRF) proceeds for the following recipients. In addition
    to determining whether CRF recipients’ risk of unallowable use of funds was low,
    moderate, or high, Castro also determined there were over $2.2 billion in total
    questioned costs for the following States, Local Governments, and Tribal
    Governments reviewed.
                o Commonwealth of Virginia
                o State of Florida
                o Los Angeles, California
                o Navajo Nation Tribal Government
                o Lancaster County
                o Commonwealth of Puerto Rico
                o Turtle Mountain Band of Chippewa
                o State of Texas
                o Commonwealth of the Northern Mariana Islands

      Treasury Office of Inspector General Semiannual Report—September 2023   ii
                                                                            Highlights

               o   San Bernardino, California
               o   Native Village of Point Hope
               o   City of Dallas, Texas
               o   State of Tennessee
               o   Pleasant Point Indiana Reservation
               o   Phoenix, Arizona
               o   State of Ohio
               o   Chippewa Cree Tribe
               o   State of California
               o   State of Illinois
               o   The Cherokee Nation, Oklahoma
               o   New York City

•   An investigation conducted by our Office of Investigations revealed that an
    individual committed wire fraud by applying for and receiving $1.8 million in
    Paycheck Protection Program Loans. The subject was sentenced in the Eastern
    District of Virginia to 37 months in prison, and $1.795 million in restitution.




    Treasury Office of Inspector General Semiannual Report—September 2023    iii
Message from the Deputy 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 15 audits, 21 desk reviews,
and 11 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.

Treasury OIG continues to provide leadership and administrative support to the Council
of Inspectors General on Financial Oversight (CIGFO), 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 (FSOC), which is
chaired by the Secretary of the Treasury. During this reporting period, CIGFO
heightened its monitoring of FSOC’s responses to the financial sector disturbances
generated by failures in financial institutions. In addition, in recognition of the
important work performed, CIGFO received an award for excellence in auditing this
period from the Council of the Inspectors General on Integrity and Efficiency for work
related to developing guidance to serve as a reference tool for both FSOC and its
member agencies in preparing for and managing crises.

Also, during this reporting period, Treasury OIG, along with the Treasury Office of
Technical Assistance, hosted a delegation from the Vietnamese State Treasury’s
Inspection and Examination Department. Our team provided information and answered
questions to assist our Vietnamese visitors in developing their understanding of the
function of an OIG and the audit process including standards, structure, and reporting.
We shared expertise for conducting risk assessments and the use of data analytics
when analyzing large amounts of data. In addition, our Office of Investigations
discussed its role with the OIG and answered questions regarding its investigative
responsibilities.

The OIG significantly contributes to the integrity and efficiency of Treasury’s programs
and operations, thanks to the impressive expertise and professionalism of all our
employees. I salute their dedication and accomplishments.




Richard K. Delmar
Deputy Inspector General

      Treasury Office of Inspector General Semiannual Report—September 2023   iv
Contents
Highlights ......................................................................................... ii
Message from the Deputy Inspector General ........................................ iv
Treasury Office of Inspector General Overview .................................... 1
Management and Performance Challenges ........................................... 4
Office of Audit – Significant Audits and Other Products ........................ 5
     CARES Act Oversight ............................................................................................. 5
     CARES Act Compliance Monitoring .......................................................................... 9
     Cyber/Information Technology ............................................................................... 19
     Anti-Money Laundering/Terrorist Financing and Intelligence ....................................... 20
     Financial Management .......................................................................................... 21
     Consolidated Appropriations Act, 2021 ................................................................... 23
     Council of Inspectors General on Financial Oversight Audit of the Financial Stability
     Oversight Council ................................................................................................. 25

Office of Investigations – Significant Investigations and Other Products 27
     CARES Act Investigations ..................................................................................... 27
     Other Significant Investigations .............................................................................. 27

Treasury OIG Accomplishments and Activities ................................... 31
Statistical Summary ........................................................................ 32
     Summary of Treasury OIG Activities ....................................................................... 32
     Metrics Used for Office of Investigations Activities ................................................... 32
     Reports with Unimplemented Recommendations ...................................................... 33
     Closed Investigations of Senior Government Employees Not Publicly Disclosed ............ 55
     Trafficking Victims Prevention and Protection Reauthorization Act of 2022 ................. 55
     Summary of Instances of Whistleblower Retaliation .................................................. 55
     Summary of Attempts to Interfere With Treasury OIG Independence, Including Instances
     Where Information or Assistance Request was Refused............................................. 56
     Listing of Audit Products Issued ............................................................................. 57
     Audit Reports Issued With Questioned Costs ........................................................... 62
     Audit Reports Issued With Recommendations that Funds Be Put to Better Use ............. 63
     Reports for Which No Management Comment Was Returned Within 60 Days .............. 64

        Treasury Office of Inspector General Semiannual Report—September 2023                                v
                                                                                                            Contents

    Reports Issued Over 6 Months for Which No Management Decision Has Been Made ..... 64
    Significant Revised Management Decisions .............................................................. 64
    Significant Disagreed Management Decisions ........................................................... 65
    Peer Reviews ....................................................................................................... 65

Other Reporting Requirements and Requests ...................................... 67
References to the Inspector General Act............................................ 69
Abbreviations ................................................................................. 71




       Treasury Office of Inspector General Semiannual Report—September 2023                                 vi
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 Inspector General appointed by the President with the
advice and consent of the Senate.

Treasury OIG performs independent, objective reviews of Treasury programs and
operations, except for those of the Internal Revenue Service, the Troubled Asset Relief
Program, 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. A Special Inspector General and GAO perform
oversight related to the Troubled Asset Relief Program. 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 (RESTORE Science 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,

1
    5 U.S.C. §§401-424

         Treasury Office of Inspector General Semiannual Report—September 2023   1
                                   Treasury Office of Inspector General Overview

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
deputy is primarily responsible for financial sector audits to include audits of banking
supervision, manufacturing of currency and coins, resource management,
procurement, 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 and the
Community Development Financial Institutions Rapid Response 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 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




      Treasury Office of Inspector General Semiannual Report—September 2023    2
                                         Treasury Office of Inspector General Overview

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 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 2023 appropriation is $48.8 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 $24.9 million for the
Coronavirus Relief Fund, $2.8 million for ERA-Oversight, $2.8 million for ERA-
Monitoring, and $1.72 million for the Homeowner Assistance Fund. As of September
30, 2023, Treasury OIG had 242 full-time staff.




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—September 2023                   3
Management and Performance Challenges
The Reports Consolidation Act of 2000 requires that the Department of the Treasury
(Treasury or the Department) Inspector General annually provide his perspective on the
most serious management and performance challenges facing Treasury and the Gulf
Coast Ecosystem Restoration Council (Council). The following is a synopsis of our
annual assessments which are available, in their entirety, on the Treasury Office of
Inspector General (OIG) website.

     Treasury
     In an October 10, 2023, memorandum to Secretary of the Treasury,
     Janet Yellen, Deputy Inspector General Richard Delmar 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,
      Deputy Inspector General Richard Delmar 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—September 2023   4
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 or the Department) 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 reporting period, Saggar & Rosenberg, P.C. (S&R), a certified
independent public accounting firm, working under a contract with and supervised by
our office, performed audits of air carrier worker support certifications. Also, during
this semiannual period, we issued audits on recipients’ use of CRF proceeds reported
via GrantSolutions.




      Treasury Office of Inspector General Semiannual Report—September 2023   5
                 Office of Audit – Significant Audits and Other Products

Audit of American Samoa’s Uses of Coronavirus Relief Fund
Payment

We found that the American Samoa Government’s (ASG) use of $1.5 million in
CRF proceeds for the purchase of the MV Pago Pago vessel and related barge
(collectively referred to as the MV Pago Pago) did not comply with the use of
funds requirements under subsection 601(d) of the Social Security Act, as
amended (42 U.S.C. 801(d)), as well as Treasury’s Coronavirus Relief Guidance
for State, Territorial, Local, and Tribal Governments (Guidance), and CRF
Frequently Asked Questions. ASG officials were unable to justify the use of CRF
proceeds as necessary in response to the Coronavirus Disease 2019 (COVID-19)
public health emergency. ASG officials were also unsure whether the former
ASG COVID-19 Task Force members considered cost effective alternatives such
as using and/or improving vessels already owned or leased prior to the MV Pago
Pago purchase.

We recommended that the Chief of the Treasury Office of Recovery Programs
work with the OIG to ensure that the ASG Treasurer returns to Treasury the
$1.5 million of CRF proceeds that were used to purchase the MV Pago Pago.
ASG agreed to pay back the $1.5 million of CRF proceeds that were used to
purchase the MV Pago Pago. Treasury concurred with our finding and
coordinated a repayment plan with ASG. Treasury and ASG’s responses and the
coordinated repayment plan met the intent of our recommendation.
(OIG-23-031) $1,500,000 Questioned Costs)

Audit of Air Carrier Worker Support Certifications – Bird Acquisition,
LLC

S&R determined that Bird Acquisition, LLC, a contractor reported correct
information for three of the four sections reviewed on its PSP1 application.
These sections were: (1) applicant information, (2) applicant type, and (3)
certification. S&R also determined that the contractor incorrectly reported
information in the awardable amounts section of the PSP1 application, which
resulted in a $128,473 overstatement. Specifically, S&R found (1) the inclusion
of unallowable corporate officer compensation resulted in an overstatement,
(2) inclusion of member-paid Consolidated Omnibus Budget Reconciliation Act
benefits resulted in an overstatement, (3) reporting incorrect data for benefits
resulted in an understatement, and (4) excluding eligible gross pay from the
awardable amount resulted in an understatement. Treasury’s awards to


Treasury Office of Inspector General Semiannual Report—September 2023   6
                 Office of Audit – Significant Audits and Other Products

contractors under PSP1 included a 90 percent pro rata distribution of application
amounts. Applying this formula, the contractor received a $115,626
overpayment from Treasury.

S&R recommended Treasury management (1) seek reimbursement of the
$115,626 overpayment of PSP1 financial assistance; and (2) review the
contractor’s requested amount for unallowable expenses under PSP2 and PSP3,
and seek reimbursement for the overpayment, if applicable. Management’s
planned corrective actions met the intent of the recommendations.
(OIG-23-029) $115,626 Questioned Costs

Audit of Air Carrier Worker Support Certifications – Paradigm Jet
Management, Inc.

S&R determined that the passenger air carrier, Paradigm Jet Management, Inc.,
reported correct information for three of the four sections reviewed on its PSP1
application, specifically: (1) Applicant Information, (2) Applicant Type, and (3)
Certification. However, S&R found that the awardable amount section included
unallowable compensation paid to one corporate officer, non-payroll
reimbursement expenses, and payments to three independent contractors.
Additionally, S&R noted a matter of concern that the passenger air carrier did
not report to the Internal Revenue Service (IRS), compensation paid to workers
outside of routine weekly payroll. This matter was referred to the Treasury
Inspector General for Tax Administration for review.

S&R recommended Treasury management (1) seek reimbursement of $71,023
for overpayment in PSP1, (2) review the passenger air carrier’s requested
amount for unallowable expenses under PSP2 and PSP3, and seek
reimbursement for the overpayment, if applicable. Management’s planned
corrective actions met the intent of the recommendations. (OIG-23-027)
$71,023 Questioned Costs

Audit of Air Carrier Worker Support Certifications – Constant
Aviation, LLC

S&R determined that Constant Aviation, LLC, a contractor, reported correct
information for three of the four sections reviewed on its PSP1 application.
These sections were: (1) application Information, (2) application Type, and (3)
certification. However, S&R also determined that the contractor incorrectly


Treasury Office of Inspector General Semiannual Report—September 2023   7
                            Office of Audit – Significant Audits and Other Products

        reported information in the awardable amounts section, which resulted in a
        $57,781 overstatement. Specifically, S&R found (1) the inclusion of corporate
        officer compensation resulted in an overstatement, (2) data errors resulted in an
        understatement, and (3) reporting conservative benefit cost estimates resulted
        in an understatement. Treasury’s awards to contractors under PSP1 included a
        90 percent pro rata distribution of application amounts. Applying this formula,
        the contractor received a $52,003 overpayment from Treasury.

        S&R recommended Treasury management (1) seek reimbursement of the
        $52,003 overpayment of PSP1 financial assistance; and (2) review the
        contractor’s requested amount for unallowable expenses under PSP2 and PSP3,
        and seek reimbursement for the overpayment, if applicable. Management’s
        planned corrective actions met the intent of the recommendations.
        (OIG-23-024) $52,003 Questioned Costs

        Audit of Air Carrier Worker Support Certifications – Ground Services
        International, Inc.

        S&R determined that Ground Services International, Inc. (GSI), a contractor,
        reported correct information for three of the four sections reviewed on its PSP1
        Application. These sections were: (1) applicant information, (2) applicant type,
        and (3) certification. S&R also determined that the contractor reported incorrect
        information in the awardable amounts section, attributable to both GSI and
        Inflight Catering portions of their merged PSP1 application. 3 Specifically, for
        GSI’s portion, S&R found (1) the inclusion of corporate officer compensation
        resulted in an overstatement, (2) differences between the PSP1 application
        amounts and the actual amounts paid to company employees resulted in an
        overstatement, (3) exclusion of eligible gross pay resulted in an understatement,
        and (4) subsequent self-reporting to Treasury for inclusion of corporate officer
        compensation resulted in an understatement. For Inflight Catering’s portion,
        S&R found (1) the inclusion of corporate officer compensation resulted in an
        overstatement, and (2) data discrepancies related to benefits resulted in an
        overstatement. Overall, the contractor did not receive an overpayment from
        Treasury for the PSP1 merged application.

        S&R recommended Treasury management (1) review the contractor’s requested
        amount for unallowable expenses under PSP2 and PSP3, and seek

3
    Although Inflight Catering prepared its portion of the PSP1 application separately from GSI, GSI
    assumed responsibility of the entire application by certifying on all affiliates behalf.

        Treasury Office of Inspector General Semiannual Report—September 2023                 8
                       Office of Audit – Significant Audits and Other Products

      reimbursement for the overpayment, if applicable. Management’s planned
      corrective actions met the intent of the recommendations. (OIG-23-028)


CARES Act Compliance Monitoring
The CARES Act assigned us responsibility for monitoring and oversight of the receipt,
disbursement, and use of Coronavirus Relief Fund (CRF) proceeds. To carry out our
monitoring responsibilities, we developed a portal via GrantSolutions, a grants
management system under U.S. Department of Health and Human Services, for CRF
recipients to report expenditures quarterly. To date, CRF data has been collected up to
and through September 30, 2023. This data is displayed on the Pandemic Response
Accountability Committee’s website (https://www.pandemicoversight.gov/).

During this semiannual reporting period, as part of our compliance monitoring of CRF
payments, Castro & Company, LLC (Castro), a certified independent public accounting
firm, working under a contract with and supervised by our office, performed the
following activities and outreach efforts for CRF recipients.

      Desk Review of the Commonwealth of Virginia’s Use of Coronavirus
      Relief Fund Proceeds

      Castro found the Commonwealth of Virginia (Virginia) did not comply with the
      CARES Act and Treasury Guidance. Virginia was unable to provide complete
      transaction information for aggregate reporting less than $50,000 and
      aggregate payments to individual’s payment categories, and Castro was unable
      to test these expenditures. Treasury OIG questioned a total of $870,559,763
      due to unsupported expenditures.

      Castro determined that Virginia’s risk of unallowable use of funds was high and
      recommended that Treasury OIG follow up with Virginia on reporting corrections
      related to the expenditure category descriptions and pursue obtaining
      documentation from Virginia’s management. Based on Virginia’s responsiveness
      to Treasury OIG’s requests and management’s ability to provide documentation,
      Castro recommended Treasury OIG determine if a full scope audit is feasible.
      (OIG-CA-23-042) $870,559,763 Questioned Costs




      Treasury Office of Inspector General Semiannual Report—September 2023   9
                 Office of Audit – Significant Audits and Other Products

Desk Review of State of Florida’s Use of Coronavirus Relief Fund
Proceeds

Castro found that the State of Florida complied with the CARES Act and
Treasury Guidance. However, Castro found that the expenditures related to
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 aggregate reporting
less than $50,000 did not comply with the CARES Act and Treasury guidance.
Castro also found that direct payments greater than or equal to $50,000
complied with the CARES Act but did not comply with Treasury Guidance.
Castro identified $893,154,358 in questioned costs.

Castro determined that Florida’s risk of unallowable use of funds was high and
recommended that Treasury OIG pursue obtaining missing documentation from
Florida, ensure reporting corrections are made, ascertain whether recoupment of
funds is necessary, and determine if a full-scope audit is feasible.
(OIG-CA-23-029) $893,154,358 Questioned Costs

Desk Review of the Los Angeles County, California’s Use of
Coronavirus Relief Fund Proceeds

Castro found Los Angeles (LA) County was compliant with the Financial
Progress Reports (FPR) submission timeline as required under Treasury’s
guidance. Castro found that LA County expenditures for the direct payments
greater than or equal to $50,000 and aggregate payments to Individuals
payment types complied with the CARES Act and Treasury guidance. Castro
found that CRF proceeds for the aggregate reporting less than $50,000
payment type complied with the CARES Act but did not comply with Treasury
guidance. Additionally, Castro found that LA County expenditures related to the
Contracts greater than or equal to $50,000 payment type did not comply with
the CARES Act and Treasury Guidance due to a lack of supporting
documentation for expenditures totaling $249,052,032.

Based on the totality of the work performed, Castro identified total questioned
costs of $249,052,032 and determined LA County’s risk of unallowable use of
funds to be high. Castro recommended that Treasury OIG pursue obtaining
documentation from LA County management and ensure reporting corrections
were made. Further, based on LA County’s responsiveness to Treasury OIG’s
requests and its ability to provide documentation, Castro recommended that


Treasury Office of Inspector General Semiannual Report—September 2023   10
                 Office of Audit – Significant Audits and Other Products

Treasury OIG determine if a focused audit is feasible over LA County’s contracts
greater than or equal to $50,000 and aggregate reporting less than $50,000.
(OIG-CA-23-027) $249,052,032 Questioned Costs

Desk Review of Navajo Nation Tribal Government’s Use of
Coronavirus Relief Fund Proceeds

Castro found that Navajo Nation Tribal Government (Navajo Nation) did not
complete the required quarterly FPR for two reporting periods. Castro
determined that the expenditures related to the Grants greater than or equal to
$50,000, aggregate reporting less than $50,000, and aggregate payments to
Individuals payment types reviewed did not comply with the CARES Act and
Treasury guidance, resulting in questioned costs.

Based on the totality of the work performed, Castro determined Navajo Nation’s
risk of unallowable use of funds to be high. Castro recommended that Treasury
OIG pursue obtaining supporting documentation from Navajo Nation personnel,
ensure reporting corrections are made, and determine if a focused audit is
feasible for Grants greater than or equal to $50,000, aggregate reporting less
than $50,000, and aggregate payments to Individuals. For aggregate payments
to individuals, Castro recommended a specific focus on Navajo Nation’s non-
payroll COVID-19 hardship claims, as well as payroll expenditures for employees
substantially dedicated to COVID-19 recovery efforts if feasible.
(OIG-CA-23-041) $80,844,218 Questioned Costs

Desk Review of Lancaster County Pennsylvania’s (Lancaster) Use of
Coronavirus Relief Fund Proceeds

Castro found that Lancaster did not comply with the quarterly FPR timeline as
required by Treasury guidance. In addition, Castro found that one submission
was prepared and certified by the same person, which did not comply with the
segregation of duties requirement for quarterly submissions. Castro also found
that Lancaster personnel could not provide necessary documentation to support
19 of 20 transactions selected for review, which resulted in unsupported
obligations and expenditures in the amounts of $57,734,925 and $38,793,071.

Castro determined that Lancaster’s risk of unallowable use of funds was high
and recommended that Treasury OIG pursue obtaining documentation from
Lancaster personnel and ensure reporting corrections are made. Further, based


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                 Office of Audit – Significant Audits and Other Products

on Lancaster’s responsiveness to Treasury OIG’s requests and its ability to
provide documentation, Castro recommended that Treasury OIG determine if a
full-scope audit is feasible. (OIG-CA-23-024) $38,793,071 Questioned Costs

Desk Review of the Commonwealth of Puerto Rico’s Use of
Coronavirus Relief Fund Proceeds

Castro found that the Commonwealth of Puerto Rico (Puerto Rico) did not
comply with the CARES Act and Treasury guidance, resulting in $33,681,692 in
questioned costs.

Castro determined that Puerto Rico’s risk of unallowable use of funds was high
and recommended that Treasury OIG pursue obtaining missing documentation
from Puerto Rico personnel and follow up on necessary reporting corrections
within the grants reporting portal. Also, based on Puerto Rico’s responsiveness
to Treasury OIG’s requests and management’s ability to provide documentation,
Castro recommended that Treasury OIG determine if a full scope audit is
feasible. (OIG-CA-23-040) $33,681,692 Questioned Costs

Desk Review of the Turtle Mountain Band of Chippewa Indians’ Use
of Coronavirus Relief Fund Proceeds

Castro found that the Turtle Mountain Band of Chippewa Indians’ (TMBCI)
expenditures related to quarterly FPR submissions did not comply with the
CARES Act and Treasury guidance, resulting in $32,333,620 in questioned
costs.

Castro determined TMBCI’s risk of unallowable use of funds were high and
recommended that Treasury OIG pursue obtaining supporting documentation
from TMBCI to ensure reporting corrections are made and determine if a full-
scope audit is feasible. (OIG-CA-23-026) $32,333,620 Questioned Costs

Desk Review of the State of Texas’ Use of Coronavirus Relief Fund
Proceeds

Castro found the State of Texas complied with the CARES Act and Treasury’s
guidance for expenditures related to direct payments greater than or equal to
$50,000 and aggregate payments to individuals. However, the expenditures
related to contracts greater than or equal to $50,000, grants greater than or
equal to $50,000, and aggregate reporting less than $50,000 did not comply


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                 Office of Audit – Significant Audits and Other Products

with CARES Act and Treasury’s Guidance. Due to ineligible and unsupported
expenditures, Treasury OIG identified $17,288,575 in questioned costs.

Castro determined that Texas’ risk of unallowable use of funds was high and
recommended that Treasury OIG obtain documentation, follow-up on all Texas’
necessary reporting corrections and 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. (OIG-CA-23-034) $17,288,575 Questioned Costs


Desk Review of the Commonwealth of the Northern Mariana Islands’
Use of Coronavirus Relief Fund Proceeds

Castro found that the Commonwealth of the Northern Mariana Islands (CNMI)
was not compliant with the quarterly FPR reporting timeline as required under
Treasury guidance for three reporting cycles. Additionally, Castro found that the
expenditures related to contracts greater than or equal to $50,000, aggregate
reporting less than $50,000, and aggregate payments to individuals did not
comply with the CARES Act and Treasury guidance, which resulted in total
questioned costs of $11,146,813.

Castro determined that CNMI’s risk of unallowable use of funds is high and
recommends that Treasury OIG request missing documentation from CNMI
management and follow up on necessary reporting corrections. Further, based
on CNMI’s responsiveness to Treasury OIG’s requests and its ability to provide
documentation, Castro recommended that Treasury OIG determine if a full-
scope audit is feasible. (OIG-CA-23-039) $11,146,813 Questioned Costs

Desk Review of San Bernardino County, California’s Use of
Coronavirus Relief Fund Proceeds

Castro found that San Bernardino County, California (San Bernardino) was
compliant with the quarterly FPR reporting timeline as required under Treasury
guidance. Castro determined that San Bernardino’s expenditures for grants
greater than or equal to $50,000 and direct payments greater than or equal to
$50,000 did not comply with the CARES Act and Treasury guidance. Based on
Castro’s desk review, Treasury OIG questioned total costs of $4,151,612 due
to ineligible expenditures and a lack of supporting documentation.




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                 Office of Audit – Significant Audits and Other Products

Based on the totality of the work performed, Castro determined that San
Bernardino’s risk of unallowable use of funds is moderate and recommended
Treasury OIG obtain documentation from San Bernardino’s management to
ensure reporting corrections are made. Additionally, Castro recommended
Treasury OIG determine if a focused audit is feasible for expenditures related to
grants greater than or equal to $50,000 and direct payments greater than or
equal to $50,000. (OIG-CA-23-030) $4,151,612 Questioned Costs

Desk Review of the Native Village of Point Hope’s Use of
Coronavirus Relief Fund Proceeds

Castro could not determine if the Native Village of Point Hope’s (Point Hope)
use of CRF proceeds complied with the CARES Act and Treasury guidance, due
to Point Hope personnel’s failure to communicate or provide documentation
during the desk review. Therefore, Castro questioned the entire $2,348,064 in
CRF proceeds that Point Hope received from Treasury.

Castro determined that Point Hope’s risk of unallowable use of funds was high
and recommended that Treasury OIG personnel follow-up on the missing
documentation and make a determination whether to conduct a full-scope audit
of Point Hope. In addition, Castro recommended that Treasury OIG 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. (OIG-CA-23-038) $2,348,064 Questioned
Costs

Desk Review of the City of Dallas, Texas’ Use of Coronavirus Relief
Fund Proceeds

Castro found that the City of Dallas, Texas (Dallas) did not comply with the
CARES Act and Treasury guidance. Dallas personnel could not provide the
necessary documentation to support 1 of 19 transactions selected for review,
resulting in total unsupported expenditures of $2,211,594.

Castro determined that Dallas’ risk of unallowable use of funds was moderate
and recommended that 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


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                 Office of Audit – Significant Audits and Other Products

documentation, Castro recommended Treasury OIG determine if a focused audit
of aggregate payments to individuals is feasible. (OIG-CA-23-028) $2,211,594
Questioned Costs


Desk Review of the State of Tennessee’s Use of Coronavirus Relief
Fund Proceeds

Castro found the State of Tennessee’s (Tennessee) expenditures for contracts
greater than or equal to $50,000, Direct Payments greater than or equal to
$50,000, and aggregate reporting less than $50,000 complied with the CARES
Act and Treasury’s guidance. Castro found that expenditures for grants greater
than or equal to $50,000, and aggregate payments to individuals did not
comply with the CARES Act and Treasury’s Guidance. Castro identified total
questioned costs of $1,162,364.

Castro determined Tennessee’s risk of unallowable use of funds was moderate
and recommended that Treasury OIG pursue obtaining documentation from
Tennessee personnel, ensure reporting corrections are made, and determine if a
focused audit is feasible for grants greater than or equal to $50,000 and
aggregate payments to individuals. (OIG-CA-23-035) $1,162,364 Questioned
Costs


Desk Review of Pleasant Point Indian Reservation, Maine’s Use of
Coronavirus Relief Fund Proceeds

Castro found that Pleasant Point Indian Reservation, Maine’s (Pleasant Point’s)
expenditures for the aggregate reporting less than $50,000 payment types
complied with the CARES Act and Treasury’s guidance. Castro found that CRF
proceeds for the contracts greater than or equal to $50,000, transfers greater
than or equal to $50,000, and aggregate payments to individuals did not
comply with the CARES Act and Treasury’s Guidance. Castro identified
$339,672 in questioned costs.

Castro determined Pleasant Point’s risk of unallowable use of funds was
moderate and does not recommend Treasury OIG perform an audit of Pleasant
Point. However, Castro recommended Treasury OIG follow-up on the status of
single audit reports and necessary reporting corrections for contracts greater
than or equal to $50,000, transfers greater than or equal to $50,000, and


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                 Office of Audit – Significant Audits and Other Products

aggregate payments to individuals. (OIG-CA-23-033) $339,672 Questioned
Costs


Desk Review of Phoenix, Arizona’s Use of Coronavirus Relief Fund
Proceeds

Castro found that Phoenix, Arizona (Phoenix) complied with the required
quarterly FPR submission timeline as required under Treasury’s guidance. Castro
found that the expenditures for the contracts 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 complied with the CARES Act
and Treasury’s guidance. Castro found that CRF proceeds for the Grants greater
than or equal to $50,000 payment type did not comply with the CARES Act
and Treasury’s guidance. Castro identified $147,379 in questioned costs.

Castro determined Phoenix’s risk of unallowable use of funds was moderate and
recommended that Treasury OIG pursue obtaining missing documentation from
Phoenix personnel and determine if a focused audit is feasible for grants greater
than or equal to $50,000. (OIG-CA-23-032) $147,379 Questioned Costs

Desk Review of State of Ohio’s Use of Coronavirus Relief Fund
Proceeds

Castro found that the State of Ohio (Ohio) was compliant with the quarterly FPR
reporting timeline as required under Treasury’s guidance. Castro determined that
Ohio’s expenditures for grants greater than or equal to $50,000 and transfers
greater than or equal to $50,000 did not comply with the CARES Act and
Treasury’s guidance. Based on the desk review, Treasury OIG questioned total
costs of $86,801 due to ineligible expenditures and a lack of supporting
documentation.

Based on the totality of the work performed, Castro determined that Ohio’s risk
of unallowable use of funds is low and did not recommend Treasury OIG
perform an audit of Ohio’s use of CRF proceeds. Castro recommended that
Treasury OIG obtain documentation from Ohio’s management to ensure
reporting corrections are made. Additionally, Castro recommended that Treasury
OIG obtain information from Ohio management to determine whether there are
ineligible severance pay transactions in addition to those already identified as
part of the desk review. (OIG-CA-23-037) $86,801 Questioned Costs

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                 Office of Audit – Significant Audits and Other Products

Desk Review of the Chippewa Cree Tribe’s Use of Coronavirus Relief
Fund Proceeds

Castro found that the Chippewa Cree Tribe’s (CCT) expenditures related to
Grants greater than or equal to $50,000 did not comply with the CARES Act
and Treasury’s guidance. Based on Castro’s desk review, Treasury OIG
questioned unsupported expenditures in the amount of $75,091. In addition,
Castro found that CCT personnel incorrectly classified the tribe’s obligations and
expenditures for direct payments in the GrantsSolutions portal in the amount of
$7,080,546 and $6,836,895.

Castro determined that CCT’s risk of unallowable use of funds was high and
recommended that Treasury OIG follow-up on all CCT’s corrections and
reclassification entries and then perform audit work on those related
transactions. (OIG-CA-23-018) $75,091 Questioned Costs

Desk Review of the State of California’s Use of Coronavirus Relief
Fund Proceeds

Castro found the State of California’s (California) documentation supporting the
uses of CRF proceeds complied with the CARES Act and Treasury’s Guidance,
except for the questioned costs for a subscription in the amount of $6,952.

Castro determined California’s risk of unallowable use of funds was low and did
not recommend Treasury OIG perform an audit; however, Castro recommended
Treasury OIG confirm that appropriate corrections have been made, or if not,
determine whether these funds have been returned to Treasury.
(OIG-CA-23-025) $6,952 Questioned Costs

Desk Review of the State of Illinois’ Use of Coronavirus Relief Fund
Proceeds

Castro found the State of Illinois (Illinois) did not have reporting issues or
variances and found the transactions selected were supported by
documentation, in accordance with the CARES Act and Treasury’s guidance.
Castro determined that Illinois’ risk of unallowable use of funds was low and did
not recommend Treasury OIG perform an audit of Illinois. (OIG-CA-23-019)




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                 Office of Audit – Significant Audits and Other Products

Desk Review of The Cherokee Nation, Oklahoma’s Use of
Coronavirus Relief Fund Proceeds

Castro found the Cherokee Nation, Oklahoma did not have reporting issues or
variances and found the transactions selected for were supported by
documentation, in accordance with the CARES Act and Treasury’s guidance.
Castro determined that the Cherokee Nation’s risk of unallowable use of funds
was low and did not recommend Treasury OIG perform an audit of the Cherokee
Nation. (OIG-CA-23-020)

Desk Review of New York City’s Use of Coronavirus Relief Fund
Proceeds

Castro found New York City was not compliant with the quarterly FPR reporting
timeline as required under Treasury guidance for three reporting periods. In
addition, Castro reviewed documentation for a selection of 25 transactions in
the quarterly reports. Other than timely reporting and errors reported in the
loans greater than or equal to $50,000 and aggregate reporting less than
$50,000 expenditure categories, Castro’s review of New York City’s quarterly
FPR submissions did not identify reporting issues. The errors in the loans greater
than or equal to $50,000 and aggregate reporting less than $50,000
expenditure categories were corrected by New York City personnel.

Once the corrections were made it was determined that the use of CRF
proceeds for contracts greater than or equal to $50,000, loans greater than or
equal to $50,000, aggregate reporting for transactions less than $50,000, and
aggregate payments to individuals complied with the CARES Act and Treasury’s
guidance.

Based on the totality of work performed, Castro determined that New York
City’s risk of unallowable use of funds is low and did not recommend Treasury
OIG perform an audit of New York City. However, Castro notified Treasury OIG
about New York City’s potential future loan repayments so Treasury OIG can
coordinate with Treasury management regarding monitoring and return of funds.
(OIG-CA-23-021)




Treasury Office of Inspector General Semiannual Report—September 2023   18
                       Office of Audit – Significant Audits and Other Products


Cyber/Information Technology
FISMA

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

      The Gulf Coast Ecosystem Restoration Council Federal Information
      Security Modernization Act of 2014 Evaluation Report for Fiscal
      Year 2023

      RMA Associates, LLC (RMA), a certified independent public accounting firm,
      working under a contract supervised by our office, performed the annual FISMA
      evaluation of Council’s security program and practices for period April 1, 2022
      through March 31, 2023. RMA found the Council’s information security
      program and practices were effective for the evaluation period. RMA did not
      make any recommendations to the Council. Council’s management concurred
      with the report. (OIG-CA-23-036)

      Fiscal Year 2021 Audit of the Department of the Treasury’s
      Information Security Program and Practices for Its Intelligence
      Systems

      In our FISMA audit of Treasury’s intelligence systems for the period July 1,
      2020 through June 30, 2021, we reported that Treasury’s security program and
      practices for its intelligence systems were not effective according to
      Department of Homeland Security’s criteria.

      Treasury management concurred with the recommendations made in our report.
      Due to the sensitive nature of these systems, this report is designed as
      classified (OIG-23-035).




      Treasury Office of Inspector General Semiannual Report—September 2023   19
                       Office of Audit – Significant Audits and Other Products

      Fiscal Year 2022 Audit of the Department of the Treasury’s
      Information Security Program and Practices for Its Intelligence
      Systems

      In our FISMA audit of Treasury’s intelligence systems for the period July 1,
      2021 through March 31, 2022, we reported that Treasury’s security program
      and practices for its intelligence systems were not effective according to
      Department of Homeland Security’s criteria. Treasury management concurred
      with the recommendations made in our report. Due to the sensitive nature of
      these systems, this report is designed as classified (OIG-23-036).


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.

      Audit of FinCEN's Management of BSA Data - Suppression Report

      This report is the first in a series of reports addressing Financial Crimes
      Enforcement Network (FinCEN) retention of Bank Secrecy Act (BSA) data, and
      more specifically suppression, which is a part of the retention process wherein
      FinCEN restricts access to specific financial records.

      We found FinCEN did not process all BSA record suppression requests timely,
      adequately, and in accordance with FinCEN policy. Specifically, FinCEN did not:
      (1) timely process and adequately document the disposition of suppression
      requests, to include notifying requesters in writing; and (2) ensure that bulk data
      recipients removed suppressed records from their respective databases.

      We recommended that the Director of FinCEN: (1) update policy and procedures
      for the BSA record suppression and duplicate BSA record suppression processes
      to establish a timeliness metric for processing suppression requests and to
      require that all relevant tracking information, such as BSA identification
      numbers, is maintained; (2) update policy and procedures for the BSA record
      suppression and duplicate BSA record suppression processes to require a review
      of suppression requests for timeliness and appropriate processing and
      documentation; (3) ensure that suppression requesters are notified in writing of
      suppression disposition and suppressions are documented in accordance with
      standard operating procedures; (4) establish a dedicated email address for


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                       Office of Audit – Significant Audits and Other Products

      receiving law enforcement suppression requests and designate an alternate
      person for processing suppressions; (5) require agencies that receive bulk data
      to remove suppressed records as a condition of their memorandum of
      understanding; and (6) 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.

      FinCEN management concurred with our recommendations and provided their
      implemented and planned corrective actions. FinCEN’s stated corrective actions
      meet the intent of our recommendations. (OIG-23-030)


Financial Management
Payment Integrity Information Act of 2019

RMA, a certified independent public accounting firm, working under a contract with
and supervised by our office, performed an audit of Treasury’s compliance with the
Payment Integrity Information Act of 2019 (PIIA) for fiscal year (FY) 2022. Our office
performed the audit of the Council’s compliance with PIIA for FY 2022. As required by
PIIA, we reported on Treasury’s and the Council’s overall compliance with PIIA for
Fiscal Year (FY) 2022.

      Treasury PIIA for FY 2022

      RMA reported that Treasury was not in compliance with PIIA for FY 2022.
      Treasury complied with nine of the ten PIIA requirements. However, Treasury
      did not comply with the requirement to report an improper payment rate of less
      than 10 percent for its programs identified as susceptible to significant improper
      payments because IRS reported an improper payment rate of more than 10
      percent for four of its programs identified as susceptible to significant improper
      payments: (i) Earned Income Tax Credit; (ii) American Opportunity Tax Credit;
      (iii) Additional Child Tax Credit; and (iv) Net Premium Tax Credit. RMA did not
      make any recommendations related to this finding.

      RMA also identified inaccurate responses and justifications by the management
      officials of the Bureau of the Fiscal Service (Fiscal Service), the Treasury
      Forfeiture Fund (TFF), and the Office of Special Inspector General for the
      Troubled Asset Relief Program (SIGTARP) to some risk assessment questions


      Treasury Office of Inspector General Semiannual Report—September 2023   21
                       Office of Audit – Significant Audits and Other Products

      used in determining the payment type’s susceptibility to significant improper
      payments. RMA recommended that Treasury’s Risk and Control Group work
      with management at the Fiscal Service, TFF, and SIGTARP 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.
      Treasury agreed with RMA’s recommendation and provided corrective actions.
      (OIG-23-026)

      Gulf Coast PIIA FY 2022

      We determined that the Gulf Coast Ecosystem Restoration Council (Council)
      complied with the requirements of PIIA for fiscal year 2022. However, during
      our review of the Council's payment integrity information, we found that certain
      risk assessment information reported on PaymentAccuracy.gov by the Council
      was not consistent with the supporting documentation provided to us. We
      recommended that the Council: (1) consult Office of Management and Budget’s
      (OMB) Payment Integrity Annual Data Call Instructions or its subsequent
      revisions to determine how to report its payment integrity information; and (2)
      review payment integrity information submitted to the OMB Annual Data Call
      prior to live publication to ensure accuracy of data reported. The Council agreed
      with our recommendations and provided corrective actions. (OIG-23-025)


Attestation Engagements

Independent certified public accounting firms, S&R and KPMG LLP (KPMG), under
contracts monitored by our office, completed the reports described below in support of
the audit of Treasury’s FY 2023 consolidated financial statements and the financial
statement audits of certain other Federal agencies.

      Reports on the Processing of Transactions by Treasury Enterprise
      Applications

      S&R examined the Treasury Enterprise Applications’ description of controls for
      processing user entities’ human resource transactions in its HRConnect system;
      and the suitability of the design and effectiveness of these controls for the
      period beginning July 1, 2022, and ending June 30, 2023. S&R found, in all
      material respects, the controls were fairly presented in the description of
      controls for this system, suitably designed, and controls tested operated
      effectively throughout the period. (OIG-23-034)

      Treasury Office of Inspector General Semiannual Report—September 2023   22
                             Office of Audit – Significant Audits and Other Products



        Reports on the Processing of Transactions by Fiscal Service

        KPMG examined the accounting and procurement processing and general
        computer controls related to financial management services provided to various
        Federal agencies by Fiscal Service’s Administrative Resource Center for the
        period beginning July 1, 2022, and ending June 30, 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-23-037)

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
FY 2022 consolidated financial statements.

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


The status of these instances of noncompliance, including progress in implementing
remediation plans, will be evaluated as part of the audit of Treasury’s FY 2023
consolidated financial statements.


Consolidated Appropriations Act, 2021
We are required to submit a report twice a year to Congress and Treasury on the
oversight provided for programs established under Title V, Subtitle B in Division N of
the Consolidated Appropriations Act, 2021 (CAA, 2021). During this semiannual
reporting period, we reported on the Community Development Financial Institutions
(CDFI) Fund’s Award and Post-Award Administration of the CDFI Rapid Response
Program (RRP) and on Fund’s Implementation of the CDFI Equitable Recovery Program
(ERP).


        Treasury Office of Inspector General Semiannual Report—September 2023                       23
                 Office of Audit – Significant Audits and Other Products

Audit of the Community Development Financial Institutions Fund’s
Award and Post-Award Administration of the CDFI Rapid Response
Program

We found that CDFI Fund management documented the CDFI RRP awards
process across multiple standard operating procedures (SOPs), consistent with
the U.S. Government Accountability Office’s (GAO) Standards for Internal
Control in the Federal Government (Green Book). CDFI Fund management also
accurately calculated CDFI RRP awards and administered them in accordance
with the CAA, 2021 and the OMB Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards, 2 Code of Federal
Regulations Part 200 (Uniform Guidance). However, the CDFI Fund did not
comply with subsequent payment review and approval timelines for 2 of the 91
payments we tested. Despite the CDFI Fund’s delays in approving the
recipients’ subsequent award payment requests, we do not believe there is a
systemic issue with the timeliness of CDFI RRP payment reviews.
The CDFI Fund designed and implemented the CDFI RRP post-award
administration process, to include recipient monitoring, in compliance with the
CAA, 2021, Uniform Guidance, and GAO Green Book. CDFI Fund management
developed post-award and monitoring SOPs as well as the Assistance
Agreement, which incorporated Uniform Guidance requirements to recipients.
Furthermore, management established: (1) procedures for evaluating CDFI RRP
annual compliance reports; (2) a non-compliance process; and (3) a process for
closing CDFI RRP awards. Finally, the CDFI Fund provided CDFI RRP available
data for Treasury’s report on the impact of programs under the CAA, 2021. We
did not make any recommendations. (OIG-23-032)

Audit of the Community Development Financial Institutions Fund’s
Implementation of the CDFI Equitable Recovery Program

We found that CDFI Fund took appropriate steps to establish the CDFI ERP to
include making funds available to recipients, as well as establishing policies,
procedures, and program guidance. CDFI Fund management took appropriate
steps to establish the CDFI ERP in compliance with GAO’s Standards for Internal
Control in the Federal Government (the “Green Book”), the CAA, 2021, and
OMB Uniform Guidance. The CDFI Fund established internal controls over the
CDFI ERP in accordance with the Green Book to include: (1) a process for CDFIs
to apply for CDFI ERP awards conforming to the CAA, 2021; and (2) a CDFI


Treasury Office of Inspector General Semiannual Report—September 2023   24
                       Office of Audit – Significant Audits and Other Products

      ERP application evaluation process (including award determinations) to meet the
      legislative requirements.

      We determined that the CDFI Fund provided sufficient guidance to potential
      CDFI ERP applicants and developed CDFI ERP-specific application submission
      and review processes, policies and procedures, and internal guidance for
      program personnel. In designing a framework to comply with the CAA, 2021,
      CDFI Fund management consulted with officials from Treasury, the OMB, and
      staff members from the Senate Committee on Banking, Housing, and Urban
      Affairs and the House Financial Services Committee. CDFI Fund management
      allocated existing staff, hired new personnel, and contracted external reviewers
      in standing up the CDFI ERP. Additionally, the CDFI Fund leveraged existing
      program structures from the CDFI Rapid Response Program and the CDFI
      Financial Assistance Program and used existing tools to evaluate CDFI ERP
      candidates’ financial and compliance risk. We did not make any
      recommendations. (OIG-23-033)


Council of Inspectors General on Financial Oversight Audit of the
Financial Stability Oversight Council
The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-
Frank) created the Council of Inspectors General on Financial Oversight (CIGFO),
whose members include the Inspectors General with oversight authority for the
majority of the Financial Stability Oversight Council (FSOC) member agencies.
Treasury OIG’s Acting Inspector General is the Chair of CIGFO. Dodd--Frank authorizes
CIGFO to convene a working group of its members to evaluate the effectiveness and
internal operations of FSOC.

      Council of Inspectors General on Financial Oversight – Audit of the
      Financial Stability Oversight Council’s Efforts to Address Climate-
      Related Financial Risk

      CIGFO convened a Working Group to perform an audit to assess FSOC’s
      response to Executive Order (EO) 14030, Climate-Related Financial Risk. This
      report was issued in May 2021.

      We concluded that FSOC’s actions were consistent with the policy, objectives,
      and directives set forth in EO 14030. Additionally, FSOC engaged with the
      member agencies to assess climate-related financial risk and implemented an

      Treasury Office of Inspector General Semiannual Report—September 2023   25
                 Office of Audit – Significant Audits and Other Products

effective process to develop its Report on Climate-Related Financial Risk. We
determined that the FSOC Report satisfactorily met the requirements set forth in
EO 14030. Finally, FSOC established a means to facilitate ongoing coordination
and information sharing among its member agencies on climate-related financial
risk.

While we made no recommendations in this report, we encouraged FSOC,
through the newly established Climate-Related Financial Risk Committee, to
consider member agency suggestions and feedback to enhance the assessment
and sharing of climate-related financial risk data and information.
(CIGFO-2023-001)




Treasury Office of Inspector General Semiannual Report—September 2023   26
Office of Investigations – Significant Investigations and
Other Products
CARES Act Investigations
Florida Resident sentenced for Wire Fraud associated with the CARES Act
and Paycheck Protection Program Loan

On August 15, 2023, the final subject in a Treasury OIG investigation was sentenced.
The subjects conspired to defraud the U.S. government by applying for Paycheck
Protection Program Loans and receiving $1.8 million in fraudulently obtained funds.
Two subjects were declined for prosecution and the final subject was sentenced to a
total of 37 months incarceration, and $1.8 million in restitution. The U.S. Attorney’s
Office (USAO) for the Eastern District of Virginia prosecuted the case.


Other Significant Investigations
Prosecution in California Declined for ERA Fraud

On April 12, 2023, the OIG completed its report of investigation based on receipt of a
complaint alleging that two individuals submitted multiple false tenant and landlord
applications in order to obtain $289,000 in Emergency Rental Assistance (ERA) from
the California ERA Program. The investigation determined that the same Internet
Protocol address was used for all the applications, and the addresses listed on the
application were different than the identification documents of the tenants. Criminal
prosecution was presented and declined by the USAO for the Central District of
California and by the California Office of the Attorney General for lack of resources
and low monetary value.

Florida Resident Sentenced to One Count of Wire Fraud for Theft of Funds
Through the Payroll Protection Program

On April 24, 2023, a Florida bank employee was sentenced to 15 months'
imprisonment and 36 months’ probation for one count of Wire Fraud. The subject was
also ordered to pay restitution in the amount of $168,000, to forfeit $243,000, and to
pay a special assessment of $100. The subject fraudulently applied for Small Business
Administration Payroll Protection Program loans, deposited the loan amounts into his
bank accounts and withdrew funds for matters unrelated to a business. The U.S.


      Treasury Office of Inspector General Semiannual Report—September 2023   27
                             Office of Investigations – Significant Investigations

District Court for the Middle District of Florida prosecuted the joint Treasury OIG and
Federal Deposit Insurance Corporation OIG case.

Prosecution Declined in Virginia for ERA Fraud

On April 10, 2023, the OIG completed its report of investigation for a case initiated
upon receipt of information from the Virginia Department of Housing and Community
Development, Richmond, Virginia, concerning an alleged fraudulent application for
Emergency Rental Assistance (ERA) under the Virginia Rent Relief Program. The
subjects misrepresented information on their applications to obtain $87,000 in ERA
funds. The case was presented to and declined by both the USAO for the Eastern
District of Virginia and the Arlington County, Virginia Commonwealth Attorney for low
monetary value.

U.S. Mint Police Officer Engaged in Sexual Activity on Government
Property

On February 1, 2023, the OIG completed its report of investigation for a case initiated
upon receipt of information from the United States Mint (Mint) that a Mint contract
employee was sexually assaulted by a Mint police officer while they were both on duty
at the Denver Mint. The complainant alleged repeated unwanted sexual contact by the
subject, and one incident of alleged rape. The subject denied force or unwanted
contact with the complainant but admitted to multiple consensual sexual encounters
with the complainant on duty at the Mint. The investigation determined that there was
sexual activity between the complainant and the subject on government property and
during duty hours. Criminal prosecution of the subject was presented and declined by
the USAO for the District of Colorado. Treasury OIG provided a report to the Mint for
their information and the subject was removed from their position at the Mint during
this reporting period.


U.S. Mint Police Officer Actively Participated in Ponzi Scheme

On February 15, 2023, the OIG completed its report of investigation for a case
initiated upon notification that a San Francisco Mint Police Officer was actively
involved in Ponzi schemes. The investigation determined that the officer was involved
in a Ponzi scheme based on interviews and social media posts associated with the
schemes. Criminal prosecution of the employee was presented and declined by the
USAO for the Northern District of California. Treasury OIG provided a report to the



      Treasury Office of Inspector General Semiannual Report—September 2023    28
                             Office of Investigations – Significant Investigations

Mint for their information and the subject was issued a letter of reprimand during this
reporting period.

Alleged Contract Fraud with U.S. Mint Equipment Purchase
Unsubstantiated

On July 13, 2023, the OIG completed its report of investigation into allegations that a
Mint employee authorized the sole-source purchase of equipment incapable of
completing required tasks. The complainant alleged that the modifications needed
incurred additional cost. The investigation determined no additional costs were
incurred by the Mint to retrofit the purchased equipment. In addition, the sole-source
justification signed by the employee was used to procure machines at three separate
Mint facilities. The initial procurement utilizing the justification was drafted and
occurred at a different facility. The justification stated that the machines were
equipped with the highest level of safety features offered on the market. These safety
features were required by the Mint’s newly adopted policy of “Safety First.”

Treasury Office of Inspector General Employee Worked for Multiple
Companies During Official Government Work Hours

The OIG completed its report of investigation for a case initiated upon notification that
a Treasury OIG employee was employed by a government contractor, while
simultaneously employed as an auditor. The investigation determined that the
employee was aware of the Treasury OIG outside employment approval process and
knowingly failed to comply with the policy. The employee was employed by four
companies in addition to Treasury OIG for a five-month period, claiming overlapping
hours for the OIG and at least two outside companies at the same time. A report was
provided, and the employee was terminated.


Prosecution in Oregon Declined for ERA Fraud

On May 31, 2023, the OIG completed its report of investigation on an inquiry based
on an anonymous allegation that the subject had multiple individuals fraudulently apply
for ERA. The subject directed individuals, not residing on their property, to apply for
ERA funds. The Oregon Housing and Community Services later found that only one
ERA application for $15,000 dollars was paid to a fraudster. The investigation was
presented and declined by the USAO for the District of Oregon and the Oregon State
Prosecutor’s office for low monetary value.



      Treasury Office of Inspector General Semiannual Report—September 2023    29
                             Office of Investigations – Significant Investigations

Bureau of the Fiscal Service Employee Forged Senior Official Signatures

On April 4, 2023, the OIG completed its report of investigation for a case initiated
upon notification that a Bureau of the Fiscal Service (Fiscal Service) human resources
employee forged the Fiscal Service Commissioner’s digital signature on an OF-8,
Position Description form. The OIG conducted a forensic examination of the
employee’s work computer that resulted in the employee admitting to applying the
Fiscal Service Commissioner’s digital signature to multiple documents because they
forgot to get the signature and were backed up on work. A report was provided to
Fiscal Service for its information and the employee resigned.

OCC Employee Impersonated a Federal Law Enforcement Officer

On January 13, 2022, the OIG completed its report of investigation for a case initiated
upon notification that a National Bank Examiner with the Office of the Comptroller of
the Currency (OCC) falsely represented themselves as a Federal Law Enforcement
Officer by showing their OCC credentials and badge to obtain special considerations
within their local community. The OIG investigation substantiated the allegation.
Criminal prosecution of the OCC employee was presented and declined by the USAO
for the Middle District of Pennsylvania. A report was provided to the OCC for its
information and the employee received a 30-day suspension during this reporting
period.




      Treasury Office of Inspector General Semiannual Report—September 2023   30
Treasury OIG Accomplishments and Activities
Treasury OIG Special Agent Award

A Treasury OIG Senior Special Agent was recognized by the U.S. Attorney’s Office for
the Southern District of Florida for exceptional investigative work and awarded an
Outstanding Law Enforcement Officer award for 2021-2023.

Treasury OIG Cyber Support

The U.S. Department of Homeland Security, Immigration and Customs Enforcement,
and Homeland Security Investigations (HSI) specifically requested Treasury OIG
support to assist in identifying individuals suspected of using cryptocurrency to
purchase Child Sexual Assault Material. Treasury OIG’s cyber forensics team provided
HSI the results of their actions for their further investigation.

HSI requested cyber forensics support in an investigation involving numerous
individuals submitting fraudulent Unemployment Insurance and Economic Impact
Disaster Loan applications. Treasury OIG’s cyber forensics team provided HSI the
results of their actions for their further investigation.

Treasury OIG Leadership Roles

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

Deborah Harker, Assistant Inspector General for Audit, is the Chair of the Council of
the Inspectors General on Integrity and Efficiency’s (CIGIE) Federal Audit Executive
Council.

Cecilia Howland, Acting 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—September 2023   31
Statistical Summary
Summary of Treasury OIG Activities
April 1, 2023, through September 30, 2023

                                                                                     Number or
 OIG Activity                                                                        Dollar Value
 Office of Counsel Activities
 Regulation and legislation reviews                                                                 22
 Instances where information was refused                                                             0
 Office of Audit Activities
 Reports issued and other products                                                                  47
 Disputed audit recommendations                                                                      0
 Significant revised management decisions                                                            0
 Management decision in which the Inspector General disagrees                                        0
 Monetary Benefits (audit)
 Questioned costs                                                                      $2,239,122,323
 Funds put to better use                                                                           $0
 Total monetary benefits                                                               $2,239,122,323

 Office of Investigations Activities*
 Criminal and judicial actions (including joint investigations)
 Investigative reports issued                                                                     142
 Cases referred for prosecution and/or litigation                                                  37
 Individuals referred for criminal prosecution to the Department of Justice                        44
 Individuals referred for criminal prosecution to state and local authorities                       2
 Cases accepted for prosecution and/or litigation                                                   8
 Arrests                                                                                            0
 Indictments/informations                                                                          17
 Convictions (by trial and plea)                                                                   19
*During the reporting period, subjects were sentenced to 69 months of prison time, 144 months of
 probation, and ordered to pay fines, restitution, and court fees in the amount of $2,128,739.61, and
 seizures and forfeitures in the amount of $3,010,614.18.


Metrics Used for Office of Investigations Activities
Department of the Treasury (Treasury or the Department) 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—September 2023                32
                                                                        Statistical Summary


Reports with Unimplemented Recommendations
Issued prior to April 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 Opportunities, and Revived Economies of the
Gulf Coast States Act of 2012 (RESTORE Act) programs and activities of the Gulf
Coast Ecosystem Restoration Council (Council) and the National Oceanic and
Atmospheric Administration’s Gulf Coast Ecosystem Restoration Science, Observation,
Monitoring, and Technology Program; 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 159 open and unimplemented recommendations for
33 reports issued prior to April 1, 2023, with $2.2 Billion in potential monetary
benefits.

Treasury OIG considers all unimplemented recommendations for reports issued over
six 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—September 2023     33
                                                                        Statistical Summary

Fiscal        Report Number          Report Title                                Date Issued
Year
2018          OIG-18-018          TERRORIST FINANCING/MONEY                   11/17
                                  LAUNDERING: OFAC Human Resources
                                  Practices Need Improvement
1.            The Office of Foreign Assets Control (OFAC) Director should ensure that
              legacy employees' current position descriptions are evaluated to ensure that
              the documented promotion potential of these nonsupervisory employees is
              consistent with OFAC's current promotion practices. Management agreed
              with the recommendation.
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.




         Treasury Office of Inspector General Semiannual Report—September 2023     34
                                                                        Statistical Summary

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 Special Publication 800-53.
              Management agreed with the recommendation.
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.




         Treasury Office of Inspector General Semiannual Report—September 2023     35
                                                                        Statistical Summary

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 should address the
              mainframe operating system vulnerabilities noted in the condition as soon as
              possible.
2.            Develop a tailored mainframe operating system security configuration
              baseline that specifies how security configuration options are to be set
              based on the selected industry guidance.
3.            Ensure that the chief information security officer assigns specific
              responsibility for providing controls over operating system security, including
              access permissions to all system datasets and all security-related option
              settings.
4.            Develop and document controls over changes and monitor update access to
              all key system datasets.
5.            Develop and document controls and baseline documentation of mainframe
              operating system options specified in the configuration files.

6.            Establish which techniques are to be used to control update access to key
              system datasets and to control read access to sensitive system datasets
              (such as the security software database and the page files), whether a third-
              party tool is to be used, or tailored change control mechanisms, and develop
              procedures and documentation to support their use.
7.            Develop procedures to provide assurance that programs installed with the
              privileges of the operating system (whether purchased from software
              vendors or internally developed) do not introduce security weaknesses.
8.            Develop, document, and implement policies, procedures, and controls to
              conduct periodic reviews of actual mainframe security software settings
              against the security baseline.
9.            Develop a mainframe security software risk assessment process using the
              Defense Information Systems Agency Security Technical Implementation
              Guide (STIG) as a guideline.




         Treasury Office of Inspector General Semiannual Report—September 2023     36
                                                                     Statistical Summary

10.        Develop a tailored mainframe security software configuration baseline that
           specifies how security configuration options should be set based on the
           industry guidance. As part of this action, management should develop and
           document a baseline specifying for each possible setting in the security
           software control file how the option should be set and who is responsible
           for approving the setting.

11.        Use the mainframe security software configuration baseline to harden the
           mainframe environment, including the Payment Authorization Manager and
           Payments, Claims, and Enhanced Reconciliations production. Remove
           duplicate and excessive permissions in the mainframe security software
           database.
12.        Remove duplicate and excessive permissions in the mainframe security
           software database.
13.        Perform an annual comparison of each actual setting in the mainframe
           security software control file to each setting specified in the baseline to
           verify compliance with the baseline.
14.        Develop and document procedures for controlling updates to the mainframe
           security software control file.
15.        Define and document the segregation of functions and privileges based on
           the principle of least privilege for mainframe security software and operating
           system.
16.        Review and establish access permissions to the mainframe system and
           security software based on the principle of least privilege access.
17.        Review and re-assess each access permission in the mainframe security
           software dataset and resource rules on a periodic basis.
18.        Develop procedures and documentation to establish the following for each
           dataset permission, resource permission, and mainframe security software
           privilege: a. Responsibility for approving access and enforcing compliance
           with the principle of least privilege; b. Actual access meets the principle of
           least privilege; and c. Any discrepancy from approved access will be
           identified and corrected.
19.        Develop, document, and implement policies, procedures, and controls for
           comprehensive logging and monitoring of events. Procedures and controls
           should include an annual re-assessment of whether logging and reporting is
           adequate.
20.        Review and determine which profiles, applications, databases, and other
           processes on the mainframe will be logged and reviewed.


      Treasury Office of Inspector General Semiannual Report—September 2023     37
                                                                     Statistical Summary

21.        Assess all mainframe logs to determine which logs should be evaluated by
           the incident management tool.
22.        Establish appropriate alerts and event thresholds for those mainframe logs
           required to be evaluated by the external tracking tool.
23.        Develop and implement data and analysis tools and processes for identifying
           event trends, patterns, spikes, and exceptions.
24.        Identify non-security related purposes for logging and monitoring (including
           performance tuning, problem management, capacity planning, and
           management of service level agreements); assign responsibility for
           addressing and integrating them with security uses of logging and
           monitoring.
25.        Identify the possible sources of log information; determine how each is to be
           used for security monitoring; and develop procedures to ensure that each
           type of logging which is necessary for effective security monitoring is
           activated.
26.        Annually assess the effectiveness of security logging and monitoring,
           ensuring that the volume of logged events is limited to just those that are
           needed for security, and ensuring that monitoring results include effective
           identification and response for any violations and for any significant trends
           (such as an increase in the number of password resets for a given group of
           users or repetition of the same attempted but failed attempt to access a
           productions dataset or resource).
27.        Identify, document, and assess the mainframe security controls affecting
           the system software to fully describe how mainframe security is provided.
           These Fiscal Service management controls should include a. Specific
           assignment of responsibility for maintaining operating security, b. Skill
           assessment and remediation for operating system security maintenance,
           c. Baseline documents for mainframe configuration files, d. Standard
           procedures for review and maintenance of operating system security, and
           e. Standard procedures to compare actual configuration settings to baseline
           documents.
28.        Update mainframe documentation to be consistent with Fiscal Service and
           Treasury Directive Publication 85-01, Department of the Treasury
           Information Technology Security Program.
29.        Develop procedures and documentation to establish who is responsible and
           how effective security is achieved for controls.




      Treasury Office of Inspector General Semiannual Report—September 2023     38
                                                                     Statistical Summary

30.        Implement an oversight process to determine that designated Fiscal Service
           personnel review and reevaluate privileges associated with the UNIX
           production environment semiannually for privileged accounts.
31.        Configure the systems-management software agents to include all UNIX
           servers, databases, and users' accounts within the UNIX environment when
           generating the users' lists for the semiannual review and recertification
           process so that all privileged and non-privileged users' access is reviewed.
32.        Update UNIX semiannual account review and recertification procedures to
           include quality control steps to validate that systems-management software
           is generating complete and accurate account listings for all UNIX servers
           and databases privileged and non-privileged user accounts within the UNIX
           environment prior to completing the review and recertification process.
33.        Finalize policies and procedures to review audit logs of production DB2
           servers.
34.        Implement an oversight process to ensure that designated Fiscal Service
           personnel: a. Review the security logs for the UNIX and DB2 servers hosting
           the Payment Information Repository (PIR), Judgment Fund Internet Claim
           System (JFICS), and Security Payment System (SPS) applications on a
           predefined frequency, as indicated in the Fiscal Service Baseline Security
           Requirements. b. Formally document the completion of their reviews and
           any escalations to the Information System Security Office, and c. Retain the
           audit logs and documentation of their reviews for 18 months, as required by
           the Baseline Security Requirements.
35.        Periodically review Fiscal Service management's implementation and
           operation of the review of the security audit logs for the UNIX and DB2
           servers hosting the PIR, JFICS, and SPS 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.
36.        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.
37.        Update its current PIR security procedures to require that management
           obtain current PIR developer access requirement listings from the service
           provider and use them when validating the appropriateness of PIR developer
           access during the semiannual access reviews and recertification of the PIR
           and UNIX environments.



      Treasury Office of Inspector General Semiannual Report—September 2023     39
                                                                     Statistical Summary

38.        Maintain the documentation used to review and recertify the access of the
           known PIR service provider developers evidencing that their access to the
           UNIX environments is commensurate with their job functions and
           responsibilities.
39.        Ensure that developers do not have the ability to make changes to the PIR
           production environment.
40.        Remove users' access once validated by the Federal Program Agency during
           the SPS annual user access review.
41.        Retain evidence of recertification of all users.


42.        Oversee the recertification process and ensure that access corrections are
           processed once received from the Federal Program Agency.
43.        Remove and disable the two users' access immediately.


44.        Implement a quality control process to ensure that PIR application accounts
           defined to the PIR production environment that have been inactive for over
           120 days are disabled.
45.        Develop and implement documentation to assign responsibility for ensuring
           adequacy of UNIX and database security and baseline settings.
46.        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 STIG.
           Management should document any deviations from the STIG and note
           compensating controls that mitigate the security risk to an acceptable level.
47.        Develop, document, and implement policies, procedures, and controls to
           conduct periodic reviews of actual UNIX and database settings against the
           security configuration baselines.
48.        Provide logging and monitoring of security-related events to include the
           retention of evidence of reviews performed.
49.        Develop a baseline of essential security settings and specify that baseline as
           the standard to be observed.
50.        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.




      Treasury Office of Inspector General Semiannual Report—September 2023     40
                                                                        Statistical Summary

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.
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.            Treasury's Assistant Secretary for Management should ensure that the
              Office of the Deputy Assistant Secretary for Human Resources and Chief
              Human Capital Officer (DASHR/CHCO) and the Office of Executive
              Resources (OER) develop, implement, and include effective internal controls
              within its policies and standard operating procedures (SOP) to ensure
              Treasury's Senior Executive Service (SES) basic pay rates are in compliance
              with 5 CFR 534.403(a)(3)(b), Suspension of certification of performance
              appraisal system and 5 CFR 534.404 (h)(2), Setting pay upon transfer.
2.            DASHR/CHCO and OER calculate the overpayment amounts for the two
              Departmental Office (DO) SES members whose pay was set higher than
              allowed by regulation.
3.            DASHR/CHCO and OER complete Office of Personnel Management (OPM)
              data calls in accordance with OPM's applicable instructions and guidance to
              ensure all required employees, such as those who have left Treasury, are
              properly reported.
4.            DASHR/CHCO finalizes and approves Treasury's SES Pay and Awards
              policy, and then periodically reviews it for continued relevance,
              effectiveness, and transparency in making pay decisions and awarding
              bonuses, assesses staffing levels, workforce skills, and respective budgets
              to determine whether additional personnel should and can plausibly be

         Treasury Office of Inspector General Semiannual Report—September 2023     41
                                                                    Statistical Summary

          incorporated into future strategic planning to ensure OER can meet its goals
          and mission.
5.        DASHR/CHCO finalizes and approves Treasury's SES Pay and Awards
          policy, and then periodically reviews it for continued relevance,
          effectiveness, and transparency in making pay decisions and awarding
          bonuses.
6.        OER documents the processes and SOP, with appropriate detail, followed in
          administering Treasury DO SES member performance ratings, pay
          adjustments, and bonuses.
7.        OER oversees the process regarding exceptions to the 12-month rule.
8.        OER includes information regarding the approval process for waiver requests
          for exceptions to the 12-month rule in the instructions provided to bureau
          heads and DO policy offices. This information should be consistent with
          Federal regulations and Treasury's SES Pay and Awards policy.
9.        OER submits Treasury's respective data call report to OPM by the due dates
          established by 5 CFR 534.405, Performance awards, and before any
          established deadlines per OPM's annual data call memorandum.
          Management agreed with the recommendations.




     Treasury Office of Inspector General Semiannual Report—September 2023     42
                                                                        Statistical Summary

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 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

         Treasury Office of Inspector General Semiannual Report—September 2023     43
                                                                    Statistical Summary

          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—September 2023     44
                                                                     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 complete its periodic review of the PIR
           user access within the annual timeframe in accordance with the PIR System
           Security Plan (SSP).
2.         Address resource constraints and prioritize efforts to perform reviews
           within the annual timeframe in accordance with the PIR SSP.
3.         Retain evidence to demonstrate PIR auditable events are reviewed timely in
           accordance with policy and procedures.
4.         Consider resource constraints and prioritize efforts to perform timely audit
           logging reviews in accordance with policy and procedures.
5.         Review the current population of JFICS accounts and disable application
           user access that has been inactive for greater than 120 days.
6.         Design and implement a control to automatically disable the JFICS
           application user accounts after 120 days of inactivity.
7.         Retain evidence to demonstrate that access is disabled in a timely manner
           in accordance with the JFICS SSP.
8.         Perform a review of the current system environment against the
           Configuration Management Database to ensure that all information system
           components are inventoried.
9.         Perform a risk assessment over the subject matter and determine the
           appropriate personnel to be responsible for monitoring and updating the
           Configuration Management Database.
10.        Update policy and procedures related to the above recommendations and
           disseminate the documentation to enforce such policy and procedures.
11.        Conduct a review of the UNIX Mid-Tier production servers to validate that
           backups are scheduled for all servers based on the frequency defined in the
           Enterprise Information Technology Infrastructure SSP for the full fiscal year.
12.        Perform a risk assessment over the subject matter and determine the
           appropriate personnel to be responsible for developing a Plan of Action &
           Milestones or formal risk acceptance for vulnerabilities identified.


      Treasury Office of Inspector General Semiannual Report—September 2023     45
                                                                      Statistical Summary

13.         Disseminate policy and procedures related to the use of a Plan of Action &
            Milestones or formal risk acceptance to the appropriate personnel
            determined above to enforce the respective vulnerability management
            requirements. 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
2021        OIG-21-028            FINANCIAL MANAGEMENT: Audit of             05/21
                                  Treasury's Compliance With the PIIA
                                  Requirements for Fiscal Year 2020
1.          Treasury’s Risk and Control Group (RCG) should work with Fiscal Service
            and Mint management to revise its controls over the review and approval
            process to verify the quantitative risk assessment includes sufficient
            supporting documentation to substantiate Fiscal Service's improper
            payment amount derived from its non-statistical sampling methodology.
            Management agreed with the recommendation.
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)
1-2.        These recommendations are Sensitive But Unclassified. Management agreed
            with the recommendations.




       Treasury Office of Inspector General Semiannual Report—September 2023     46
                                                                      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-22-012            FINANCIAL MANAGEMENT: Audit of              11/21
                                  the Department of the Treasury's
                                  Consolidated Financial Statements for
                                  Fiscal Years 2021 and 2020
1.          The Acting Assistant Secretary for Management and Acting Chief Financial
            Officer should ensure that Fiscal Service implements requisite corrective
            actions to resolve control deficiencies over its cash management and debt
            information systems. Separate reports with additional details and
            recommendations for corrective action were provided to Fiscal Service
            management.
2.          Ensure that the Internal Revenue Service (IRS) implements corrective
            actions to resolve the control deficiencies at IRS. A separate report was
            provided to IRS management detailing the conditions identified and
            recommendations to address the significant deficiency.
3.          Ensure that the IRS and the Fiscal Service develop and implement
            remediation plans outlining actions to be taken to resolve noncompliance

       Treasury Office of Inspector General Semiannual Report—September 2023     47
                                                                    Statistical Summary

          with the federal financial management system requirements and the
          resources and responsible organizational units for such planned actions.
          Separate reporting with recommendations was provided to IRS and Fiscal
          Service management to address the noncompliance with the Federal
          financial management system requirements. Management agreed with the
          recommendations.
Fiscal    Report Number         Report Title                              Date Issued
Year
2022      OIG-22-014            FINANCIAL MANAGEMENT:                    12/21
                                Management Letter for the Audit of the
                                Department of the Treasury's
                                Consolidated Financial Statements for
                                Fiscal Years 2021 and 2020
1.        DO management should assist management in mitigating the risk of
          potential inaccurate reporting and noncompliance with public laws,
          management should complete a full review of all Treasury Account
          Symbols, compare all attributes to the Federal Account Symbols and Titles
          book, and create policies and procedures to adequately document the
          review of new Treasury Account Symbols. Management agreed with the
          recommendation.
Fiscal    Report Number         Report Title                             Date Issued
Year
2022      OIG-22-015           FINANCIAL MANAGEMENT: Audit of               12/21
                               the Office of D.C Pensions' Financial
                               Statements for Fiscal Years 2021 and
                               2020
1.        Office of D.C. Pensions management should enhance existing policies and
          procedures to document a process for reviewing, investigating, and
          resolving unusual or suspicious activity identified during the audit log
          review, as well as maintaining evidence of such review, investigation and
          resolution. Management agreed with the recommendation.
Fiscal    Report Number        Report Title                                 Date Issued
Year
2022      OIG-22-028          CORONAVIRUS DISEASE 2019                   03/22
                              PANDEMIC RELIEF PROGRAMS: Audit
                              of Treasury's Implementation of the
                              Emergency Capital Investment Program
1.        The Deputy Assistant Secretary should ensure the Interim Director of the
          Emergency Capital Investment Program finalizes policies and procedures

     Treasury Office of Inspector General Semiannual Report—September 2023     48
                                                                    Statistical Summary

          and key documentation to govern full program implementation and ongoing
          administration of Emergency Capital Investment Program investments, as
          well as effective internal control over the program. Management agreed
          with the recommendation.
Fiscal    Report Number         Report Title                            Date Issued
Year
2022      OIG-22-031             RESOURCE MANAGEMENT: Audit of            03/22
                                 the Department of the Treasury's Use of
                                 Cash Discounts ($42,563 Funds Put to
                                 Better Use)
1.        The Director of the Financial Crimes Enforcement Network (FinCEN) ensures
          that FinCEN develops, revises, and/or finalizes SOPs for taking cash
          discounts to ensure the process is adequately revised and documented to
          take full advantage of cash discounts when offered, and when applicable,
          as required by Section 2060 of the Treasury Financial Manual (TFM).
          ($41,426, Funds Put to Better Use)
2.        Maintains adequate controls on internal processes related to payment
          approvals.
3.        Ensures that Contracting Officer Representatives (CORs) approve invoices
          with discounts timely.
4.        Participates in required training, as necessary.
5.        Distributes SOPs and/guidance relating to cash discounts to FinCEN's
          management, staff, Contracting Officer's, and COR, including provide
          training, as necessary.
6.        The Director of the Comptroller of the Currency ensures that Office of the
          Comptroller of the Currency (OCC) develops, revises, and/or finalizes SOPs
          for taking full advantage of cash discounts when offered and applicable, as
          required by Section 2060 of the TFM. ($1,137, Funds Put to Better Use)
7.        Maintains adequate controls on internal processes related to payment
          approvals.
8.        Ensures that CORs approve invoices with discounts timely.
9.        Distributes SOPs and/or guidance relating to cash discounts to OCC
          management, staff, Contract Officers, and CORs and provide training, as
          necessary. Management agreed with the recommendations.




     Treasury Office of Inspector General Semiannual Report—September 2023     49
                                                                    Statistical Summary

Fiscal    Report Number          Report Title                                Date Issued
Year
2022      OIG-22-035            FINANCIAL MANAGEMENT: Audit of              06/22
                                Treasury's Compliance With the PIIA
                                Requirements for Fiscal Year 2021
1.        Treasury's RCG work with management at the Fiscal Service, Exchange
          Stabilization Fund, and Office of the Assistant Secretary for International
          Affairs to complete proper review of the program-specific risk assessments
          to better ensure management responses to risk assessment questions are
          accurate.
2.        Treasury's RCG perform sufficient review of the annual Office of
          Management and Budget (OMB) data call to ensure the information
          published on PaymentAccuracy.gov are complete and accurate.
          Management agreed with the recommendations.
Fiscal    Report Number         Report Title                                Date Issued
Year
ADX       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.        These recommendations are Sensitive But Unclassified. Management agreed
          with the recommendation.
Fiscal    Report Number     Report Title                              Date Issued
Year
2023      OIG-23-007            FINANCIAL MANAGEMENT: Audit of            11/22
                                the Department of the Treasury's
                                Consolidated Financial Statements for
                                Fiscal Years 2022 and 2021
1.        The Acting Assistant Secretary for Management and Deputy Chief Financial
          Officer ensure that IRS and Fiscal Service develop and implement
          remediation plans outlining actions to be taken to resolve noncompliance
          with the federal financial management system requirements and the
          resources and responsible organizational units for such planned actions.
2.        Ensure that IRS implements corrective actions to resolve the control
          deficiencies at IRS.




     Treasury Office of Inspector General Semiannual Report—September 2023     50
                                                                    Statistical Summary

3.        Ensure that Fiscal Service implements requisite corrective actions to resolve
          control deficiencies over its cash management systems. Management
          agreed with the recommendations.
Fiscal    Report Number         Report Title                               Date Issued
Year
2023      OIG-23-009            FINANCIAL MANAGEMENT:                     12/22
                                Management Letter for the Audit of the
                                Department of the Treasury's
                                Consolidated Financial Statements for
                                Fiscal Years 2022 and 2021
1.        To assist DO management in mitigating the risk of potential inaccurate
          reporting and noncompliance with public laws, management enforce full
          review of all Treasury Information Executive Repository fund symbol
          following the SOP and update procedures to adequately document the
          review of new Treasury Information Executive Repository fund symbol.
2.        Office of Recovery Programs (ORP) management determine the recipient
          monitoring resources needed to perform a timely review of the Projects and
          Expenditures report submission to align with financial statement reporting
          deadlines.
3.        Design and implement policies and procedures that require certain manual
          journal entries are reviewed by ORP management prior to Administrative
          Resource Center (ARC) posting the journal entry or that journal entries
          posted by ARC are reviewed by ORP management on a timely basis.
4.        Management annually, identify and ensure that the relevant complementary
          customer agency controls listed in The Report on the Bureau of the Fiscal
          Service's Description of its Administrative Resource Center Shared Service
          System and the Suitability of the Design and Operating Effectiveness of its
          Controls are considered in the design and implementation of controls at
          ORP. Management agreed with the recommendations.
Fiscal    Report Number         Report Title                              Date Issued
Year
2023      OIG-23-012           FINANCIAL MANAGEMENT: Audit of               12/22
                               the Office of D.C. Pensions' Financial
                               Statements for Fiscal Years 2022 and
                               2021
1.        Office of D.C. Pensions' management should enhance existing policies and
          procedures to document a process for reviewing, investigating, and
          resolving unusual or suspicious activity identified during the audit log



     Treasury Office of Inspector General Semiannual Report—September 2023     51
                                                                    Statistical Summary

          review, as well as maintaining evidence of such review, investigation and
          resolution. Management agreed with the recommendation.
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
          PSP1 financial assistance. The amount is sensitive information.
2.        Review Wings Air Helicopters' 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-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
          capture of necessary information and to ensure consistency of data
          collected.
2.        Mint leadership should 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.        Mint leadership should 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

     Treasury Office of Inspector General Semiannual Report—September 2023      52
                                                                    Statistical Summary

          conducting surveys and/or other forms of outreach among the workforce as
          it pertains to the complaint process. Management agreed with the
          recommendations.

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



     Treasury Office of Inspector General Semiannual Report—September 2023     53
                                                                     Statistical Summary

           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.
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 and TTO officials require ACE training related to the oversight of
           in-bond cargo for all CBP officers.
14.        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.
15.        Ensure the Commercial Operations Revenue & Entry Division provides
           general bond training to include setting the appropriate bond amounts.
           Management agreed with the recommendations.




      Treasury Office of Inspector General Semiannual Report—September 2023     54
                                                                      Statistical Summary


Closed Investigations of Senior Government Employees Not
Publicly Disclosed
April 1, 2023, through September 30, 2023

Treasury OIG closed 1 investigation involving senior Government employees during the
period that was not publicly disclosed and it was unsubstantiated.

Allegation/Disposition

On June 7, 2023, the OIG completed its report of investigation for a case initiated
upon notification that two senior employees of the Office of the Comptroller of the
Currency (OCC) undermined the OCC computer security phishing program by notifying
employees under their supervision that it was in progress. The complaint was
discussed with the OIG, Office of Chief Counsel and the determination was made that
an administrative violation was not committed by either of the employees. The OIG
provided a report to the OCC for its information. This matter was unsubstantiated and
not referred to the Department of Justice. Unsubstantiated



Trafficking Victims Prevention and Protection Reauthorization
Act of 2022
April 1, 2023, through September 30, 2023

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
April 1, 2023, through September 30, 2023

There were no new cases of possible whistleblower retaliation opened during this
reporting period. As such, there were no established cases of whistleblower retaliation
to report for the period.

      Treasury Office of Inspector General Semiannual Report—September 2023      55
                                                                     Statistical Summary




Summary of Attempts to Interfere With Treasury OIG
Independence, Including Instances Where Information or
Assistance Request was Refused
April 1, 2023, through September 30, 2023

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—September 2023     56
                                                                     Statistical Summary



Listing of Audit Products Issued
April 1, 2023, through September 30, 2023

Office of Audit

                   Report Title                                   Report Number
                                                April 2023
 CORONAVIRUS DISEASE 2019 PANDEMIC RELIEF                           OIG-23-024
  PROGRAMS: Audit of Air Carrier Worker Support
      Certifications - Constant Aviation, LLC

                                                May 2023
  Overseas Contingency Operations - Summary of                    OIG-CA-23-017
 Work Performed by the Department of the Treasury
   Related to Terrorist Financing and Anti-Money
  Laundering for Second Quarter Fiscal Year 2023

FINANCIAL MANAGEMENT: Audit of the Gulf Coast                       OIG-23-025
 Ecosystem Restoration Council's Compliance With
        PIIA of 2019 for Fiscal Year 2022

 FINANCIAL MANAGEMENT: Audit of Treasury’s                          OIG-23-026
 Compliance With the PIIA Requirements for Fiscal
                   Year 2022

                                                June 2023
 CORONAVIRUS DISEASE 2019 PANDEMIC RELIEF                           OIG-23-027
  PROGRAMS: Audit of Air Carrier Worker Support
   Certifications - Paradigm Jet Management, Inc.

 CORONAVIRUS DISEASE 2019 PANDEMIC RELIEF                           OIG-23-028
  PROGRAMS: Audit of Air Carrier Worker Support
 Certifications - Ground Services International, Inc.

 CORONAVIRUS DISEASE 2019 PANDEMIC RELIEF                           OIG-23-029
  PROGRAMS: Audit of Air Carrier Worker Support
      Certifications - Bird Acquisition, LLC

   Desk Review of Chippewa Cree Tribe’s Use of                    OIG-CA-23-018
         Coronavirus Relief Fund Proceeds




      Treasury Office of Inspector General Semiannual Report—September 2023       57
                                                                     Statistical Summary

Desk Review of State of Illinois’ Use of Coronavirus              OIG-CA-23-019
              Relief Fund Proceeds

Desk Review of The Cherokee Nation, Oklahoma’s                    OIG-CA-23-020
    Use of Coronavirus Relief Fund Proceeds

      Desk Review of New York City’s Use of                       OIG-CA-23-021
         Coronavirus Relief Fund Proceeds

System Review Report - Department of the Interior,                OIG-CA-23-023
           Office of Inspector General

Letter of Comment - Department of the Interior, OIG               OIG-CA-23-024


 Desk Review of Lancaster County, Pennsylvania’s                  OIG-CA-23-024
     Use of Coronavirus Relief Fund Proceeds

                                                July 2023
    Desk Review of State of California’s Use of                   OIG-CA-23-025
        Coronavirus Relief Fund Proceeds

Desk Review of Turtle Mountain Band of Chippewa                   OIG-CA-23-026
 Indians’ Use of Coronavirus Relief Fund Proceeds

 Desk Review of Los Angeles County, California’s                  OIG-CA-23-027
    Use of Coronavirus Relief Fund Proceeds

   Desk Review of City of Dallas, Texas’s Use of                  OIG-CA-23-028
         Coronavirus Relief Fund Proceeds

     Desk Review of State of Florida’s Use of                     OIG-CA-23-029
        Coronavirus Relief Fund Proceeds

Desk Review of San Bernardino County, California’s                OIG-CA-23-030
     Use of Coronavirus Relief Fund Proceeds

  Joint Purchase and Integrated Card Violations                   OIG-CA-23-031
Report (October 1, 2022, through March 31, 2023)
             - Internal Memorandum

    Desk Review of Phoenix, Arizona’s Use of                      OIG-CA-23-032
        Coronavirus Relief Fund Proceeds

 Desk Review of Pleasant Point Indian Reservation,                OIG-CA-23-033
 Maine’s Use of Coronavirus Relief Fund Proceeds




      Treasury Office of Inspector General Semiannual Report—September 2023       58
                                                                     Statistical Summary

Desk Review of State of Texas’ Use of Coronavirus                 OIG-CA-23-034
              Relief Fund Proceeds

 Desk Review of the State of Tennessee’s Use of                   OIG-CA-23-035
       Coronavirus Relief Fund Proceeds

CYBERSECURITY/INFORMATION TECHNOLOGY:                             OIG-CA-23-036
 The Gulf Coast Ecosystem Restoration Council
Federal Information Security Modernization Act of
  2014 Evaluation Report for Fiscal Year 2023

Desk Review of State of Ohio’s Use of Coronavirus                 OIG-CA-23-037
             Relief Fund Proceeds

Desk Review of Native Village of Point Hope’s Use                 OIG-CA-23-038
      of Coronavirus Relief Fund Proceeds

                                             August 2023
Desk Review of the Commonwealth of the Northern                   OIG-CA-23-039
  Mariana Islands Use of Coronavirus Relief Fund
                    Proceeds

   Desk Review of the Commonwealth of Puerto                      OIG-CA-23-040
  Rico’s Use of Coronavirus Relief Fund Proceeds

Desk Review of Navajo Nation Tribal Government’s                  OIG-CA-23-041
     Use of Coronavirus Relief Fund Proceeds

 Desk Review of the Commonwealth of Virginia’s                    OIG-CA-23-042
    Use of Coronavirus Relief Fund Proceeds

 Overseas Contingency Operations - Summary of                     OIG-CA-23-043
Work Performed by the Department of the Treasury
  Related to Terrorist Financing and Anti-Money
Laundering for the Third Quarter Fiscal Year 2023

 Emergency Rental Assistance (ERA) Action Team                    OIG-CA-23-044
 ERA Complaint Review and Disposition Standard
  Operating Procedures - Internal Memorandum

 Emergency Rental Assistance (ERA) Action Team                    OIG-CA-23-045
   ERA Complaint Processing and Distribution
    Standard Operating Procedures - Internal
                 Memorandum

 Emergency Rental Assistance (ERA) Action Team                    OIG-CA-23-046
  Procedures for Analyzing and Advising on ERA
  Program Single Audit Priority Findings - Internal
                  Memorandum



      Treasury Office of Inspector General Semiannual Report—September 2023       59
                                                                     Statistical Summary

     ANTI-MONEY LAUNDERING/TERRORIST                                OIG-23-030
FINANCING: Audit of FinCEN's Management of BSA
           Data - Suppression Report

                                           September 2023
 Plan to Establish a Data Literacy Program for the                OIG-CA-23-047
  Department of the Treasury Office of Inspector
                      General

Interim Audit Update ─ Audit of American Samoa’s                    OIG-23-031
      Uses of Coronavirus Relief Fund Payment

CORONAVIRUS DISEASE 2019 PANDEMIC RELIEF                            OIG-23-032
PROGRAMS: Audit of the Community Development
Financial Institutions Fund’s Award and Post-Award
Administration of the CDFI Rapid Response Program

CORONAVIRUS DISEASE 2019 PANDEMIC RELIEF                            OIG-23-033
PROGRAMS: Audit of the Community Development
Financial Institutions Fund's Implementation of the
         CDFI Equitable Recovery Program

    FINANCIAL MANAGEMENT: Report on the                             OIG-23-034
     Enterprise Applications’ Description of its
HRConnect System and the Suitability of the Design
 and Operating Effectiveness of its Controls for the
      Period July 1, 2022 to June 30, 2023

 CYBERSECURITY/INFORMATION TECHNOLOGY:                              OIG-23-035
 Fiscal Year 2021 Audit of the Department of the
   Treasury's Information Security Program and
Practices for Its Intelligence Systems (CLASSIFIED,
            NOT PUBLICLY DISCLOSED

 CYBERSECURITY/INFORMATION TECHNOLOGY:                              OIG-23-036
 Fiscal Year 2022 Audit of the Department of the
   Treasury's Information Security Program and
Practices for Its Intelligence Systems (CLASSIFIED,
            NOT PUBLICLY DISCLOSED)

 FINANCIAL MANAGEMENT: Report on the Bureau                         OIG-23-037
      of the Fiscal Service’s Description of its
  Administrative Resource Center Shared Services
    System and the Suitability of the Design and
   Operating Effectiveness of its Controls for the
      Period July 1, 2022, to June 30, 2023




      Treasury Office of Inspector General Semiannual Report—September 2023       60
                                                                     Statistical Summary

Council of Inspectors General on Financial Oversight

                   Report Title                                   Report Number
                                                July 2023
 Annual Report of the Council of Inspectors General              No Report Number
        on Financial Oversight (July 2023)

                                               August 2023
 Audit of the Financial Stability Oversight Council's            CIGFO-2023-001
 Efforts to Address Climate-Related Financial Risk




      Treasury Office of Inspector General Semiannual Report—September 2023         61
                                                                                    Statistical Summary



Audit Reports Issued With Questioned Costs
April 1, 2023, through September 30, 2023

                                                           Total No.      Total                 Total
                                                           of             Questioned            Unsupported
Category                                                   Reports        Costs                 Costs
For which no management decision had been made by
beginning of reporting period                                        4           $1,133,408                      $0
Which were issued during the reporting period                      22        $2,239,122,323                      $0
  Subtotals                                                        26        $2,240,255,731                      $0
For which a management decision was made during the
reporting period                                                     3           $1,105,256                      $0
  Dollar value of disallowed costs                                   3           $1,105,256                      $0
  Dollar value of costs not disallowed                               0                     $0                    $0
For which no management decision was made by the
end of the reporting period                                        23        $2,239,150,475                      $0
For which no management decision was made within 6
months of issuance                                                   1               $28,152                     $0
Questioned costs include expenditures: (1) that are questioned because of an alleged violation of a provision of a
law, regulation, contract, or other requirement governing the expenditure of funds; (2) that, at the time of the
audit, are not supported by adequate documentation (i.e., unsupported costs); or (3) used for the intended
purpose that are unnecessary or unreasonable.




       Treasury Office of Inspector General Semiannual Report—September 2023                           62
                                                                                      Statistical Summary



Audit Reports Issued With Recommendations that Funds Be Put
to Better Use
April 1, 2023, through September 30, 2023

                                                   Total
                                                   No. of                                          Revenue
    Category                                       Reports         Total           Savings         Enhancement
    For which no management decision had been
    made by beginning of reporting period                           1      $50,837               $0                  $0
    Which were issued during the reporting
    period                                                          0           $0               $0                  $0
      Subtotals                                                     1      $50,837               $0                  $0
    For which a management decision was made
    during the reporting period                                   14        $8,274               $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       $8,274               $0                  $0
    For which no management decision was
    made by the end of the reporting period                         1      $42,563               $0                  $0
    For which no management decision was
    made within 6 months of issuance                                1      $42,563               $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.




4
     There was a management decision on 1of 3 recommendations with funds put to better use, for
     report, Treasury OIG, RESOURCE MANAGEMENT: Audit of the Department of the Treasury’s Use of
     Cash Discounts, OIG-22-031 (March 23, 2022).

           Treasury Office of Inspector General Semiannual Report—September 2023                        63
                                                                      Statistical Summary



Reports for Which No Management Comment Was Returned
Within 60 Days
As of September 30, 2023

There were no 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 September 30, 2023

As of the end of this semiannual reporting period, Treasury management had not
decided on recommendations with monetary benefits for 2 reports issued over 6
months:

   •   RESOURCE MANAGEMENT: Audit of the Department of the Treasury’s Use of Cash
       Discounts (OIG-22-031, 03/23/2022) $42,563 Funds Put to Better Use
   •   CORONAVIRUS DISEASE 2019 PANDEMIC RELIEF PROGRAMS: Audit of Air
       Carrier Worker Support Certifications - Wings Air Helicopters, LLC (Redacted) (OIG-
       23-023, 03/31/2023) $28,152 Questioned Costs




Significant Revised Management Decisions
April 1, 2023, through September 30, 2023

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




       Treasury Office of Inspector General Semiannual Report—September 2023     64
                                                                     Statistical Summary


Significant Disagreed Management Decisions
April 1, 2023, through September 30, 2023

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



Peer Reviews
April 1, 2023, through September 30, 2023

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 three 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.

On June 27, 2023, Treasury OIG rendered a Pass rating to the Department of Interior
OIG for its system of quality control in effect for the year ended September 30, 2022.

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 three
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.



      Treasury Office of Inspector General Semiannual Report—September 2023     65
                                                                     Statistical Summary

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.

On June 6, 2023, Treasury OIG rendered a compliant rating to the Small Business
Administration OIG.




      Treasury Office of Inspector General Semiannual Report—September 2023     66
Other Reporting Requirements and Requests
This section addresses certain reporting requirements of our office that are separate
from the reporting requirements in the Inspector General Act of 1978 (as amended).

      Reviews of Bank Failures With Nonmaterial Losses

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

      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 or the Department) activities with
      respect to disrupting the Islamic State of Iraq and Syria’s (ISIS) finances. The
      memorandums included specific examples of activities to disrupt ISIS’s
      financing, information on Treasury programs that combat terrorist financing, and



      Treasury Office of Inspector General Semiannual Report—September 2023    67
                                Other Reporting Requirements and Requests

work we performed or plan to perform to review these programs.
(OIG-CA-23-017, OIG-CA-23-043)




Treasury Office of Inspector General Semiannual Report—September 2023   68
References to the Inspector General Act
    Section                                            Requirement                                              Page
Section 404(a)(2)   Review of legislation and regulations                                                            32
Section 405(b)(1)   Significant problems, abuses, and deficiencies                                                 5-30
Section 405(b)(2)   Recommendations with respect to significant problems, abuses, and deficiencies                 5-30

Section 405(b)(3)   Significant unimplemented recommendations described in previous semiannual                    33-54
                    reports
Section 405(b)(4)   Matters referred to prosecutive authorities                                                      32
Section 406(c)(2)   Summary of instances where information was refused                                               56
Section 405(b)(6)   List of audit reports                                                                         57-61
Section 405(b)(7)   Summary of significant reports                                                                 5-30
Section 405(b)(8)   Audit reports with questioned costs                                                              62
Section 405(b)(9)   Recommendations that funds be put to better use                                                  63
Section             Summary of each audit, inspection, and evaluation report issued before the                    33-54
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                       64
405(b)(10)(B)       management comment was returned within 60 days
Section             Summary of each audit, inspection, and evaluation report issued before the                         64
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                          64
405(b)(11)
Section             Management decisions with which the Inspector General is in disagreement                           65
405(b)(12)
Section             Instances of unresolved Federal Financial Management Improvement Act                               23
405(b)(13)          noncompliance
Section             Results of peer reviews conducted of Treasury OIG by another OIG                              65-66
405(b)(14)
Section             List of outstanding recommendations from peer reviews                                         65-66
405(b)(15)
Section             List of peer reviews conducted by Treasury OIG, including a list of outstanding               65-66
405(b)(16)          recommendations from those peer reviews
Section             Statistics for the period related to the number of (A) investigative reports issued,               32
405(b)(17)(A-D)     (B) persons referred to the Department of Justice for criminal prosecution,
                    (C) persons referred to state and local authorities for criminal prosecution, and
                    (D) criminal indictments/informations
Section             Description of metrics used to develop investigative statistics in Section 5(a)(17)                32
405(b)(18)
Section             Summary of each investigation involving a senior Government employee where                         55
405(b)(19)          allegation of misconduct was substantiated
Section             Instances of whistleblower retaliation                                                             56
405(b)(20)
Section             Summary of attempts to interfere with Treasury OIG independence                                    56
405(b)(21)
Section             Description of each inspection, evaluation, and audit that was closed and not                 57-61
405(b)(22)(A)       publicly disclosed
Section             Description of each investigation closed, involving a senior Government employee,                  55
405(b)(22)(B)       that was not publicly disclosed


      Treasury Office of Inspector General Semiannual Report—September 2023                                69
                                                   References to the Inspector General Act

Section 405(e)      Serious or flagrant problems, abuses, or deficiencies                             N/A
Section 406(c)(2)   Report to Secretary when information or assistance is unreasonably refused         56




       Treasury Office of Inspector General Semiannual Report—September 2023                     70
Abbreviations
ACE                                        Automated Commercial Environment
ARP                                        American Rescue Plan Act of 2021
ASG                                        American Samoa Government
BEP                                        Bureau of Engraving and Printing
BSA                                        Bank Secrecy Act
CAA, 2021                                  Consolidated Appropriations Act, 2021
CARES Act                                  Coronavirus Aid, Relief, and Economic Security
                                           Act
Castro                                     Castro & Company, LLC
CBP                                        U.S. Customs and Border Protection
CDFI                                       Community Development Financial Intuitions
CIGFO                                      Council of Inspectors General on Financial
                                           Oversight
CIGIE                                      Council of the Inspectors General on Integrity
                                           and Efficiency
Council                                    Gulf Coast Ecosystem Restoration Council
COR                                        Contracting Officer Representative
COVID-19                                   Coronavirus Disease 2019
CRF                                        Coronavirus Relief Fund
CSC                                        Cargo Security and Controls Division
DASHR/CHCO                                 Office of the Deputy Assistant Secretary for
                                           Human Resources and Chief Human Capital
                                           Officer
DATA Act                                   Digital Accountability and Transparency Act
DO                                         Departmental Offices
Dodd-Frank                                 Dodd-Frank Wall Street Reform and Consumer
                                           Protection Act of 2010
DIF                                        Deposit Insurance Fund
ERA                                        Emergency Rental Assistance
ERP                                        Equitable Recovery Program
FinCEN                                     Financial Crimes Enforcement Network
Fiscal Service                             Bureau of the Fiscal Service
FISMA                                      Federal Information Security Modernization Act
                                           of 2014
FPR                                        Financial Progress Reports
FSOC                                       Financial Stability Oversight Council
GAO                                        Government Accountability Office
Green Book                                 Standards for Internal Control in the Federal
                                           Government

        Treasury Office of Inspector General Semiannual Report—September 2020   71
                                                                             Abbreviations

GSI                                     Ground Services International, Inc.
IRS                                     Internal Revenue Service
JFICS                                   Judgment Fund Internet Claim System
KPMG                                    KPMG LLP
Mint                                    United States Mint
OCC                                     Office of the Comptroller of the Currency
OER                                     Office of Executive Resources
OFAC                                    Office of Foreign Assets Control
OIG                                     Office of Inspector General
OMB                                     Office of Management and Budget
OPM                                     Office of Personnel Management
ORP                                     Office of Recovery Programs
PIIA                                    Payment Integrity Information Act of 2019
PIR                                     Payment Information Repository
PSP1                                    Payroll Support Program
PSP2                                    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
RCG                                     Risk and Control Group
RMA                                     RMA Associates, LLC
RRP                                     Rapid Response Program
SBLF                                    Small Business Lending Fund
SES                                     Senior Executive Service
SPS                                     Security Payment System
SOP                                     standard operating procedures
S&R                                     Saggar & Rosenberg, P.C.
SSP                                     System Security Plan
STIG                                    Security Technical Implementation Guide
TIGTA                                   Treasury Inspector General for Tax
                                        Administration
TFM                                     Treasury Financial Manual
TMBCI                                   Turtle Mountain Band of Chippewa Indians’
Treasury                                Department of the Treasury
TTO                                     Trade Transformation Office
Uniform Guidance                        Uniform Administrative Requirements, Cost
                                        Principles, and Audit Requirements for Federal



     Treasury Office of Inspector General Semiannual Report—September 2023        72
                                                                              Abbreviations

                                         Awards, 2 Code of Federal Regulations Part
                                         200
USAO                                     U.S. Attorney’s Office
Wings Air Helicopters                    Wings Air Helicopters, LLC.




      Treasury Office of Inspector General Semiannual Report—September 2023        73
              Treasury Office of Inspector General Locations
                           1500 Pennsylvania Avenue, N.W., Room 4436
                                     Washington, DC 20220
                                  875 15th Street, N.W., Suite 200
                                      Washington, DC 20005




                             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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