Treasury OIG: Semiannual Report to Congress, April 1, 2024 – September 30, 2024
Summary
This Treasury Office of Inspector General semiannual report says the Office of Audit issued 35 products and identified $992,965 in questioned costs, and that work by the Office of Investigations resulted in 15 indictments and 13 convictions. Desk reviews of Emergency Rental Assistance (ERA) funds found $386,077 in total questioned costs for governments including Houston, Texas and the State of Michigan. An accounting firm found $438,465 in questioned costs in Air Carrier Payroll Support Program (PSP1) awards to Wing Aviation Charter Services, LLC and Superior Transportation Associates, Inc. Two contractors agreed to pay $11.3 million in civil settlements over cybersecurity requirements in New York's ERAP contract. Its page footers read both September 2023 and September 2024; the body cites a fiscal year 2024 appropriation of $48.3 million.
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Cite this document
“Treasury OIG: Semiannual Report to Congress, April 1, 2024 – September 30, 2024.”
Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/semiannual-report-to-congress-sep-2024-31fc4c90d2/
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Highlights
During this semiannual reporting period, the Office of Audit issued 35 products. The office
also identified $992,965 in questioned costs. Work by the Office of Investigations resulted in
15 indictments and 13 convictions. Some of our more significant results for the period are
described below:
• Our Office of Audit performed desk reviews of the use of Emergency Rental Assistance
(ERA)1 and ERA2 funds for Houston, Texas and Harris County, Texas. In addition to
determining whether ERA recipients complied with the use of ERA fund requirements,
we also determined there were $386,077 in total questioned costs based on our desk
reviews and other information received for the following State and Local governments:
o Houston, Texas and Harris County, Texas
o State of Washington
o Thurston County, Washington
o State of Missouri
o State of Michigan
• A certified independent public accounting firm (IPA), 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 awards under the Air Carrier
Payroll Support Program (PSP1) for the following air carriers:
o Wing Aviation Charter Services, LLC
o Superior Transportation Associates, Inc.
o Flight Group Corporation
o Freight Runners Express, Inc.
o Prosegur Services Group, Inc.
o Prospect Airport Services, Inc.
o One Sky Flight, LLC
o Suburban Air Freight, Inc.
The IPA found Wing Aviation Charter Services, LLC, had $250,713 in questioned costs
and Superior Transportation Associates, Inc. had $187,752 in questioned costs,
resulting in a total of $438,465 in questioned costs.
• An investigation conducted by our Office of Investigations resulted in two contractors
agreeing to pay a total of $11.3 million in civil settlements for failing to abide by
requirements of New York's Emergency Rental Assistance Program (ERAP). The ERAP
contract required specific cybersecurity requirements, and the contractors admitted they
had failed to properly meet the requirements. The U.S. Attorney’s Office for the
Northern District of New York and the Department of Justice Civil Division negotiated
the settlement.
Treasury Office of Inspector General Semiannual Report—September 2023 i
Message from the Inspector General
During this reporting period, the Department of the Treasury (Treasury) Office of Inspector
General (OIG) continued its in-depth oversight of the pandemic recovery programs
administered by Treasury. We issued a total of 35 products during the reporting period, of
which 17 products were pandemic-related products.
As part of pandemic oversight, Treasury OIG performed desk reviews of the use of Emergency
Rental Assistance (ERA)1 and ERA2 funds. We determined multiple states were in violation of
ERA1 and ERA2 statutes. We found proof that an individual submitted fraudulent applications
to receive rental assistance funds. We also found overpayments due to assistance exceeding
the allowed 15 months, payments for ineligible expenses to beneficiaries who did not provide
adequate proof of identification or proof of residence in accordance with the grantees’
program policy, and a payment error.
Additionally, during this reporting period Treasury OIG performed an audit to determine if the
Financial Crimes Enforcement Network (FinCEN) managed Bank Secrecy Act (BSA) data
access, use, and retention in compliance with laws, regulations, and Treasury policies and
procedures. BSA data are useful for countering money laundering, illicit finance, and terrorism,
but the information is sensitive, and FinCEN must safeguard it against unauthorized release. In
this report, we identified five findings and made eight recommendations regarding this issue.
We plan to issue additional reports on BSA data safeguards in the next year.
Treasury OIG continues to provide leadership and administrative support to the Council of
Inspectors General on Financial Oversight, the organization established by the Dodd-Frank Wall
Street Reform and Consumer Protection Act to oversee and monitor the activities of the
Financial Stability Oversight Council, which is chaired by the Secretary of the Treasury.
Treasury OIG continues to investigate fraud, waste, and abuse of Treasury programs, to
include pandemic programs, employee misconduct, and various cyber-related fraud. Treasury
OIG participates in several law enforcement working groups and task forces to investigate
external fraud that affects Treasury.
This is the last semi-annual report to Congress I will issue. I have served in Treasury OIG for
25 years, the last 5 as Acting Inspector General. It has been an honor, and the highlight of my
federal career, to be associated with this organization and the outstanding professionals who
provide expert oversight of Treasury’s programs and operations.
Richard K. Delmar
Acting Inspector General
Treasury Office of Inspector General Semiannual Report—September 2024 ii
Contents
Contents
Highlights ......................................................................................... i
Message from the Inspector General .................................................... ii
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
Emergency Rental Assistance Oversight .................................................................. 11
Cyber/Information Technology ............................................................................... 14
Geospatial Data Act ............................................................................................. 17
Anti-Money Laundering/Terrorist Financing and Intelligence ....................................... 17
Manufacturing and Revenue .................................................................................. 19
Financial Management .......................................................................................... 20
Consolidated Appropriations Act, 2021 ................................................................... 22
Other Audits of Treasury Programs and Operations ................................................... 25
Office of Investigations – Significant Investigations ............................ 26
Treasury OIG Accomplishments and Activities ................................... 30
Statistical Summary ........................................................................ 31
Summary of Treasury OIG Activities ....................................................................... 31
Metrics Used for Office of Investigations Activities ................................................... 31
Reports with Unimplemented Recommendations ...................................................... 32
Closed Investigations of Senior Government Employees Not Publicly Disclosed ............ 52
Trafficking Victims Prevention and Protection Reauthorization Act of 2022 ................. 53
No-Knock Entry Reporting ..................................................................................... 53
Summary of Instances of Whistleblower Retaliation .................................................. 53
Summary of Attempts to Interfere With Treasury OIG Independence, Including Instances
Where Information or Assistance Request was Refused............................................. 54
Listing of Audit Products Issued ............................................................................. 55
Audit Reports Issued With Questioned Costs ........................................................... 60
Treasury Office of Inspector General Semiannual Report—September 2024 iii
Contents
Audit Reports Issued With Recommendations that Funds Be Put to Better Use ............. 61
Reports for Which No Management Comment was Returned Within 60 Days ............... 62
Reports Issued Over 6 Months for Which No Management Decision Has Been Made ..... 62
Significant Revised Management Decisions .............................................................. 64
Significant Disagreed Management Decisions ........................................................... 64
Peer Reviews ....................................................................................................... 64
Other Reporting Requirements and Requests ...................................... 66
References to the Inspector General Act............................................ 68
Abbreviations ................................................................................. 70
Treasury Office of Inspector General Semiannual Report—September 2024 iv
Treasury Office of Inspector General Overview
The Department of the Treasury’s (Treasury) Office of Inspector General (OIG) was
established pursuant to the 1988 amendments to the Inspector General Act of 1978. 1
Treasury OIG is headed by an Inspector General appointed by the President with the
advice and consent of the Senate.
Treasury OIG performs independent, objective reviews of Treasury programs and
operations, except for those of the Internal Revenue Service (IRS), and keeps the
Secretary of the Treasury and Congress fully informed of problems, deficiencies, and
the need for corrective action. The Treasury Inspector General for Tax Administration
(TIGTA) and the Government Accountability Office (GAO) perform oversight related to
the IRS. 2
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). 3 In addition to performing oversight of
Treasury related activities, Treasury OIG performs oversight of programs and
operations administered by the Gulf Coast Ecosystem Restoration Council (Council),
established as an independent federal entity, and the Gulf Coast Ecosystem
Restoration Science, Observation, Monitoring, and Technology Program (Science
Program) administered by the National Oceanic and Atmospheric Administration
(NOAA). With regard to the Council and the Science Program, Treasury OIG keeps the
appointed Chairperson of the Council, the NOAA Science Program Administrator, and
Congress fully informed of problems, deficiencies, and the need for corrective actions.
Treasury OIG has four components, the Office of Audit, Office of Investigations,
Office of Counsel, and Office of Management. Treasury OIG is headquartered in
Washington, DC.
The Office of Audit, under the leadership of the Assistant Inspector General for Audit,
performs and supervises financial and performance audits, attestation engagements,
and evaluations. The Assistant Inspector General for Audit also serves as the Special
1
5 U.S.C. §§401-424
2
During prior semiannual reporting periods, a Special Inspector General and GAO performed oversight
related to the Troubled Asset Relief Program (TARP). On March 31, 2024, the Special Inspector
General for the Troubled Asset Relief Program ended its operations as the last remaining investment
made by Treasury through the TARP was repaid, thereby, ending the program.
3
Public Law (P.L.)112-141
Treasury Office of Inspector General Semiannual Report—September 2024 1
Treasury Office of Inspector General Overview
Deputy Inspector General for Small Business Lending Fund (SBLF) Program Oversight.
Under the Assistant Inspector General for Audit, there are four deputies. The first
deputy is primarily responsible for financial sector audits to include audits of banking
supervision, manufacturing of currency and coins, Customs revenue collection
activities, resource management, procurement, alcohol and tobacco excise tax revenue
collection activities, and the State Small Business Credit Initiative authorized by the
American Rescue Plan 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
Governmentwide collection, payment, and debt programs and operations; and audits
of anti-money laundering/terrorist financing, foreign sanction, international affairs, and
intelligence programs and operations. The third deputy is primarily responsible for
cybersecurity, and financial assistance audits, including oversight of domestic
assistance programs under the Community Development Financial Institutions Fund
and other capital investment programs for low-to-moderate income communities, and
audits of RESTORE Act programs and operations. 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 to investigate threats against Treasury personnel and
assets in designated circumstances as authorized by the Inspector General Act. The
Office of Investigations also manages the Treasury OIG Hotline to facilitate reporting
of allegations involving these programs and operations.
The Office of Counsel, under the leadership of the Counsel to the Inspector General,
provides legal advice to the Inspector General and all Treasury OIG components. The
office represents Treasury OIG in administrative legal proceedings and provides a
variety of legal services, including (1) processing Freedom of Information Act and
Giglio 4 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
4
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 2024 2
Treasury Office of Inspector General Overview
responds to media and Congressional inquiries and serves as the Whistleblower
Protection Coordinator for Treasury.
The Office of Management, under the leadership of the Assistant Inspector General for
Management, provides administrative services to maintain the Treasury OIG
administrative infrastructure, including facilities, human resources, information
technology, procurement, records management, and security.
Treasury OIG’s fiscal year 2024 appropriation was $48.3 million, which included 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 $10 million for the Coronavirus
Relief Fund, $130,000 for ERA, and $30,000 for the Homeowner Assistance Fund. As
of September 30, 2024, Treasury OIG had 224 full-time staff.
Treasury Office of Inspector General Semiannual Report—September 2024 3
Management and Performance Challenges
The Reports Consolidation Act of 2000 requires that the Department of the Treasury
(Treasury) Inspector General annually provide information on the most serious
management and performance challenges facing Treasury and the Gulf Coast
Ecosystem Restoration Council (Council). The following is a synopsis of our annual
assessments which are available, in their entirety, on the Treasury Office of Inspector
General (OIG) website.
Treasury
In an October 15, 2024, memorandum to the Secretary of the Treasury OIG
reported the following four challenges facing the Department, of which one was
new.
• Ongoing Management of COVID-19 Pandemic Relief Programs (reframed
from Previous Challenge, COVID-19 Pandemic Relief)
• Cyber Threats (Repeat)
• Anti-Money Laundering/Terrorist Financing and Bank Secrecy Act
Enforcement (Repeat)
• Crypto and Digital Assets (New)
In addition to these challenges, we reported our concerns about the following
matters: (1) U.S. Mint gold acquisitions, (2) Bureau of Engraving and Printing’s
construction of a new facility, and (3) Treasury’s role with Customs revenue
functions.
Gulf Coast Ecosystem Restoration Council
In an October 3, 2024, letter to the Honorable Michael Regan, Administrator of
the U.S. Environmental Protection Agency, as Chairperson of the Council, OIG
reported three challenges.
• Recruiting and Retaining a Highly Skilled Workforce (Repeat)
• Federal Statutory and Regulatory Compliance (Repeat)
• Grant and Interagency Agreement Compliance Monitoring (Repeat)
Treasury Office of Inspector General Semiannual Report—September 2024 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) 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 (CAA, 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 Act of 2021 (ARP)
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. During this semiannual reporting period, a
certified independent public accounting firm (IPA), working under a contract with and
supervised by our office, performed the following audits of air carrier worker support
certifications.
Audit of Air Carrier Worker Support Certifications – Flight Group
Corporation
The IPA found that Flight Group Corporation, a passenger air carrier, reported
correct information for all four sections reviewed on its PSP1 Application. These
sections are: (1) applicant information, (2) applicant type, (3) awardable
amounts, and (4) certification. The IPA determined that Flight Group Corporation
incurred eligible PSP1 compensation between April 1, 2019, and
September 30, 2019, which exceeded the amount certified to Treasury on the
PSP1 Application by $130,388. Flight Group Corporation understated its
requested amount by $130,388 and did not over-request PSP1 financial
assistance. As a result, no amounts are owed back to Treasury. (OIG-24-038,
Redacted)
Treasury Office of Inspector General Semiannual Report—September 2023 5
Office of Audit – Significant Audits and Other Products
Audit of Air Carrier Worker Support Certifications – Freight Runners
Express, Inc.
The IPA found that Freight Runners Express, Inc., a cargo air carrier, reported
correct information for all four sections reviewed on its PSP1 application. These
sections are: (1) applicant information, (2) applicant type, (3) awardable
amounts, and (4) certification. The IPA determined that Freight Runners
Express, Inc. incurred eligible PSP1 compensation between April 1, 2019, and
September 30, 2019, which exceeded the amount certified to Treasury on the
PSP1 Application by $708. Freight Runners Express, Inc. understated its
requested amount by $708 and did not over-request PSP1 financial assistance.
As a result, no amounts are owed back to Treasury. (OIG-24-039, Redacted)
Audit of Air Carrier Worker Support Certifications – Prosegur
Services Group, Inc.
The IPA found that Prosegur Services Group, Inc., a contractor, reported correct
information for three of the four sections reviewed on its PSP1 application.
These sections are: (1) applicant information, (2) applicant type, and
(3) certification. For the awardable amounts section, the IPA found the company
was unable to provide sufficient supporting documentation to demonstrate that
the amounts requested for “benefits” were eligible for PSP1, in which the total
compensation incurred exceeded the amount certified to Treasury by
$31,059,787. Prosegur Services Group, Inc. understated its requested PSP1
amount by $31,059,787 and did not over-request PSP1 financial assistance
despite partial non-compliance with application requirements. As a result, no
amounts are owed back to Treasury. (OIG-24-040, Redacted)
Audit of Air Carrier Worker Support Certifications – Wing Aviation
Charter Services, LLC
The IPA found that Wing Aviation Charter Services, LLC, a passenger air carrier,
reported correct information for three of the four sections reviewed on its PSP1
application. These sections are: (1) applicant information, (2) applicant type,
and (3) certification. The IPA also found that the air carrier incorrectly reported
information in the awardable amounts section, resulting in a $320,605
overstatement. Specifically, the IPA found (1) the inclusion of unallowable
corporate officer compensation, resulting in an overstatement; and
(2) differences between the benefit estimates used to prepare the PSP1
Treasury Office of Inspector General Semiannual Report—September 2024 6
Office of Audit – Significant Audits and Other Products
application and the actual paid benefit amounts, resulting in an understatement.
Treasury’s awards to passenger air carriers under PSP1 included a 78.2 percent
pro-rata distribution of application amounts. Applying this formula, the air carrier
received a $250,713 overpayment from Treasury.
The IPA recommended Treasury management (1) seek reimbursement of the
$250,713 overpayment of PSP1 financial assistance; and (2) review the Wing
Aviation Charter Services, LLC’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-24-041, Redacted) $250,713 Questioned Costs
Audit of Air Carrier Worker Support Certifications – Superior
Transportation Associates, Inc.
The IPA found that Superior Transportation Associates, Inc., a passenger air
carrier, reported correct information for three of the four sections reviewed on
its PSP1 application. These sections are: (1) applicant information, (2) applicant
type, and (3) certification. The IPA also found that the air carrier incorrectly
reported information in the awardable amounts section, resulting in a $240,092
overstatement. Specifically, the IPA found (1) the inclusion of unallowable
corporate officer compensation, resulting in an overstatement; (2) the inclusion
of unsupported “other compensation” amounts, resulting in an overstatement;
and (3) differences between accrual-based accounting information used to
prepare the PSP1 Application, for “salaries and wages” and “benefits,” and the
actual compensation paid, resulting in an understatement. Treasury’s awards to
passenger air carriers under PSP1 included a 78.2 percent pro-rata distribution
of application amounts. Applying this formula, the air carrier received a
$187,752 overpayment from Treasury.
The IPA recommended Treasury management (1) seek reimbursement of the
$187,752 overpayment of PSP1 financial assistance; and (2) review Superior
Transportation Associates, Inc.’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-24-042, Redacted) $187,752 Questioned Costs
Treasury Office of Inspector General Semiannual Report—September 2024 7
Office of Audit – Significant Audits and Other Products
Audit of Air Carrier Worker Support Certifications – Prospect Airport
Services, Inc.
The IPA found that Prospect Airport Services, Inc., a contractor, reported
correct information for three of the four sections reviewed on its PSP1
application. These sections are: (1) applicant information, (2) applicant type,
and (3) certification. The IPA also determined that the contractor incorrectly
reported information in the awardable amounts section, resulting in a $310,004
overstatement. Specifically, the IPA found (1) the inclusion of unallowable
corporate officer compensation, resulting in an overstatement; (2) differences
between the accrual-based financial information used for benefits and the actual
amounts paid, resulting in an overstatement; and (3) the inclusion of benefit
compensation for ineligible affiliate employees, resulting in an overstatement.
However, the overstatements were offset by a $4,860,352 understatement due
to data errors, and eligible tip compensation paid to employees that the
company voluntarily withheld from the PSP1 application. Prospect Airport
Services, Inc. understated its requested PSP1 amount by $4,550,348 and did
not over-request PSP1 financial assistance despite partial non-compliance with
application requirements. As a result, no amounts are owed back to Treasury.
(OIG-24-043, Redacted)
Audit of Air Carrier Worker Support Certifications – One Sky Flight,
LLC
The IPA found that One Sky Flight, LLC, a passenger air carrier, reported correct
information for three of the four sections reviewed on its PSP1 application.
These sections are: (1) applicant information, (2) applicant type, and
(3) certification. The IPA also found that the air carrier incorrectly reported
information in the awardable amounts section, resulting in a $1,742,487
overstatement. Specifically, the IPA found (1) the inclusion of unallowable
corporate officer compensation, resulting in an overstatement; (2) the inclusion
of employee-paid contributions to benefits, resulting in an overstatement; and
(3) data errors, resulting in an overstatement. However, the overstatements
were offset by the company’s use of estimated employee healthcare costs that
would be provided under the Consolidated Omnibus Budget Reconciliation Act 5
elections, rather than actual paid amounts, resulting in a $4,845,182
understatement.
5
P.L. 99-272 (April 7, 1986)
Treasury Office of Inspector General Semiannual Report—September 2024 8
Office of Audit – Significant Audits and Other Products
One Sky Flight, LLC understated its requested amount by $3,102,695 and did
not over-request PSP1 financial assistance despite partial non-compliance with
application requirements. As a result, no amounts are owed back to Treasury.
(OIG-24-044, Redacted)
Audit of Air Carrier Worker Support Certifications – Suburban Air
Freight, Inc.
The IPA found that Suburban Air Freight, Inc., a cargo air carrier, reported
correct information for three of the four sections reviewed on its PSP1
application. These sections are: (1) applicant information, (2) applicant type,
and (3) certification. The IPA also determined that the air carrier incorrectly
reported information in the awardable amounts section, resulting in a $61,535
overstatement. Specifically, the IPA found (1) the inclusion of unallowable
corporate officer compensation, resulting in an overstatement, and (2) usage of
earned 6 and accrual based financial information instead of actual amounts paid
during the applicable period from April 1, 2019, through September 30, 2019,
resulting in an overstatement.
On May 28, 2021, Suburban Air Freight, Inc. recertified to Treasury and
acknowledged the inclusion of unallowable corporate officer compensation in its
PSP1 application. The money was returned to Treasury via a wire transfer on
December 3, 2021. The amounts returned to Treasury exceed the
overstatement of $61,535. As a result, no additional amounts are owed back to
Treasury. (OIG-24-045, Redacted)
CARES Act Compliance Monitoring
The CARES Act assigned our office 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
6
Suburban Air Freight, Inc. used earned rather than paid salaries and wages in its awardable amount
calculation. According to Treasury’s PSP1 guidance, the awardable amount should consist of figures
paid during April 1, 2019, through September 30, 2019. The use of salaries and wages earned
results in compensation paid outside of the applicable period. For example, salaries and wages
earned in September 2019 and paid in October 2019.
Treasury Office of Inspector General Semiannual Report—September 2024 9
Office of Audit – Significant Audits and Other Products
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, a certified independent public accounting firm (IPA), working under a
contract with and supervised by our office, performed the following activities and
outreach efforts for CRF recipients.
Desk Review of Bucks County, Pennsylvania’s Use of Coronavirus
Relief Funds
The IPA found that the expenditures related to contracts greater than or equal
to $50,000, aggregate reporting less than $50,000, 7 and aggregate payments
to individuals’ 8 payment types do not comply with CARES Act and Treasury’s
guidance. Based on the totality of the work performed, the IPA determined that
Bucks County’s risk of unallowable use of funds is moderate and recommended
that Treasury Office of Inspector General (OIG) follow-up with Bucks County’s
management, to confirm the transactions noted as unsupported or ineligible
expenditures across all payment types, are recouped or reallocated to other
eligible uses; and determine the feasibility of conducting an audit on those
related transactions. (OIG-CA-24-019) $111,423 Questioned Costs
Desk Review of Bergen County, New Jersey’s Use of Coronavirus
Relief Funds
The IPA found the expenditures related to the contracts greater than or equal to
$50,000 and transfers greater than or equal to $50,000 9 payment types
complied with the CARES Act and Treasury’s Guidance. The IPA also found that
the direct payments greater than or equal to $50,000 payment type complied
with the CARES Act but did not comply with Treasury’s Guidance. Additionally,
the IPA found that the aggregate reporting less than $50,000 payment type did
not comply with the CARES Act and Treasury’s Guidance. The IPA personnel
7
Recipients are required to report CRF transactions greater than or equal to $50,000 in detail in the
grants portal. Transactions less than $50,000 can be reported as an aggregate lump-sum amount by
type (contracts, grants, loans, direct payments, and transfers to other government entities).
8
Obligations and expenditures for payments made to individuals, regardless of amount, are required to
be reported in the aggregate in the grants portal to prevent inappropriate disclosure of personally
identifiable information.
9
A transfer to another government entity is a disbursement or payment to a government entity that is
legally distinct from the prime recipient.
Treasury Office of Inspector General Semiannual Report—September 2024 10
Office of Audit – Significant Audits and Other Products
reviewed documentation for a non-statistical selection of 20 transactions
reported in the quarterly Financial Progress Reports and identified unsupported
questioned costs totaling $57,000. Based on the totality of the work performed,
the IPA determined that Bergen County’s risk of unallowable use of funds is
moderate and recommended that Treasury OIG follow-up with Bergen County’s
management, to confirm the unsupported expenditures within aggregate
reporting less than $50,000, are recouped or reallocated to other eligible uses;
and determine the feasibility of conducting an audit on those related
transactions. (OIG-CA-24-028) $57,000 Questioned Costs
Emergency Rental Assistance Oversight
Section 501 of the CAA, 2021 assigned our office the responsibility to conduct
monitoring and oversight of the receipt, disbursement, and use of ERA1 and ERA2
funds and the authority to recoup funds used in violation of the CAA, 2021 and
Treasury’s guidance. The ERA1 statute, codified at 15 USC § 9058a, and the ERA2
statute, codified at 15 USC § 9058c, direct Treasury to make allocations and
payments to eligible grantees such as State and Local governments, who in-turn, make
funding available in the form of rental assistance to eligible households. As part of its
oversight authority for ERA1, if Treasury OIG determines that a grantee failed to
comply with the use of funds requirements in the statute, the amount equal to the
amount of funds used in violation shall be booked as a debt of such entity owed to the
Federal Government (i.e., recoup the misused funds). Under ERA2, Treasury OIG
reports misused funds to Treasury management as questioned costs for its action.
During this reporting period we performed the following activities and outreach efforts
for ERA1 and ERA2:
Emergency Rental Assistance Payments Made by the City of
Houston, TX and Harris County, TX
Based on numerous complaints received through our Office of Investigations
hotline, we initiated desk reviews of Houston’s and Harris County’s ERA1
Program. We also received a request from GAO to review potential duplicative
assistance involving these grantees.
We found 21,123 potential duplicative assistance payments related to
overlapping grantee jurisdictions for Houston and Harris County from Treasury’s
ERA1 database. Based on the non-statistical sample reviewed, we found
Treasury Office of Inspector General Semiannual Report—September 2024 11
Office of Audit – Significant Audits and Other Products
21 beneficiaries who received $110,928 in overpayments. Of the $110,928 in
overpayments, we questioned $98,242 as unallowable costs. We also found
overpayments due to assistance exceeding the allowed 15 months, payments
for ineligible expenses to beneficiaries who did not provide adequate proof of
identification or proof of residence in accordance with grantees’ program policy,
and a payment error. Lastly, we found a payment on behalf of a beneficiary
where the landlord and tenant may have had a familial relationship.
We recommended Treasury’s Office of Capital Access management require the
grantees’ management to take appropriate and timely corrective actions to
(1) determine if payments in the total population we used were made to eligible
beneficiaries in the correct amounts, (2) identify whether additional ERA1
ineligible and duplicate payments occurred after December 31, 2021, and if
applicable, provide the amount of such payments, and (3) identify whether
ineligible and duplicate payments were made during the entire ERA2 award
period of performance and if applicable, provide the amount of such payments.
We also recommended that Treasury management develop, document, and
communicate to our office its processes to monitor grantees for overpayments
and duplicate payments, track grantees’ recharacterizations, 10 and ensure data
quality for household addresses provided by grantees. Lastly, we recommended
that Treasury management provide technical advice and counsel to all grantees
and our office about the use of funds in circumstances where a landlord and a
tenant are related.
Treasury management agreed with our recommendations and the planned
corrective actions meet the intent of our recommendations. (OIG-CA-24-029)
$98,242 Questioned Costs
State of Washington
The State of Washington is a recipient of funds under the ERA1 statute. In
August 2023, we received a report from a Thurston County internal auditor of
10 cases of suspected and confirmed fraudulent ERA1 financial assistance
10
There may be cases in which a grantee discovers that a household has received ERA assistance from
multiple grantees intended to cover the same period of rent, utilities, rental arrears, or utility arrears.
In such cases, assuming certain conditions are met, the grantee may decline to recover its payment
and instead recharacterize it as assistance covering a different period of eligible rental or utility
expenses. Department of the Treasury, “Emergency Rental Assistance Frequently Asked Questions”
question 45 (May 10, 2023).
Treasury Office of Inspector General Semiannual Report—September 2024 12
Office of Audit – Significant Audits and Other Products
payments made by Thurston County Public Health and Social Services, a
subrecipient of the State of Washington. We agreed with the Thurston County
internal auditor’s conclusions on 9 of the 10 cases. Based on the information
provided, we determined that the State of Washington, through its subrecipient,
Thurston County Public Health and Social Services’ ERA1 program, paid out
ERA1 funds totaling $151,685.49 in violation of the ERA1 statute because the
funds were disbursed to ineligible households. On July 16, 2024, Treasury’s
Bureau of the Fiscal Service (Fiscal Service) issued an invoice for $151,685 to
the State of Washington. (OIG- CA-24-024, Redacted) $151,685 Questioned
Costs
Thurston County, Washington
Thurston County, Washington (Thurston County) is a recipient of funds under
the ERA1 statute. In August 2023, we received a report from a Thurston
County internal auditor of eight cases of suspected and confirmed fraudulent
ERA1 financial assistance payments made by Thurston County. We agreed with
the Thurston County internal auditor’s conclusions on seven of the eight cases.
Based on the information provided, we determined that Thurston County’s ERA1
program paid out ERA1 funds totaling $100,150 in violation of the ERA1 statute
because the funds were disbursed to ineligible households. On July 16, 2024,
Fiscal Service issued an invoice for $100,150 to Thurston County.
(OIG- CA- 24- 023, Redacted) $100,150 Questioned Costs
State of Missouri
The State of Missouri is a recipient of funds under the ERA1 statute. In June
2023, we made an inquiry to Missouri Housing Development Commission
(MHDC), a subrecipient that administers the ERA program for the State of
Missouri, regarding an allegation of fraud reported by MHDC to the Treasury OIG
Hotline that an individual submitted fraudulent applications to receive rental
assistance funds. Based on the information obtained in response to our inquiry,
we determined that MHDC paid out ERA1 funds in the amount of $24,600 in
violation of the ERA1 statute because the funds were disbursed to an ineligible
household. On April 18, 2024, Fiscal Service issued an invoice for $24,600 to
the State of Missouri. (OIG-CA-24-020, Redacted) $24,600 Questioned Costs
Treasury Office of Inspector General Semiannual Report—September 2024 13
Office of Audit – Significant Audits and Other Products
State of Michigan
On August 18, 2021, Treasury OIG received a complaint that alleged an
individual submitted fraudulent documentation to receive rental assistance
funds. On May 12, 2023, Treasury OIG referred this complaint to the State of
Michigan for its review. Based on the results of its review, we determined that
the State of Michigan paid out $11,400 of ERA2 funds in violation of the Use
of Funds statute because the funds were paid to an ineligible household. In
response to a draft of this questioned cost finding, the State of Michigan
reimbursed its ERA2 program account for $11,400 with non-federal funds.
Accordingly, we make no recommendation to Treasury management in this
memorandum. (OIG-CA-24-022, Redacted) $11,400 Questioned Costs
Cyber/Information Technology
Assessment of the Department of the Treasury’s Incident Response
Reporting Process for Select Incidents
We performed this assessment as part of our ongoing oversight of Treasury’s
compliance with the Federal Information Security Modernization Act of 2014
(FISMA), which required agencies to develop, document, and implement an
agency-wide information security program including procedures for detecting,
reporting, and responding to security incidents. To support our ongoing
oversight of Treasury’s compliance with FISMA, we performed periodic
assessments of the information security programs and practices of Treasury’s
bureaus and offices.
We found Treasury effectively implemented federal and departmental
requirements for reporting cyber incidents. However, we found discrepancies in
Treasury’s procedures and processes for determining and declaring the severity
level of incidents. We made two recommendations to the responsible officials to
address the identified deficiencies. Treasury management agreed with the
recommendations and prepared corrective actions that were responsive to the
intent of our recommendations. Due to the sensitive nature of these systems,
this report is designated Sensitive But Unclassified. (OIG-CA-24-027, Sensitive
But Unclassified)
Treasury Office of Inspector General Semiannual Report—September 2024 14
Office of Audit – Significant Audits and Other Products
FISMA
The 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.
Audit of the Department of the Treasury Federal Information
Security Modernization Act, Fiscal Year 2024 Performance Audit for
the Collateral National Security Systems
A certified independent public accounting firm (IPA), working under a contract
with and supervised by our office, performed an audit of Treasury’s information
security program and practices for its collateral National Security Systems for
the period April 1, 2023, through March 31, 2024. For fiscal year 2024, the
IPA reported that Treasury established and maintained its information security
program and practices for its collateral national security systems for the 5
Cybersecurity Functions and 9 FISMA Metric Domains. The IPA assessed
Treasury’s information security programs and practices for both of its Collateral
National Security Systems as Consistently Implemented (Level 3), which was
ineffective according to the Department of Homeland Security’s (DHS) criteria.
While the IPA did not identify any new findings, most metrics were not
assessed as Managed and Measurable (Level 4) due to a lack of identified
qualitative and quantitative performance measures on the effectiveness of the
security programs and practices. As one prior year finding remained open,
Treasury management agreed with the recommendation and prepared a
corrective action plan that met the intent of the IPA’s recommendation. Due to
the sensitive nature of these systems, this report is designated Sensitive But
Unclassified. (OIG-24-033, Sensitive But Unclassified)
Audit of the Department of the Treasury Federal Information
Security Modernization Act, Fiscal Year 2024 Performance Audit for
the Unclassified Systems
An IPA, working under a contract with and supervised by our office, performed
an audit of Treasury’s unclassified systems, for the period April 1, 2023,
through March 31, 2024. The Treasury Inspector General for Tax Administration
(TIGTA) performed the annual FISMA evaluation of the Internal Revenue Service
(IRS) unclassified systems. For fiscal year 2024, the IPA reported Treasury’s
information security program and practices for its unclassified systems were
established and have been maintained for the 5 Cybersecurity Functions and 9
Treasury Office of Inspector General Semiannual Report—September 2024 15
Office of Audit – Significant Audits and Other Products
FISMA Metric Domains. However, the program was not effective according to
DHS criteria and as reflected by 4 deficiencies noted by the IPA within 4 of the
5 Cybersecurity Functions and within 4 of the 9 FISMA Metric Domains.
Accordingly, the IPA made 6 recommendations to the responsible officials to
address the identified deficiencies. Treasury management agreed with the
recommendations and prepared corrective action plans that met the intent of
the IPA’s recommendations. Due to the sensitive nature of these findings, this
report is designated Sensitive But Unclassified. (OIG-24-034, Sensitive But
Unclassified)
Fiscal Year 2023 Audit of the Department of the Treasury’s
Information Security Program and Practices for Its Intelligence
Systems
We found Treasury’s intelligence systems for the period April 1, 2022, through
March 31, 2023, were not effective according to DHS criteria. Treasury
management concurred with the recommendations made in our report. Due to
the sensitive nature of these systems, this report is designated as Classified.
(OIG-24-046, Classified)
Fiscal Year 2024 Audit of the Department of the Treasury’s
Information Security Program and Practices for Its Intelligence
Systems
We found Treasury’s intelligence systems for the period April 1, 2023, through
March 31, 2024, were not effective according to DHS criteria. Treasury
management concurred with the recommendations made in our report. Due to
the sensitive nature of these systems, this report is designated as Classified.
(OIG-24-047, Classified)
The Gulf Coast Ecosystem Restoration Council Federal Information
Security Modernization Act of 2014 Evaluation Report for Fiscal
Year 2024
An IPA, working under a contract supervised by our office, performed the
annual FISMA evaluation of the Council’s security program and practices for the
period April 1, 2023, through March 31, 2024. The IPA found the Council’s
information security program and practices were effective for the evaluation
period. The IPA did not make any recommendations to the Council. Council’s
management concurred with the report. (OIG-CA-24-021)
Treasury Office of Inspector General Semiannual Report—September 2024 16
Office of Audit – Significant Audits and Other Products
Geospatial Data Act
Title VII, Subtitle F, Section 759(c) of the Geospatial Data Act of 2018 (GDA) requires
the Inspector General of a covered agency to submit to Congress an audit of the
collection, production, acquisition, maintenance, distribution, use, and preservation of
geospatial data by the covered agency on a biennial basis. Section 759(c) requires that
Inspectors General review the respective covered agency’s compliance with the
following: (1) standards for geospatial data, including metadata for geospatial data,
established under Section 757; (2) the 13 covered agency responsibilities under
Section 759(a); and (3) limitations on the use of federal funds under Section 759A.
We issued the following biennial report during this semiannual reporting period.
Audit of the Department of the Treasury’s Compliance with the
Geospatial Data Act of 2018
Treasury’s Office of the Chief Information Officer is responsible for the
oversight of implementing the Act at Treasury. Of the Treasury bureaus, only
the Alcohol and Tobacco Tax and Trade Bureau currently has reportable
geospatial data. We concluded that Treasury complied with the 13 covered
agency responsibilities as identified under Section 759(a) of the GDA. We did
not evaluate the requirements included in Sections 759(c)(1) and 759(c)(3)
because comprehensive geospatial data standards had not been established by
the Federal Geographic Data Committee. There were no recommendations in the
report. (OIG-24-035)
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 – User Access
This report is the second in a series of reports presenting the results of our audit
of Treasury’s Financial Crimes Enforcement Network's (FinCEN) management of
Bank Secrecy Act (BSA) data, and more specifically granting and revoking
access to FinCEN Portal.
We found that FinCEN did not manage aspects of BSA data access in
compliance with applicable policies and procedures, memoranda of
Treasury Office of Inspector General Semiannual Report—September 2024 17
Office of Audit – Significant Audits and Other Products
understanding (MOU), and government-wide standards. Specifically, FinCEN did
not: (1) have proper controls to ensure that external agencies provided proper
notification to FinCEN when disabling accounts, (2) maintain proper records of
the dates and reasons internal user accounts were disabled, (3) timely disable
internal user accounts, (4) properly complete out-processing forms for departed
employees, and (5) require agencies to identify whether users received
background checks.
We recommended that the Director of FinCEN: (1) implement internal controls to
ensure that agencies properly notify FinCEN when agencies revoke user access
for non-routine actions; (2) determine whether the MOU requirement that
agencies notify FinCEN when they revoke user access for routine personnel
actions is necessary, and if not, communicate this change to agencies, in
writing, and remove that language from future MOUs; (3) update MOUs and
related guidance to specifically require agencies to disable accounts when their
users no longer require or meet criteria for access, and to include a timeliness
metric to ensure accounts are disabled promptly; (4) determine if a database
software update is warranted to accurately capture a historical record of the
dates and reasons user accounts are disabled, and if warranted, implement the
update; otherwise, design and implement an alternative tracking method;
(5) update the FinCEN Portal/Query/FIR – Disabled Account Tickets standard
operating procedures (SOP) to add quarterly and “spot-check” reviews of
disabled user accounts to determine if supervisors are providing advance
notification of departing employees and if Application Help Desk Technicians are
appropriately and timely disabling accounts; (6) update the Account
Management guidance to include a timeliness metric for how quickly Application
Help Desk Technicians must disable an account when a user no longer requires
access; (7) implement quality control measures, including a timeliness metric for
form completion, to ensure supervisors properly review and complete departed
employees’ out-processing forms; and (8) ensure the background check field is
mandatory for Portal user account profiles, and until the related system update
takes effect, design and implement a process to ensure only users with
background checks can access BSA data, and confirm that background checks
were completed for all existing users.
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-24-030)
Treasury Office of Inspector General Semiannual Report—September 2024 18
Office of Audit – Significant Audits and Other Products
Manufacturing and Revenue
We conduct audits of Treasury’s coin, currency, and alcohol and tobacco tax and
trade programs. We issued the following report during this semiannual period.
The Mint Needs to Enhance Controls Over Gold Acquisitions
We performed a review of the United States Mint (Mint) process and controls to
acquire gold for use in the Mint’s gold bullion and numismatic programs,
including controls used by the Mint’s gold bullion suppliers and refiners to
ensure responsible sourcing.
We found the Mint did not receive illicit gold and that the gold is responsibly
sourced; however, further engagement with its gold suppliers and refiners
would enhance controls over the process. Specifically, we found the Mint has
limited engagement with its gold bullion suppliers or approved gold refineries to
reaffirm that responsible sourcing requirements are being conducted in
accordance with U.S. law. The Mint did not request or obtain any
documentation from gold refiners concerning the origin of the gold or relating to
the supply chain and primarily relies on the gold refiners’ adherence to the
London Bullion Market Association’s (LBMA) Good Delivery List (GDL) to ensure
that gold acquired by the Mint is responsibly sourced. The LBMA GDL is the list
of gold and silver refiners whose products are acceptable to be traded on the
London bullion market. To be listed on the GDL, refiners must undergo, among
other things, stringent checks regarding their history in the market, their
financial standing, and their compliance with standards for responsible sourcing
and their ability to produce bars that meet the specified standards.
Additionally, we found that the Mint cannot ensure most gold coins produced
are minted from newly mined U.S. gold and in compliance with the Gold Bullion
Coin Act of 1985 11 and the Presidential $1 Coin Act of 2005. 12 This is due to
the Mint’s lack of documentation from its gold refiners certifying the amount of
newly mined U.S. gold acquired. We also found it questionable whether the
Mint’s methodology used to determine what constitutes newly mined U.S. gold
is permissible under current U.S. law and that the Mint’s website represented
certain gold coins as minted entirely from U.S. gold, which may mislead
purchasers.
11
P.L. 99-185
12
P.L. 109-145
Treasury Office of Inspector General Semiannual Report—September 2024 19
Office of Audit – Significant Audits and Other Products
We recommended that the Director of the Mint ensure the Mint (1) considers
additional procedures to oversee refiners including, but not limited to, obtaining
and periodically reviewing documentation from the Mint’s approved refineries,
such as the LBMA-required third party audits and supporting documentation, to
ensure that refineries are sourcing gold responsibly in accordance with U.S. law
and the best interests of the U.S. Government; and (2) within 30 days of
issuance of this report, develops a plan that outlines the steps and controls the
Mint will implement to comply with Public Law 99-185 and Public Law 109-145
in the production of gold coins, which includes a review of the Mint’s current
methodology to ensure it complies with U.S. law. As part of this review, the
Mint should publish its procedures for acquiring newly mined U.S. gold in the
Federal Register. Furthermore, the Mint needs to update its website for
accuracy.
Mint management concurred with our audit’s findings and outlined planned
corrective actions to implement our recommendations. (OIG-24-027)
U.S. Treasury’s Role with the Customs Revenue Function – Trade
Facilitation and Trade Enforcement Act of 2015, Section 112
We performed a review of Treasury’s role with the Customs revenue function.
We found Treasury needs to address the official delegation of Customs revenue
responsibilities following the May 2022 retirement of the Deputy Assistant
Secretary for Tax, Trade, and Tariff Policy who was delegated the responsibility
retained by Treasury related to Customs revenue functions. Treasury officials
have since continued to be engaged in the Customs revenue function and
acknowledge our recommendation to update orders and directives as necessary
and have considered how to best allocate responsibility for Customs revenue
functions between Treasury and the U.S. Department of Homeland Security.
Treasury officials anticipate this will be completed in 60 days from issuance of
this memorandum as we recommended. (OIG-CA-24-025)
Financial Management
A certified independent public accounting firm (IPA), 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) 2023. Our office
performed the audit of the Council’s compliance with PIIA for FY 2023. As required by
Treasury Office of Inspector General Semiannual Report—September 2024 20
Office of Audit – Significant Audits and Other Products
PIIA, we reported on Treasury and the Council’s overall compliance with PIIA for FY
2023.
Treasury PIIA for FY2023
The IPA determined that Treasury was not in compliance with PIIA for FY 2023.
Specifically, Treasury did not adequately conclude whether programs are likely
to make Improper Payments and Unknown Payments above or below the
statutory threshold for two pandemic relief programs—the Emergency Rental
Assistance Program and Air Carrier Payroll Support Programs; and did not
comply with the requirement to report an improper payment rate of less than 10
percent for four IRS 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. Treasury
complied with the remaining eight PIIA requirements. (OIG-24-029)
Gulf Coast PIIA FY 2023
We determined that the Council complied with the applicable requirements of
PIIA for fiscal year 2023. We made no recommendations in this report.
(OIG- 24- 028)
Attestation Engagements
An IPA, under contract monitored by our office, completed the report described below
in support of the audit of Treasury’s FY 2024 consolidated financial statements and
the financial statement audits of certain other federal agencies.
Report on the Processing of Transactions by Treasury Enterprise
Applications
The IPA examined management of 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 operating
effectiveness of these controls for the period beginning July 1, 2023, and
ending June 30, 2024. The IPA 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- 24-031)
Treasury Office of Inspector General Semiannual Report—September 2024 21
Office of Audit – Significant Audits and Other Products
Federal Financial Management Improvement Act
The following instance of noncompliance with the Federal Financial Management
Improvement Act of 1996 was reported in connection with the audit of Treasury’s FY
2023 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)
The status of this instance of noncompliance, including progress in implementing
remediation plans, will be evaluated as part of the audit of Treasury’s FY 2024
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 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 Equitable Recovery Program (CDFI ERP) and Treasury’s
Soundness of Investment Decisions for Participation in the Emergency Capital
Investment Program (ECIP).
Audit of Treasury’s Soundness of Investment Decisions for
Participation in the Emergency Capital Investment Program
We performed this audit in accordance with Title V, Subtitle B in Division N of
CAA, 2021, which requires the Treasury OIG to submit a report twice a year to
Congress and the Treasury on the oversight provided for the programs
established under Subtitle B, including any recommendations for improvement.
We found that Treasury accurately allocated investments under the Emergency
Capital Investment Program (ECIP), in accordance with CAA, 2021 and ECIP
policies and procedures. Furthermore, Treasury incorporated internal controls
throughout their application review and decision-making process in accordance
with Government Accountability Office’s (GAO) Standards for Internal Control in
Treasury Office of Inspector General Semiannual Report—September 2024 22
Office of Audit – Significant Audits and Other Products
the Federal Government (Green Book). Treasury received 212 ECIP applications
from banks, Bank Holding Companies, Savings and Loans Holding Companies,
and credit unions by the established September 1, 2021, deadline. We reviewed
a sample of 52 from the 212 applications and determined Treasury complied
with the CAA, 2021, for investment decisions made under ECIP.
As a follow up to our Audit of Treasury’s Implementation of the Emergency
Capital Investment Program (OIG-22-028), we determined Treasury finalized
policies and procedures and key documentation to govern full program
implementation and ongoing administration of ECIP investments and designed
internal control over the program. Treasury designed and implemented
Treasury’s ECIP Standard Operating Procedures: Application Review and
Decisioning Process: (1) to standardize the process that Treasury ECIP personnel
follow to review applications and select applicants for investment; and (2) to
clearly document and allocate responsibilities among Treasury ECIP personnel
and define roles to implement these procedures. Lastly, we determined that
Treasury complied with the requirements in the GAO Green Book and Office of
Management and Budget (OMB) Circular A-123, Management’s Responsibility
for Internal Control, when reviewing and approving or disapproving ECIP
applicants. (OIG-24-036)
Audit of the Community Development Financial Institutions Fund’s
Award and Post-Award Administration of the CDFI Equitable
Recovery Program
We found the CDFI Fund documented the CDFI ERP award determination
process across multiple Standard Operating Procedures (SOPs), consistent with
the GAO Green Book. The CDFI Fund also accurately calculated and
administered CDFI ERP awards, and issued payments, in accordance with the
CAA, 2021 and the OMB’s Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards, 2 Code of Federal
Regulations (CFR) Part 200 (Uniform Guidance). For applicants deemed ineligible
to receive a CDFI ERP award, the CDFI Fund reviewed and documented
applicants’ ineligibility in accordance with the requirements in the notice of
funds availability and in compliance with internal policies and procedures.
Additionally, we found the CDFI Fund designed and implemented the CDFI ERP
post-award administration process, as well as developed post-award monitoring
SOPs and the CDFI ERP Assistance Agreement, in compliance with the CAA,
2021, Uniform Guidance, and GAO Green Book. Furthermore, the CDFI Fund
Treasury Office of Inspector General Semiannual Report—September 2024 23
Office of Audit – Significant Audits and Other Products
established: (1) procedures for evaluating CDFI ERP annual compliance reports;
(2) a noncompliance process; and (3) a process for closing CDFI ERP awards.
We did not make any recommendations. (OIG-24-037)
Treasury Office of Inspector General Semiannual Report—September 2024 24
Office of Audit – Significant Audits and Other Products
Other Audits of Treasury Programs and Operations
Audit of Direct Express Program Disputes Related to Certain
Cardholder Accounts
This third report in the series was initiated in response to complaints made by
Direct Express cardholders who contacted our Office of Investigations. Of the
42 Service Request notices 13 reviewed, we found that Comerica, Fiscal
Service’s financial agent, and Conduent, Comerica’s contractor, were compliant
with Regulation E, 12 CFR Section 1005.11(c), Time limits and extent of
investigation, with one exception. According to this section, a financial
institution is required to investigate promptly and determine whether an error
occurred within 10 business days of receiving a notice of error. For this
instance, the cardholder gave oral notification and provided the fraud
questionnaire timely; however, Conduent did not close the case until the 11th
business day and did not provide a provisional credit to the cardholder. We
made one recommendation in our report.
Fiscal Service’s management concurred with our recommendation. Management
noted that more stringent service level requirements (SLRs) were included in the
most recent financial agency agreement (FAA) with Comerica, dated January 3,
2020, to help ensure that service request notices are reviewed and processed in
accordance with Regulation E. Management stated that in future Direct Express
FAAs Fiscal Service intends to, subject to the financial agent’s agreement,
implement measures related to Regulation E compliance, such as (1) increasing
the financial agent’s expected performance levels for Regulation E compliance-
related SLRs; (2) requesting that the proposed financial agent provide the
capability to file disputes and track dispute status online and via the mobile app,
thereby increasing the efficiency of the process and providing transparency to
cardholders; and (3) requiring the financial agent to provide regular aggregate
Regulation E compliance reporting data. (OIG-24-032)
13
A Service Request notice is opened by Conduent, a contractor for Comerica, Fiscal Service’s financial
agent, when a cardholder contacts Conduent to report a potential error with a card transaction.
Treasury Office of Inspector General Semiannual Report—September 2024 25
Office of Investigations – Significant Investigations
Maryland Resident Sentenced to 24 Months in Mortgage Fraud Scheme
During this reporting period, the subject of a Department of the Treasury (Treasury)
Office of Inspector General (OIG) and Fairfax County Police Department investigation
was sentenced to 24 months’ incarceration, 36 months of supervised release,
$183,000 in restitution, and a $100 special assessment for bank fraud. The subject
devised a scheme to defraud a mortgage lender into agreeing to a short sale, or pre-
foreclosure sale, of a residential property in Alexandria, Virginia that was pending
foreclosure for non-payment of the mortgage. The subject and the nominee owner
received the proceeds of the fraudulent sale which was used to pay off the remaining
loan balance and purchase a new property in Ft. Washington, Maryland. The subject
also forfeited $276,000 of the proceeds of the offense prior to sentencing. The U.S.
Attorney’s Office (USAO) for the Eastern District of Virginia prosecuted the case.
Emergency Rental Assistance Funds Disbursement Unsubstantiated
On June 12, 2024, Treasury OIG completed its investigation into a complaint received
from a charitable organization in Houston, Texas regarding an allegation of an
identified landlord to defraud the Emergency Rental Assistance (ERA) program of
approximately $1.9 million via suspected fraudulent ERA applications. Treasury OIG
unsubstantiated the complaint through document reviews, interviews of current and
past residents listed on the applications in question, and subsequent subject
interviews. Treasury OIG was able to corroborate all the applications previously
identified as fraudulent were legitimate ERA applications.
Former Treasury Policy Advisor Sentenced for Violent Crimes
On May 16, 2024, Treasury OIG completed its report of investigation for a case
alleging a former Treasury Departmental Offices (DO) Policy Advisor committed violent
crimes. The investigation by the Arlington County Virginia Police Department resulted
in a substantiation of the allegations and the subject was sentenced in Arlington
County Virginia Circuit Court to 36 months’ incarceration and 288 months’ supervised
release. Treasury OIG monitored the Arlington Circuit Court activity and acted in an
intermediary capacity by providing open-source court information to the DO. Treasury
OIG has provided a report to the DO for its information.
Treasury Office of Inspector General Semiannual Report—September 2024 26
Office of Investigations – Significant Investigations
Allegations of Emergency Rental Assistance Fraud Substantiated
On April 15, 2024, Treasury OIG completed its report of investigation based on receipt
of a complaint alleging that one individual submitted three false tenant applications
and one fraudulent landlord application to obtain $101,000 in California Coronavirus
Disease 2019 (COVID-19) Rent Relief funds from the ERA program. The investigation
revealed the subject filed a fraudulent landlord application and took over the true
landlord’s ERA account to erroneously obtain ERA funds for himself and three fake
tenants totaling $101,000. The investigation was presented to the California Office of
the Attorney General and was subsequently declined due to lack of prosecutorial
resources and higher priority investigations. This case was presented to the USAO for
the Northern District of California, who declined prosecution due to lack of
prosecutorial resources and higher priority investigations.
Civil Settlement Obtained for Contractors that Failed to Meet
Cybersecurity Requirements Regarding the Emergency Rental Assistance
Program
On May 13, 2024, two contractors agreed to pay a total of $11 million in civil
settlements for failing to abide by requirements of New York's ERA program. The ERA
contract required specific cybersecurity requirements, and the contractors admitted
they had failed to properly meet the requirements. The USAO for the Northern District
of New York and Department of Justice Civil Division negotiated the settlement.
Allegation of Payroll Support Program Fund Misuse by Recipient Business
Unsubstantiated
On July 26, 2024, Treasury OIG completed its report of an investigation into an
allegation of misuse of Payroll Support Program (PSP) funding received by a business
in Ohio. Allegedly, the business obtained $50,350,000 in PSP between 2020 and
2021 and was using the funds to pay off previous debts rather than to pay
employees. Treasury OIG reviewed internal business documents, bank data, and audit
reports that revealed no evidence of a misuse of PSP funds occurred. The investigation
further determined that the PSP funds were deposited into an account used for the
purpose of employee payroll.
Treasury Office of Inspector General Semiannual Report—September 2024 27
Office of Investigations – Significant Investigations
PRAC Subject Sentenced for Theft of Government Funds After Falsifying
Economic Injury and Disaster Loan and Paycheck Protection Program Loan
Applications
On April 26, 2024, a subject in a Pandemic Response Accountability Committee
(PRAC) Task Force investigation was sentenced to 36 months’ probation, with four
months’ home confinement, and $200,000 in restitution. The subject applied for and
received one Economic Injury and Disaster Loan (EIDL), and two Paycheck Protection
Program (PPP) loans, while debarred from receiving federal contracts. The subject
attested on each PPP and EIDL application that they were not barred from receiving
federal contracts. The USAO for the Eastern District of Virginia prosecuted the case.
Coronavirus Relief Fund, Paycheck Protection Program, and Economic
Injury and Disaster Loan Fraud Substantiated
On August 29, 2024, Treasury OIG completed its report of investigation for a joint
case with the Federal Bureau of Investigation (FBI) regarding Coronavirus Relief Fund
(CRF) fraud against the Department of Economic Development, Louisville, KY.
Specifically, the investigation revealed three subjects conspired to submit fraudulent
documentation to obtain CRF funding for businesses they owned during the COVID-19
pandemic. The subjects also received funding from the Small Business
Administration’s PPP and EIDL program, both totaling over $200,000. This matter was
presented and declined by the USAO for the Western District of Kentucky and the
USAO for the Eastern District of Kentucky, citing the loss amount being below
threshold and venue concerns.
Allegations of CARES ACT Fraud by Monacan Indian Nation
Unsubstantiated
On July 26, 2024, Treasury OIG completed its investigation into a complaint alleging
that the Tribal leadership of Monacan Indian Nation was misspending the funding on
property, new vehicles, and repaired existing buildings for unknown purposes.
Treasury OIG’s investigation also revealed the Tribe’s law firm, Cultural Heritage
Partners, received a significant amount of funds from the receipt of CRF. Treasury
OIG, in coordination with the Office of Audit, conducted an eligibility meeting and
concluded the purchase of the properties, the renovations to the properties, the
purchase of a vehicle, and the law firm’s funds was considered an eligible use of CRF
assistance. The allegations were unsubstantiated.
Treasury Office of Inspector General Semiannual Report—September 2024 28
Office of Investigations – Significant Investigations
Two Subjects Sentenced for Theft of U.S. Treasury Checks
On June 26, 2024, the final subject in a joint Treasury OIG, FBI, Treasury Inspector
General for Tax Administration (TIGTA), U.S. Postal Inspection Service, and the
Internal Revenue Service (IRS) - Criminal Investigation Division investigation was
sentenced. Two subjects conspired and stole a Thrift Saving Plan withdrawal check
and tax refund checks. The two subjects were sentenced to a 120 months’
incarceration, 72 months’ probation, and $3 million in restitution. The USAO for the
Southern District of Texas prosecuted the case.
Bureau of Engraving and Printing Employee Accepted Illegal Gratuities
from a Government Contractor Substantiated
On February 21, 2024, Treasury OIG completed its report of investigation for a case
initiated upon notification that Bureau of Engraving and Printing (BEP) employees
responsible for overseeing a contractor’s activities may have engaged in an
inappropriate relationship with the contractor’s owner. Treasury OIG’s investigation
determined a BEP employee accepted financial and other incentives from the
contractor. The USAO for the District of Columbia declined the case for federal
prosecution. Criminal prosecution of the subject was also presented to the Office of
the Attorney General for the District of Columbia and was declined.
Treasury Office of Inspector General Semiannual Report—September 2024 29
Treasury OIG Accomplishments and Activities
Treasury OIG Leadership Roles
Department of the Treasury (Treasury) Office of Inspector General (OIG) professionals
serve on various important public and private professional organizations supporting the
federal audit community. Examples of participation in these organizations follows:
Pauletta Battle, Deputy Assistant Inspector General for Financial Management and
Transparency Audits, serves as the Council of the Inspectors General on Integrity and
Efficiency’s Accounting and Auditing Policy Committee member on the Federal
Accounting Standards Advisory Board.
Cecilia Howland, Deputy Assistant Inspector General for Cyber and Financial
Assistance Audits, is the National Single Audit Coordinator for Treasury.
Treasury Office of Inspector General Semiannual Report—September 2024 30
Statistical Summary
Summary of Treasury OIG Activities
April 1, 2024, through September 30, 2024
Number or
OIG Activity Dollar Value
Office of Counsel Activities
Regulation and legislation reviews 11
Instances where information was refused 0
Office of Audit Activities
Reports issued and other products 35
Disputed audit recommendations 0
Significant revised management decisions 0
Management decision in which the Inspector General disagrees 0
Monetary benefits (audit)
Questioned costs $992,965
Funds put to better use $0
Total monetary benefits $992,965
Office of Investigations Activities*
Criminal and judicial actions (including joint investigations)
Investigative reports issued 71
Cases referred for prosecution and/or litigation 21
Individuals referred for criminal prosecution to the Department of Justice 28
Individuals referred for criminal prosecution to state and local authorities 2
Cases accepted for prosecution and/or litigation 8
Arrests 2
Indictments/informations 15
Convictions (by trial and plea) 13
*During the reporting period, subjects were sentenced to 609 months of prison time, 528 months of
probation, and ordered to pay fines, restitution, and court fees in the amount of $14,948,508.
Metrics Used for Office of Investigations Activities
Department of the Treasury (Treasury) Office of Inspector General (OIG) investigative
statistics listed above were obtained through closed reports drawn from Treasury
OIG’s Office of Investigations case management system.
Treasury Office of Inspector General Semiannual Report—September 2024 31
Statistical Summary
Reports with Unimplemented Recommendations
Issued prior to October 1, 2024
The following list of Treasury OIG reports with unimplemented recommendations is
based on information in Treasury’s automated audit recommendation tracking system,
which is maintained by Treasury management officials, and recommendations tracked
by other federal organizations related to Treasury OIG’s oversight of the Resources
and Ecosystems Sustainability, Tourist Operations, and Revived Economies of the Gulf
Coast States Act of 2012 (RESTORE Act) programs and activities of the Gulf Coast
Ecosystem Restoration Council (Council) and the National Oceanic and Atmospheric
Administration’s (NOAA) Gulf Coast Ecosystem Restoration Science, Observation,
Monitoring, and Technology Program; and of U.S. Department of Homeland Security
(DHS), U.S. Customs and Border Protection’s (CBP) programs and activities related to
protecting revenue.
Treasury OIG is reporting 105 open and unimplemented recommendations for
46 reports issued prior to April 1, 2024, with over $2.2 billion in potential cost
savings.
Treasury OIG considers the following unimplemented recommendations 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 2024 32
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2018 OIG-18-044 TERRORIST FINANCING/MONEY 04/18
LAUNDERING: Audit of the Office of
Intelligence and Analysis’ Authorities and
Actions Related to U.S. Persons’
Financial Information
1. The Under Secretary for Terrorism and Financial Intelligence, as
expeditiously as possible, should implement a compliance monitoring
program to assess whether intelligence analysts’ activities are conducted in
accordance with Office of Intelligence and Analysis authorities, and
electronic searches and other queries are performed in a manner that fully
protects the rights of U.S. persons. Management agreed with the
recommendation.
Fiscal Report Number Report Title Date Issued
Year
2019 OIG-19-007 INFORMATION TECHNOLOGY: 10/18
Department of the Treasury Federal
Information Security Modernization Act
Fiscal Year 2018 Performance Audit
1. Treasury Inspector General for Tax Administration (TIGTA) management
should establish a current enterprise baseline of software and related
configurations for the TIGTA System. Management agreed with the
recommendation.
Fiscal Report Number Report Title Date Issued
Year
2020 OIG-20-003 INFORMATION TECHNOLOGY: 10/19
Department of the Treasury Federal
Information Security Modernization Act
Fiscal Year 2019 Performance Audit
1.& 2. U.S. Mint (Mint) management should finalize and implement its bureau-wide
privacy program that includes a strategic organizational privacy plan for
implementing applicable privacy control and procedures in
accordance with National Institute of Standards and Technology 800-53.
Management agreed with the recommendation.
Treasury Office of Inspector General Semiannual Report—September 2024 33
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2020 OIG-20-007 DATA ACT: Treasury Continues to Make 11/19
Progress in Meeting its DATA Act
Reporting Requirements
1. Treasury’s Assistant Secretary for Management, working as needed with
Treasury’s Senior Accountable Official, the Senior Procurement Executive,
reporting entities, the Program Management Office, and the Office of
Management and Budget should develop and implement a method and
procedures to submit Treasury Forfeiture Fund financial assistance award
data to the Financial Assistance Broker Submission in accordance with the
reporting submission specifications established by the Digital Accountability
and Transparency Act (DATA Act) Information Model Schema. Management
agreed with the recommendation.
Fiscal Report Number Report Title Date Issued
Year
2020 OIG-20-022 FINANCIAL MANAGEMENT: 12/19
Management Report for the Audit of
the Department of the Treasury’s
Consolidated Financial Statements for
Fiscal Years 2019 and 2018
1. Bureau of the Fiscal Service (Fiscal Service) management finalize policies
and procedures to review audit logs of production DB2 servers.
2. Implement an oversight process to ensure that designated Fiscal Service
personnel:
a. Reviews the security logs for the UNIX and DB2 servers hosting the
Payment Information Repository, Judgment Fund Internet Claim System,
and Security Payment System applications on a pre-defined frequency, as
indicated in the Fiscal Service Baseline Security Requirements,
b. Formally documents completion of their reviews and any escalations to
the Information System Security Office, and
c. Retains the audit logs and documentation of its reviews for 18 months,
as required by the Baseline Security Requirements.
3. Periodically review Fiscal Service management’s implementation and
operation of the review the security audit logs for the UNIX and DB2 servers
hosting the Payment Information Repository, Judgment Fund Internet Claim
System, and Security Payment System applications to determine that Fiscal
Service management completes the reviews on a pre-defined basis,
documents completion of the reviews and escalations, and maintains such
documentation.
Treasury Office of Inspector General Semiannual Report—September 2024 34
Statistical Summary
4. Establish an effective enforcement process or mechanism to ensure that (a)
UNIX and DB2 events and monitoring controls are followed, and (b) Fiscal
Service management has confidence it consistently reviews for potential
unauthorized or inappropriate activity.
5. Develop and implement documentation to assign responsibility for ensuring
adequacy of UNIX and database security and baseline settings.
6. Update existing UNIX and database configuration security baseline
documents to ensure that these documents fully incorporate and enforce the
components of the Defense Information Systems Agency Security Technical
Implementation Guides. Management should document any deviations from
the Security Technical Implementation Guides and note compensating
controls that mitigate the security risk to an acceptable level.
7. Develop, document, and implement policies, procedures, and controls to
conduct periodic reviews of actual UNIX and database settings against the
security configuration baselines.
8. Provide logging and monitoring of security related events to include the
retention of evidence of reviews performed.
9. Develop a baseline of essential security settings and specifying that baseline
as the standard to be observed.
10. Implement corrective actions to address all vulnerabilities associated with
the baseline enforcement to include removing the three default user
accounts on UNIX servers. Management agreed with the recommendations.
Fiscal Report Number Report Title Date Issued
Year
2020 OIG-20-027 RESOURCE MANAGEMENT: Audit of the 02/20
Department of the Treasury Departmental
Offices Executive Pay Adjustments,
Bonuses, and Awards
1. Office of the Deputy Assistant Secretary for Human Resources and Chief
Human Capital Officer and Office of Executive Resources calculate the
overpayment amounts for the two Departmental Office Senior Executive
Service members whose pay was set higher than allowed by regulation.
Management agreed with the recommendation.
Treasury Office of Inspector General Semiannual Report—September 2024 35
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. 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 (Uniform Guidance). Management agreed with the
recommendation.
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 Bureau of Engraving and Printing (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.
Treasury Office of Inspector General Semiannual Report—September 2024 36
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2021 OIG-21-021 FINANCIAL MANAGEMENT: 02/21
Management Report for the Audit of
the Department of the Treasury's
Consolidated Financial Statements for
Fiscal Years 2020 and 2019
1. Fiscal Service management should perform a review of the current system
environment against the Configuration Management Database to ensure
that all information system components are inventoried.
2. Perform a risk assessment over the subject matter and determine the
appropriate personnel to be responsible for monitoring and updating the
Configuration Management Database.
3. Update policy and procedures related to the above recommendations and
disseminate the documentation to enforce such policy and procedures.
Management agreed with the recommendations.
Fiscal Report Number Report Title Date Issued
Year
2021 OIG-21-026 BILL AND COIN MANUFACTURING: 04/21
Audit of Physical Security at U.S. Mint
Production Facilities (Sensitive But
Unclassified)
1.& 2. These recommendations are Sensitive But Unclassified. Management agreed
with the recommendations.
Fiscal Report Number Report Title Date Issued
Year
2022 OIG-22-005 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.
Treasury Office of Inspector General Semiannual Report—September 2024 37
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2022 OIG-22-008 DATA ACT: Treasury Submitted Higher 11/21
Quality Non-IRS Data in its Fiscal Year
2020 Third Quarter DATA Act
Submission, However Improvements are
Still Needed
1. Treasury should continue working with the Treasury Executive Office for
Asset Forfeiture to ensure proper submission of Equitable Sharing financial
assistance awards on USAspending.gov. Management agreed with the
recommendation.
Fiscal Report Number Report Title Date Issued
Year
2022 OIG-22-037 CYBERSECURITY/INFORMATION 09/22
TECHNOLOGY: Federal Information
Security Modernization Act Fiscal Year
2022 Performance Audit for the
Unclassified Systems (Sensitive But
Unclassified)
1. This recommendation is Sensitive But Unclassified. Management agreed
with the recommendation.
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-23-028 CORONAVIRUS DISEASE 2019 06/23
PANDEMIC RELIEF PROGRAMS: Audit
of Air Carrier Worker Support
Certifications - Ground Services
International, Inc.
1. The Chief Recovery Officer should review Ground Services International,
Inc.'s and Inflight Catering's requested amount for unallowable expenses,
under PSP2 and PSP3, and seek reimbursement for the overpayment, if
applicable. Management agreed with the recommendation.
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-23-030 ANTI-MONEY 08/23
LAUNDERING/TERRORIST FINANCING:
Audit of FinCEN's Management of BSA
Data - Suppression Report
1. The Director of Financial Crimes Enforcement Network (FinCen) should
require agencies that receive bulk data to remove suppressed records as a
condition of their MOUs.
Treasury Office of Inspector General Semiannual Report—September 2024 38
Statistical Summary
2. Publish and communicate guidance explaining how FinCEN will notify bulk
data agencies of records to be suppressed within bulk data files and
specifying the timelines for FinCEN and the agencies’ required actions
regarding the suppression of the records. Management agreed with the
recommendations.
Fiscal Report Number Report Title Date Issued
Year
2024 OIG-24-008 FINANCIAL MANAGEMENT: 12/23
Management Letter for the Audit of the
Department of the Treasury’s
Consolidated Financial Statements for
Fiscal Years 2023 and 2022
1. DO management should work with Administrative Resource Center (ARC)
management to include and enforce an appropriate timeline of review
requirements in the policies and procedures for ARC reviewers to perform a
timely review of posted transactions related to the Budget Roll Forward
process and other significant and complex transactions. Management
agreed with the recommendation.
Fiscal Report Number Report Title Date Issued
Year
2024 OIG-24-012 FINANCIAL MANAGEMENT: 12/23
Management Letter for the Audit of the
United States Mint’s Financial
Statements for Fiscal Years 2023 and
2022
1. Mint Management define and implement the required timeframe and process
for timely notifying Fiscal Service ARC of terminated and transferred users
with access to Oracle.
2. Enforce separation of duties principles by documenting and retaining
evidence of an independent review of users who are also performing
periodic access reviews.
3. Update relevant policies to require that an independent review of users who
are also performing periodic access reviews be documented and retained.
Management agreed with the recommendations.
Treasury Office of Inspector General Semiannual Report—September 2024 39
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2024 OIG-24-014 FINANCIAL MANAGEMENT: 12/23
Management Letter for the Audit of the
Office of the Comptroller of the
Currency’s Financial Statements for
Fiscal Years 2023 and 2022
1. The Office of the Comptroller of the Currency (OCC) should ensure the
Network General Support System (GSS) Contingency Plan is reviewed
annually and updated if changes are needed per the Master Security Control
Catalog.
2. Ensure that the GSS and the financial management system security plans
are reviewed and updated to address the following items: Identify system
interconnections. Update the incomplete, inaccurate, or inadequate
implementation statements. Identify the current system
components/subsystems in place.
3. Ensure that all financial management system database accounts are
included in the semi-annual account recertification process.
4. Recertify the financial management system users with default accounts
semi-annually in accordance with documented policies and procedures. If a
decision is made that these accounts should not be recertified, then OCC
should document a risk acceptance and identify compensating controls to
minimize the residual risk to a level acceptable by management.
5. Ensure that backup resources are available to review and approve monthly
the financial management system audits when the primary reviewer is not
available. Management agreed with the recommendations.
Fiscal Report Number Report Title Date Issued
Year
2024 OIG-24-019 FINANCIAL MANAGEMENT: 12/23
Management Letter for the Audit of the
Bureau of Engraving and Printing's
Financial Statements for Fiscal Years
2023 and 2022
1. BEP management should update Local Area Network/Wide Area Network
password configuration settings to comply with policy requirements or
formally document a risk acceptance with mitigating controls. Management
agreed with the recommendation.
Treasury Office of Inspector General Semiannual Report—September 2024 40
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2024 OIG-24-022 CYBERSECURITY/INFORMATION 01/24
TECHNOLOGY: Department of the
Treasury Federal Information Security
Modernization Act Fiscal Year 2023
Performance Audit for the Unclassified
Systems (Sensitive But Unclassified)
1.& 2. Sensitive But Unclassified. Management agreed with the recommendations.
Fiscal Report Number Report Title Date Issued
Year
2024 OIG-24-023 CYBERSECURITY/INFORMATION 12/23
TECHNOLOGY: Department of the
Treasury Federal Information Security
Modernization Act Fiscal Year 2023
Performance Audit for the Collateral
National Security Systems (Sensitive
But Unclassified)
1. Sensitive But Unclassified. Management agreed with the recommendation.
Fiscal Report Number Report Title Date Issued
Year
2024 OIG-24-025 ANTI-MONEY 03/24
LAUNDERING/TERRORIST FINANCING:
TFI’s Ukraine-/Russia-related Sanctions
Program Complied With Requirements
But Designation Decision Records Were
Not Consistently Complete and Closed
Timely
1. The Director of Office of Foreign Assets Control update the Office of Global
Targeting standard operating procedures to establish responsibilities and
expected timeframes for review of evidentiary memoranda and Office of
Foreign Assets Control’s Administrative System for Investigations and
Sanctions (OASIS) case files to ensure they are complete and closed timely.
2. Develop and implement a close-out checklist for the evidentiary memoranda
and OASIS case files that encompasses all necessary documentation to
ensure they are complete and closed timely. Management agreed with the
recommendations.
Treasury Office of Inspector General Semiannual Report—September 2024 41
Statistical Summary
Other Federal, State, and Local Entities
Fiscal Report Number Report Title Date Issued
Year
2022 OIG-22-033 REVENUE COLLECTION: The U.S. 03/22
Customs and Border Protection’s
Oversight of the Merchandise
Transported In-Bond Program Needs
Improvement to Better Ensure the
Protection of Revenue
1. Ensure Cargo Security and Controls Division (CSC) officials develop and
disseminate performance measures specific to the In-Bond Program so that
CSC, field offices, and port personnel are aware of program expectations.
These measures should be used to regularly assess port performance and
hold ports accountable.
2. Ensure CSC officials develop written procedures for CSC’s oversight of port
performance relating to the In-Bond Program to include, but not be limited
to, regular data analytics and review of Automated Commercial Environment
(ACE) reports.
3. Ensure CSC officials work with Trade Transformation Office (TTO) officials
to implement a central repository to store ACE reports, compliance
examination documentation, and other in-bond related information, including
training materials, maintained by the ports so that CSC can oversee in-bond
activity. Additionally, CSC should regularly notify field offices and ports that
these documents are available in this repository.
4. Ensure CSC officials expand the Self-Inspection Program in-bond Self-
Inspection Worksheet questions to cover key program areas, such as the
ports’ use of ACE reporting to oversee overdue in-bond shipments and
training for CBP officers on in-bond compliance examinations and audits.
5. Ensure CSC officials provide guidance to the ports on how to respond to in-
bond Self-Inspection Worksheet questions to include scenarios and the
appropriate response given those scenarios.
6. Ensure CSC officials issue policies and procedures for ports on ACE reports
they are expected to run regularly to oversee in-bond shipments and ensure
in-bonds are closed out. This should include guidance necessary to monitor
shipments in ACE as well as review proof of exports.
7. Ensure CSC officials issue policies and procedures for CSC to regularly
review the monitoring and tracking of in-bond shipments conducted by the
ports.
8. Ensure CSC officials update in-bond regulations to require a standardized
proof of export to be uploaded to ACE for all cargo exported.
Treasury Office of Inspector General Semiannual Report—September 2024 42
Statistical Summary
9. Ensure CSC officials provide TTO official’s business requirements after
regulations are updated so that TTO can update ACE to require proof of
export for closure of in-bonds that are exported.
10. Ensure Office of Trade officials, with input from CSC officials, update
regulations to support ACE functionality and data quality to modernize the
in-bond process. This includes improving the report processing time,
improving the quality of reports, and addressing Commercial Customs
Operations Advisory Committee concerns regarding the system.
11. Ensure CSC officials provide TTO officials with business requirements after
regulations are updated so that TTO can implement changes in ACE to
modernize in-bond tracking and automation processes and enhance data
quality to meet user needs.
12. Direct CSC officials to consider updating guidance on compliance
examinations to require ports to examine a statistically valid sample of in-
bond shipments so that cargo reviewed is more representative of all in-bond
shipments. Additionally, the guidance should contain instructions on waivers
of examination including documenting the justification for these waivers.
13. Ensure CSC officials provide the ports with written policies and procedures
to ensure compliance examinations are adequate and consistent. These
procedures should include selecting cargo for review, conducting
examinations, documenting the process used for the review and the results,
and storing the records.
14. Ensure CSC and TTO officials require ACE training related to the oversight of
in-bond cargo for all CBP officers.
15. Ensure the Commercial Operations Revenue & Entry Division coordinates
with the Revenue Division and CSC officials to improve custodial bonding to
address the risks of merchandise transported in-bond and update CBP’s
bonding policy. The policy should improve the connectivity between in-bond
shipments and respective duties, taxes, and fees by considering estimated
duties when determining the appropriate bond coverage. Management
agreed with the recommendations
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-23-025 FINANCIAL MANAGEMENT: Audit of 05/23
the Gulf Coast Ecosystem Restoration
Council's Compliance with PIIA of
2019 for Fiscal Year 2022
1. The Gulf Coast Ecosystem Restoration Council should consult OMB’s
Payment Integrity Annual Data Call Instructions or its subsequent revisions
to determine how to report its payment integrity information.
2. Review payment integrity information submitted to the OMB Annual Data
Call for accuracy prior to live publication to ensure accuracy of data
reported. Management agreed with the recommendations.
Treasury Office of Inspector General Semiannual Report—September 2024 43
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-018 Desk Review of Chippewa Cree Tribe’s 06/23
Use of Coronavirus Relief Fund
Proceeds
1. Treasury OIG should pursue obtaining documentation from the Chippewa
Cree Tribe's management and ensure reporting corrections are made within
the GrantSolutions portal. Further, based on Chippewa Cree Tribe's
responsiveness to Treasury OIG’s requests and its ability to provide
documentation, Treasury OIG should determine if a focused audit is feasible
for grants greater than or equal to $50,000 and direct payments greater
than or equal to $50,000. Management agreed with the recommendation.
($75,091 Questioned Costs)
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-024 Desk Review of Lancaster County, 06/23
Pennsylvania’s Use of Coronavirus
Relief Fund Proceeds
1. Treasury OIG should pursue obtaining documentation from Lancaster County
personnel and ensure reporting corrections are made. Further, based on
Lancaster County’s responsiveness to Treasury OIG’s requests and its ability
to provide documentation, Treasury OIG should determine if a full-scope
audit is feasible. Management agreed with the recommendation.
($38,793,071 Questioned Costs)
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-025 Desk Review of State of California’s 07/23
Use of Coronavirus Relief Fund
Proceeds
1. Treasury OIG should confirm that appropriate corrections have been made,
or if not, determine whether the ineligible expenditures have been returned
to Treasury. Management agreed with the recommendation.
($6,952 Questioned Costs)
Treasury Office of Inspector General Semiannual Report—September 2024 44
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-026 Desk Review of Turtle Mountain Band 07/23
of Chippewa Indians’ Use of
Coronavirus Relief Fund Proceeds
(Redacted)
1. Treasury OIG should pursue obtaining supporting documentation from the
Turtle Mountain Band of Chippewa Indians’ (TMBCI) personnel and ensure
reporting corrections are made. Further, based on TMBCI’s responsiveness to
Treasury OIG’s requests and its ability to provide documentation, Treasury
OIG should determine if a full-scope audit is feasible. ($32,333,620
Questioned Costs)
2. Follow-up with TMBCI personnel to obtain sufficient support to quantify
expenditures related to these allegations and determine whether the amounts
represent eligible Coronavirus Relief Fund (CRF) costs. Management agreed
with the recommendations.
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-027 Desk Review of Los Angeles County, 07/23
California’s Use of Coronavirus Relief
Fund Proceeds
1. Treasury OIG should pursue obtaining documentation from LA County
management and ensure reporting corrections are made. Further, based on
LA County’s responsiveness to Treasury OIG’s requests and its ability to
provide documentation, Treasury OIG should determine if a focused audit is
feasible over LA County’s contracts greater than or equal to $50,000 and
aggregate reporting less than $50,000. Management agreed with the
recommendation. ($249,052,032 Questioned Costs)
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-028 Desk Review of City of Dallas, Texas’ 07/23
Use of Coronavirus Relief Fund
Proceeds
1. Treasury OIG pursue obtaining documentation from Dallas management
related to the aggregate payments to individuals and ensure that
expenditures reported are properly supported. Further, based on Dallas’
responsiveness to Treasury OIG’s requests and its ability to provide
documentation, we recommend Treasury OIG determine if a focused audit on
aggregate payments to individuals is feasible. Management agreed with the
recommendation. ($2,211,594 Questioned Costs)
Treasury Office of Inspector General Semiannual Report—September 2024 45
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-029 Desk Review of State of Florida’s Use 07/23
of Coronavirus Relief Fund Proceeds
1. Treasury OIG should pursue obtaining missing documentation from Florida
management and ensure reporting corrections are made, or whether
recoupment of funds is necessary. Further, based on Florida's
responsiveness to Treasury OIG's requests and its ability to provide
sufficient documentation, Treasury OIG should determine if a full-scope audit
over Florida's use of its CRF proceeds is feasible. Management agreed with
the recommendation. ($893,154,358 Questioned Costs)
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-030 Desk Review of San Bernardino County, 07/23
California’s Use of Coronavirus Relief
Fund Proceeds
1.-3. San Bernardino County management should provide missing supporting
documentation and make necessary reporting corrections. Additionally,
Treasury OIG should determine if a focused audit over grants greater than or
equal to $50,000 is feasible. Management agreed with the
recommendations. ($4,151,612 Questioned Costs)
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-032 Desk Review of Phoenix, Arizona’s Use 07/23
of Coronavirus Relief Fund Proceeds
1. Treasury OIG follow-up with Phoenix management on the finalization of its
reconciliation and reporting corrections. Based on Phoenix management’s
responsiveness to Treasury OIG’s requests, and its ability to provide
sufficient documentation, we recommend that Treasury OIG determine if a
focused audit is feasible for grants greater than or equal to $50,000.
Management agreed with the recommendation. ($147,379 Questioned
Costs)
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-033 Desk Review of Pleasant Point Indian 07/23
Reservation, Maine’s Use of
Coronavirus Relief Fund Proceeds
1. Treasury OIG follow-up on necessary reporting corrections for contracts
greater than or equal to $50,000, transfers greater than or equal to
$50,000, and aggregate payments to individuals. Management agreed with
the recommendation. ($339,672 Questioned Costs)
Treasury Office of Inspector General Semiannual Report—September 2024 46
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-034 Desk Review of State of Texas’ Use of 07/23
Coronavirus Relief Fund Proceeds
1. Treasury OIG obtain documentation from Texas management and follow-up
on necessary reporting corrections. Further, based on Texas’ responsiveness
to Treasury OIG’s requests and its ability to provide sufficient
documentation, we recommend Treasury OIG determine if a focused audit is
feasible for contracts greater than or equal to $50,000 and grants greater
than or equal to $50,000. Management agreed with the recommendation.
($17,288,575 Questioned Costs)
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-035 Desk Review of the State of 07/23
Tennessee’s Use of Coronavirus Relief
Fund Proceeds
1. Treasury OIG should pursue obtaining documentation from Tennessee
personnel and ensure reporting corrections are made. Further, based on
Tennessee's responsiveness to Treasury OIG's requests and its ability to
provide documentation and remove ineligible transactions, Treasury OIG
should determine if a focused audit is feasible for grants greater than or
equal to $50,000 and aggregate payments to individuals. Management
agreed with the recommendation. ($1,162,364 Questioned Costs)
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-037 Desk Review of State of Ohio’s Use of 07/23
Coronavirus Relief Fund Proceeds
1.& 2. State of Ohio management should provide missing supporting documentation
and make necessary reporting corrections.
3. Provide missing supporting documentation and make necessary reporting
corrections. Additionally, Treasury OIG should obtain information to
determine if there are other ineligible severance pay transactions in addition
to those already identified as part of the desk review. Management agreed
with the recommendations. ($86,801 Questioned Costs)
Treasury Office of Inspector General Semiannual Report—September 2024 47
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-038 Desk Review of Native Village of Point 07/23
Hope’s Use of Coronavirus Relief Fund
Proceeds
1. Treasury OIG follow-up on the missing documentation and make a
determination whether to conduct a full-scope audit of Point Hope. In
addition, Treasury OIG personnel determine whether to take further action,
up to and including recoupment of Point Hope’s CRF proceeds, based on the
scope limitation and potential noncompliance with the records retention
requirement. Management agreed with the recommendation. ($2,348,064
Questioned Costs)
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-039 Desk Review of the Commonwealth of 08/23
the Northern Mariana Islands’ Use of
Coronavirus Relief Fund Proceeds
1. Treasury OIG should request missing documentation from the
Commonwealth of the Northern Mariana Islands management and follow-up
on necessary reporting corrections. Further, based on Commonwealth of the
Northern Mariana Islands responsiveness to Treasury OIG’s requests and its
ability to provide sufficient documentation, Treasury OIG should determine if
a full scope audit is feasible. Management agreed with the recommendation.
($11,146,813 Questioned Costs)
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-040 Desk Review of the Commonwealth of 08/23
Puerto Rico’s Use of Coronavirus Relief
Fund Proceeds
1. Treasury OIG should follow-up to obtain the status of these Single Audits.
Treasury OIG should pursue obtaining missing documentation from Puerto
Rico’s management and follow-up on necessary reporting corrections within
the GrantSolutions portal. Based on Puerto Rico’s responsiveness to
Treasury OIG’s requests and management’s ability to provide
documentation, Treasury OIG should determine if a full scope audit is
feasible. Management agreed with the recommendation. ($33,681,692
Questioned Costs)
Treasury Office of Inspector General Semiannual Report—September 2024 48
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-041 Desk Review of Navajo Nation Tribal 08/23
Government's Use of Coronavirus Relief
Fund Proceeds (Redacted)
1. Treasury OIG should follow-up on Navajo Nation management's corrective
action related to $141,187 in questioned costs reported in Single Audit
finding number 2020-009.
2. Follow-up to obtain the status of the Navajo Nation's 2021 Single Audit.
3.-5. Follow-up with Navajo Nation management to obtain missing documentation
to support expenditures and that Navajo Nation has made necessary
reporting corrections; and determine the feasibility of performing a focused
audit for grants greater than or equal to $50,000.
6. Follow-up with Navajo Nation management to obtain missing documentation
to support expenditures and that Navajo Nation has made necessary
reporting corrections; and determine the feasibility of performing a focused
audit for aggregate payments to individuals with a specific focus on Navajo
Nation's non-payroll COVID-19 hardship claims and payroll expenditures for
employees substantially dedicated to COVID-19 recovery efforts.
($80,844,219 Questioned Costs)
7. Confirm that Navajo Nation management has reversed $(Amount Redacted)
in duplicate hardship check payments that were fraudulently cashed by tribal
citizens and recorded by management within the aggregate payments to
individuals payment type in the Cycle 3 GrantSolutions submission.
8. Ensure Navajo Nation management re-issued $(Amount Redacted) stale-
dated checks before the end of December 31, 2022, and ensure that checks
were cashed by the beneficiaries, or funds are returned to Treasury.
9. Ensure Navajo Nation management has reversed the sub-recipient incurred
costs that they determined to be ineligible as a result of their internal
investigation. Management agreed with the recommendations.
Treasury Office of Inspector General Semiannual Report—September 2024 49
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2023 OIG-CA-23-042 Desk Review of the Commonwealth of 08/23
Virginia’s Use of Coronavirus Relief
Fund Proceeds
1. Treasury OIG should follow-up with the Commonwealth of Virginia (Virginia)
management on necessary reporting corrections. Specifically, Items Not
Listed Above description corrections are needed in the contracts greater than
or equal to $50,000, grants greater than or equal to $50,000, transfers
greater than or equal to $50,000, and direct payments greater than or equal
to $50,000 payment types. In addition, Treasury OIG should pursue
obtaining documentation from Virginia management for contracts greater
than or equal to $50,000, transfers greater than or equal to $50,000, direct
payments greater than or equal to $50,000, aggregate reporting less than
$50,000, and aggregate payments to individuals. Based on Virginia’s
responsiveness to Treasury OIG’s requests and its ability to provide
documentation, Treasury OIG should determine if a focused audit is feasible
for contracts, transfers, and direct payments greater than or equal to
$50,000, as well as aggregate reporting less than $50,000 and aggregate
payments to individuals. In addition, Treasury OIG should work with Virginia
management to determine whether there are any additional costs attributable
to Virginia Department of Emergency Management and Virginia Department
of Health and to ensure that Virginia management makes any necessary
corrections to those balances. Also, Treasury OIG should follow-up to obtain
the status of the 2021 Single Audit Annual Comprehensive Financial Report
finding. Management agreed with the recommendation. ($870,559,763
Questioned Costs)
Fiscal Report Number Report Title Date Issued
Year
2024 OIG-CA-24-003 City of Springfield, Massachusetts – 10/23
Use of Coronavirus Relief Fund
Proceeds
1. Treasury’s Acting Chief Recovery Officer should work with Treasury OIG to
obtain adequate documentation from the Commonwealth of Massachusetts
for the Department of Health and Human Services $300,000 in expenditures
or begin recoupment proceedings for the disallowed costs. Management
agreed with the recommendation. ($300,000 Questioned Costs)
Treasury Office of Inspector General Semiannual Report—September 2024 50
Statistical Summary
Fiscal Report Number Report Title Date Issued
Year
2024 OIG-CA-24-015 Inquiry on Revolving Door Between the 03/24
Largest Accounting Firms and the
Department of the Treasury
1. As expeditiously as possible, Treasury's Office of the Assistant General
Counsel for General Law, Ethics and Regulation (GLER) should consider
completing a cost-benefit analysis to determine if a fully integrated and
automated tracking system would benefit GLER with its ethics
responsibilities.
2. Develop and implement standard operating procedures, including monitoring,
to ensure ethics officials fully utilize the Ethics Tracker database to track
requests, substantive advice and counsel provided, as well as documentation
of final resolution of issues. Management agreed with the recommendations.
Fiscal Report Number Report Title Date Issued
Year
2024 OIG-24-026 REVENUE COLLECTION: CBP Needs to 03/24
Enhance its Monitoring and Tracking of
the Outcomes of Investigations into
the Underpayment of Duties
1. U.S. Customs and Border Protection (CBP) Commissioner should ensure the
Office of Chief Counsel establishes documented policies for processing
delinquent duty, liquidated damage, and penalty cases, and include its
organization structure, roles and responsibilities, and delegations of
authority.
2. Ensure Office of Trade (OT) and Office of Field Operations (OFO) officials
assess the need for performance metrics once the Commercial Enforcement
Analysis and Response (CEAR) standard operating procedures (SOP) are
updated.
3. Ensure OT and OFO officials responsible for oversight of the CEAR process
review and update the CEAR SOP to ensure the SOPs continue to be
relevant and effective in meeting objectives and addressing risks.
4. Ensure OT and OFO officials responsible for oversight of the CEAR process
monitor referrals made to Immigration and Customs Enforcement Homeland
Security Investigations (ICE HSI) and ensure established mechanisms to
track ICE HSI referrals are followed.
5. Ensure Trade Remedy Law Enforcement Directorate (TRLED) staff
coordinates with appropriate internal offices to track revenue recovered from
the e-Allegations program and uses the information to evaluate the
program’s performance in achieving objectives.
Treasury Office of Inspector General Semiannual Report—September 2024 51
Statistical Summary
6. Ensure that TRLED officials enhance procedures to ensure that the statuses
of e-Allegations cases are timely, accurate, and complete in its information
system, Analysis and Referral Management system; monitor those
procedures to ensure that they are working as intended; and assess the need
for related training. Management agreed with the recommendations.
Closed Investigations of Senior Government Employees Not
Publicly Disclosed
April 1, 2024, through September 30, 2024
Treasury OIG closed 2 investigations involving senior Government employees during
the period that were not publicly disclosed. Both substantiated an instance of
misconduct against a senior Government employee.
Allegation/Disposition
On July 18, 2024, Treasury OIG completed its report of investigation for a case
initiated from an anonymous complaint which alleged, in or around 2016, an Office of
the Comptroller of the Currency (OCC) employee failed to notify the OCC of a
residential relocation in order to submit inflated mileage on expense reports and charge
the OCC for travel expenses for one location while residing in another. Treasury OIG’s
investigation determined the employee had some questionable expenses, including
instances of erroneous mileage claims totaling $867.62 in overpayments between
2015 and 2017. Treasury OIG provided its initial findings to the OCC Travel Policy and
Operations Department for review. OCC determined Treasury OIG’s findings were
accurate. Information provided by OCC was discussed with the OIG Office of Counsel
and a decision was made to refer the matter to OCC for appropriate action. This
matter was not referred to the Department of Justice.
Substantiated
On July 22, 2024, Treasury OIG completed its investigation of a case initiated upon
receipt of information from the OCC expressing concerns regarding the handling and
potential compromise of OCC Information Technology (IT) equipment provided to a
Senior OCC employee for international travel. The OIG substantiated that the OCC
employee violated OCC IT policies based on forensic examinations. The Report of
Investigation was provided to OCC for their information. This matter was not referred
to the Department of Justice.
Substantiated
Treasury Office of Inspector General Semiannual Report—September 2024 52
Statistical Summary
Trafficking Victims Prevention and Protection Reauthorization
Act of 2022
April 1, 2024, through September 30, 2024
Number of Suspected Violation Reported: 0
Number of Investigations: 0
Status and Outcome of Investigations: N/A
Recommended Actions to Improve: None
No-Knock Entry Reporting
Per Executive Order (EO) 14074, Section 10(c), the heads of Federal Law Enforcement
Agencies shall issue annual reports to the President—and post the reports publicly—
setting forth the number of no-knock entries that occurred pursuant to judicial
authorization; the number of no-knock entries that occurred pursuant to exigent
circumstances; and disaggregated data by circumstances for no-knock entries in which
a law enforcement officer or other person was injured in the course of a no-knock
entry.
Pursuant to EO 14074, Section 10(c), no such entries occurred during this reporting
period.
Summary of Instances of Whistleblower Retaliation
April 1, 2024, through September 30, 2024
There was one new case of possible whistleblower retaliation opened during this
reporting period.
Treasury Office of Inspector General Semiannual Report—September 2024 53
Statistical Summary
Summary of Attempts to Interfere With Treasury OIG
Independence, Including Instances Where Information or
Assistance Request was Refused
April 1, 2024, through September 30, 2024
There were no attempts made to resist, delay, or restrict Treasury OIG access to
records or other information and no instances where an information or assistance
request was refused during this reporting period.
Treasury Office of Inspector General Semiannual Report—September 2024 54
Statistical Summary
Listing of Audit Products Issued
April 1, 2024, through September 30, 2024
Office of Audit
Report Title Report Number
May 2024
BILL AND COIN MANUFACTURING: The Mint OIG-24-027
Needs to Enhance Controls over Gold
Acquisitions
FINANCIAL MANAGEMENT: Audit of the Gulf OIG-24-028
Coast Ecosystem Restoration Council's
Compliance with PIIA of 2019 for Fiscal Year
2023
FINANCIAL MANAGEMENT: Audit of the OIG-24-029
Treasury’s Compliance with the PIIA
Requirements for fiscal Year 2023
Overseas Contingency Operations - Summary OIG-CA-24-017
of Work Performed by the Department of the
Treasury Related to Terrorist Financing and
Anti-Money Laundering for the Second Quarter
Fiscal Year 2024
Report Title Report Number
July 2024
Semi-Annual Joint Purchase and Integrated OIG-CA-24-018
Card Violation Report (October 1, 2023 -
March 31, 2024) Internal Memorandum -
Internal Memorandum
Emergency Rental Assistance (ERA1) Program OIG-CA-24-020
Notice of Recoupment - State of Missouri
(Redacted)
CYBERSECURITY/INFORMATION OIG-CA-24-021
TECHNOLOGY: The Gulf Coast Ecosystem
Restoration Council Federal Information
Treasury Office of Inspector General Semiannual Report—September 2024 55
Statistical Summary
Security Modernization Act of 2014 Evaluation
Report for Fiscal Year 2024
Report Title Report Number
August 2024
Desk Review of Bucks County, Pennsylvania’s OIG-CA-24-019
Use of Coronavirus Relief Fund Proceeds
ANTI-MONEY LAUNDERING/TERRORIST OIG-24-030
FINANCING: Audit of FinCEN's Management of
BSA Data - User Access Report
Emergency Rental Assistance Program (ERA2) - OIG-CA-24-022
Questioned Cost Finding, State of Michigan
(Redacted)
Emergency Rental Assistance (ERA1) Program OIG-CA-24-023
Notice of Recoupment - Thurston County,
Washington (Redacted)
Emergency Rental Assistance (ERA1) Program OIG-CA-24-024
Notice of Recoupment - State of Washington
(Redacted)
U.S. Treasury’s Role with the Customs OIG-CA-24-025
Revenue Function – Trade Facilitation and
Trade Enforcement Act of 2015, Section 112
Report Title Report Number
September 2024
Overseas Contingency Operations - Summary OIG-CA-24-026
of Work Performed by the Department of the
Treasury Related to Terrorist Financing and
Anti-Money Laundering for the Third Quarter
Fiscal Year 2024
FINANCIAL MANAGEMENT: Report on the OIG-24-031
Enterprise Applications' Description of its
HRConnect System and the Suitability of the
Design and Operating Effectiveness of its
Controls for the Period July 1, 2023 to June
30, 2024
Treasury Office of Inspector General Semiannual Report—September 2024 56
Statistical Summary
GOVERNMENT-WIDE FINANCIAL SERVICES: OIG-24-032
Audit of Direct Express Program Disputes
Related to Certain Cardholder Accounts
CYBERSECURITY/INFORMATION OIG-CA-24-027
TECHNOLOGY: Assessment of the Department
of the Treasury’s Incident Response Reporting
Process for Select Incidents (Sensitive But
Unclassified) Not Publicly Disclosed
CYBERSECURITY/INFORMATION OIG-24-033
TECHNOLOGY: Department of the Treasury
Federal Information Security Modernization Act
Fiscal Year 2024 Performance Audit for the
Collateral National Security Systems (Sensitive
But Unclassified) Not Publicly Disclosed
CYBERSECURITY/INFORMATION OIG-24-034
TECHNOLOGY: Department of the Treasury
Federal Information Security Modernization Act
Fiscal Year 2024 Performance Audit for the
Unclassified Systems (Sensitive But
Unclassified) Not Publicly Disclosed
FINANCIAL REGULATION AND OVERSIGHT: OIG-24-035
Audit of the Department of the Treasury’s
Compliance with the Geospatial Data Act of
2018
Desk Review of Bergen County, New Jersey’s OIG-CA-24-028
Use of Coronavirus Relief Fund Proceeds
CORONAVIRUS DISEASE 2019 PANDEMIC OIG-24-036
RELIEF PROGRAMS: Audit of Treasury’s
Soundness of Investment Decisions for
Participation in the Emergency Capital
Investment Program
CORONAVIRUS DISEASE 2019 PANDEMIC OIG-24-037
RELIEF PROGRAMS: Audit of the Community
Development Financial Institutions Fund’s
Award and Post-Award Administration of the
CDFI Equitable Recovery Program
CORONAVIRUS DISEASE 2019 PANDEMIC OIG-24-038
RELIEF PROGRAMS: Audit of Air Carrier
Treasury Office of Inspector General Semiannual Report—September 2024 57
Statistical Summary
Worker Support Certifications - Flight Group
Corporation (Redacted)
CORONAVIRUS DISEASE 2019 PANDEMIC OIG-24-039
RELIEF PROGRAMS: Audit of Air Carrier
Worker Support Certifications - Freight Runners
Express, Inc. (Redacted)
CORONAVIRUS DISEASE 2019 PANDEMIC OIG-24-040
RELIEF PROGRAMS: Audit of Air Carrier
Worker Support Certifications - Prosegur
Services Group, Inc. (Redacted)
CORONAVIRUS DISEASE 2019 PANDEMIC OIG-24-041
RELIEF PROGRAMS: Audit of Air Carrier
Worker Support Certifications - Wing Aviation
Charter Services, LLC (Redacted)
CORONAVIRUS DISEASE 2019 PANDEMIC OIG-24-042
RELIEF PROGRAMS: Audit of Air Carrier
Worker Support Certifications - Superior
Transportation Associates, Inc. (Redacted)
CORONAVIRUS DISEASE 2019 PANDEMIC OIG-24-043
RELIEF PROGRAMS: Audit of Air Carrier
Worker Support Certifications - Prospect
Airport Services, Inc. (Redacted)
CORONAVIRUS DISEASE 2019 PANDEMIC OIG-24-044
RELIEF PROGRAMS: Audit of Air Carrier
Worker Support Certifications - One Sky Flight,
LLC (Redacted)
CORONAVIRUS DISEASE 2019 PANDEMIC OIG-24-045
RELIEF PROGRAMS: Audit of Air Carrier
Worker Support Certifications - Suburban Air
Freight, Inc. (Redacted)
Desk Review of Emergency Rental Assistance OIG-CA-24-029
Payments Made by the City of Houston, TX
and Harris County, TX
CYBERSECURITY/INFORMATION OIG-24-046
TECHNOLOGY: Fiscal Year 2023 Audit of the
Department of the Treasury's Information
Security Program and Practices for Its
Treasury Office of Inspector General Semiannual Report—September 2024 58
Statistical Summary
Intelligence Systems (CLASSIFIED, NOT
PUBLICLY DISCLOSED)
CYBERSECURITY/INFORMATION OIG-24-047
TECHNOLOGY: Fiscal Year 2024 Audit of the
Department of the Treasury's Information
Security Program and Practices for Its
Intelligence Systems (CLASSIFIED, NOT
PUBLICLY DISCLOSED)
Council of Inspectors General on Financial Oversight
Report Title Report Number
July 2024
Annual Report of the Council of Inspectors No Report Number
General on Financial Oversight (July 2024)
Treasury Office of Inspector General Semiannual Report—September 2024 59
Statistical Summary
Audit Reports Issued With Questioned Costs
April 1, 2024, through September 30, 2024
Total Total
Total No. Questioned Unsupported
Category of Reports Costs Costs
For which no management decision had been made
by beginning of reporting period 23 $2,237,950,475 $2,237,950,475
Which were issued during the reporting period 9 $992,965 $992,965
Subtotals 32 $2,238,943,440 $2,238,943,440
For which a management decision was made during
the reporting period 7 $454,489 $454,489
Dollar value of disallowed costs 7 $454,489 $454,489
Dollar value of costs not disallowed 0 $0 $0
For which no management decision was made by
the end of the reporting period 25 $2,238,488,951 $2,238,488,951
For which no management decision was made
within 6 months of issuance 19 $2,237,683,671 $2,237,683,671
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 2024 60
Statistical Summary
Audit Reports Issued With Recommendations that Funds Be Put
to Better Use
April 1, 2024, through September 30, 2024
Total
No. of Revenue
Category Reports Total Savings Enhancement
For which no management decision had been
made by beginning of reporting period 0 $0 $0 $0
Which were issued during the reporting
period 0 $0 $0 $0
Subtotals 0 $0 $0 $0
For which a management decision was made
during the reporting period 0 $0 $0 $0
Dollar value of recommendations agreed to
by management 0 $0 $0 $0
Dollar value based on proposed
management action 0 $0 $0 $0
Dollar value based on proposed
legislative action 0 $0 $0 $0
Dollar value of recommendations not
agreed to by management 0 $0 $0 $0
For which no management decision was
made by the end of the reporting period 0 $0 $0 $0
For which no management decision was
made within 6 months of issuance 0 $0 $0 $0
A recommendation that funds be put to better use denotes funds could be used more efficiently if management took
actions to implement and complete the recommendation including: (1) reduction in outlays; (2) de-obligations of
funds from programs or operations; (3) costs not incurred by implementing recommended improvements related to
operations; (4) avoidance of unnecessary expenditures noted in pre-award review of contract or grant agreements;
(5) any other savings which are specifically identified; or (6) enhancements to revenues of the Federal Government.
Treasury Office of Inspector General Semiannual Report—September 2024 61
Statistical Summary
Reports for Which No Management Comment was Returned
Within 60 Days
As of September 30, 2024
There were no such reports issued for comment over 60 days as of the end of the
reporting period.
Reports Issued Over 6 Months for Which No Management
Decision Has Been Made
As of September 30, 2024
As of the end of this semiannual reporting period, Treasury and OIG management had
not decided on recommendations with monetary benefits for 19 reports issued over 6
months:
Desk Review of Chippewa Cree Tribe’s Use of Coronavirus Relief Fund Proceeds
(OIG-CA-23-018, 6/26/2023) $75,091 Questioned Costs
Desk Review of Lancaster County, Pennsylvania’s Use of Coronavirus Relief Fund
Proceeds (OIG-CA-23-024, 6/29/2023) $38,793,071 Questioned Costs
Desk Review of State of California’s Use of Coronavirus Relief Fund Proceeds
(OIG-CA-23-025, 7/7/2023) $6,952 Questioned Costs
Desk Review of Turtle Mountain Band of Chippewa Indians’ Use of Coronavirus Relief
Fund Proceeds (Redacted) (OIG-CA-23-026, 7/7/2023) $32,333,620 Questioned
Costs
Desk Review of Los Angeles County, California’s Use of Coronavirus Relief Fund
Proceeds (OIG-CA-23-027, 7/7/2023) $249,052,032 Questioned Costs
Desk Review of City of Dallas, Texas’ Use of Coronavirus Relief Fund Proceeds
(OIG-CA-23-028, 7/20/2023) $2,211,594 Questioned Costs
Treasury Office of Inspector General Semiannual Report—September 2024 62
Statistical Summary
Desk Review of State of Florida’s Use of Coronavirus Relief Fund Proceeds
(OIG-CA-23-029, 7/20/2023) $893,154,358 Questioned Costs
Desk Review of San Bernardino County, California’s Use of Coronavirus Relief Fund
Proceeds (OIG-CA-23-030, 7/20/2023) $4,151,612 Questioned Costs
Desk Review of Phoenix, Arizona’s Use of Coronavirus Relief Fund Proceeds
(OIG-CA-23-032, 7/21/2023) $147,379 Questioned Costs
Desk Review of Pleasant Point Indian Reservation, Maine’s Use of Coronavirus Relief
Fund Proceeds (OIG-CA-23-033, 7/21/2023) $339,672 Questioned Costs
Desk Review of State of Texas’ Use of Coronavirus Relief Fund Proceeds
(OIG-CA-23-034, 7/21/2023) $17,288,575 Questioned Costs
Desk Review of the State of Tennessee’s Use of Coronavirus Relief Fund Proceeds
(OIG-CA-23-035, 7/26/2023) $1,162,364 Questioned Costs
Desk Review of State of Ohio’s Use of Coronavirus Relief Fund Proceeds
(OIG-CA-23-037, 7/27/2023) $86,801 Questioned Costs
Desk Review of Native Village of Point Hope’s Use of Coronavirus Relief Fund
Proceeds (OIG-CA-23-038, 7/28/2023) $2,348,064 Questioned Costs
Desk Review of the Commonwealth of the Northern Mariana Islands Use of
Coronavirus Relief Fund Proceeds (OIG-CA-23-039, 8/8/2023) $11,146,813
Questioned Costs
Desk Review of the Commonwealth of Puerto Rico’s Use of Coronavirus Relief Fund
Proceeds (OIG-CA-23-040, 8/8/2023) $33,681,692 Questioned Costs
Desk Review of Navajo Nation Tribal Government’s Use of Coronavirus Relief Fund
Proceeds (Redacted) (OIG-CA-23-041, 8/8/2023) $80,844,218 Questioned Costs
Desk Review of the Commonwealth of Virginia’s Use of Coronavirus Relief Fund
Proceeds (OIG-CA-23-042, 8/9/2023) $870,559,763 Questioned Costs
City of Springfield, Massachusetts - Use of Coronavirus Relief Fund Proceeds
(OIG-CA-24-003, 10/17/2023) $300,000 Questioned Costs
Treasury Office of Inspector General Semiannual Report—September 2024 63
Statistical Summary
Significant Revised Management Decisions
April 1, 2024, through September 30, 2024
There were no significant revised management decisions during the reporting period.
Significant Disagreed Management Decisions
April 1, 2024, through September 30, 2024
There were no significant disagreed management decisions during the reporting period.
Peer Reviews
April 1, 2024, through September 30, 2024
Office of Audit
Audit organizations that perform audits and attestation engagements of Federal
Government programs and operations are required by generally accepted government
auditing standards to undergo an external peer review every 3 years. The objectives of
an external peer review are to determine, during the period under review, whether the
audit organization was complying with its quality control system to provide the audit
organization with reasonable assurance that it was conforming to applicable
professional standards. Federal audit organizations can receive a peer review rating of
Pass, Pass with Deficiencies, or Fail.
The most recent peer review of our office was performed by the U.S. Department of
Health and Human Services (HHS) OIG. In its report dated September 27, 2021, HHS
OIG rendered a Pass rating for our system of quality control in effect for the year
ended March 31, 2021. External audit peer review reports of our office are available
on Treasury OIG’s website.
The U.S. Department of Energy OIG’s review of our office’s system of quality control
in effect for the year ended March 31, 2024, was ongoing as of the end of the
reporting period. Treasury OIG’s review of the U.S. Environmental Protection Agency
Treasury Office of Inspector General Semiannual Report—September 2024 64
Statistical Summary
OIG’s system of quality control as of September 30, 2023, was also ongoing as of the
end of the reporting period.
Office of Investigations
Council of the Inspectors General on Integrity and Efficiency (CIGIE) mandates that the
investigative law enforcement operations of all OIGs undergo peer reviews every
3 years to ensure compliance with (1) Council of the Inspectors General on Integrity
and Efficiency investigations quality standards and (2) the relevant guidelines
established by the Office of the Attorney General of the United States.
In its report dated January 5, 2021, the Federal Housing Finance Agency OIG found
our office to be in compliance with all relevant guidelines for fiscal year 2020. During
this reporting period, our office did not perform a peer review of another OIG.
Treasury Office of Inspector General Semiannual Report—September 2024 65
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.
During this reporting period, there were no banks supervised by the OCC that
failed.
Operation Inherent Resolve Quarterly Summary Memorandums to the
Department of Defense OIG
During this reporting period, we issued two summary memorandums to the
Department of Defense OIG regarding information we obtained on the
Department of the Treasury’s (Treasury) activities with respect to disrupting the
Islamic State of Iraq and Syria’s (ISIS) finances. The memorandums included
specific examples of activities to disrupt ISIS’s financing, information on
Treasury Office of Inspector General Semiannual Report—September 2024 66
Other Reporting Requirements and Requests
Treasury programs that combat terrorist financing, and work we performed or
plan to perform to review these programs. (OIG-CA-24-017, OIG-CA-24-026)
Treasury Office of Inspector General Semiannual Report—September 2024 67
References to the Inspector General Act
Section Requirement Page
Section Review of legislation and regulations 31
404(a)(2)
Section Significant problems, abuses, and deficiencies 5-29
405(b)(1)
Section Recommendations with respect to significant problems, abuses, and deficiencies 5-29
405(b)(2)
Section Significant unimplemented recommendations described in previous semiannual 32-52
405(b)(3) reports
Section Matters referred to prosecutive authorities 31
405(b)(4)
Section Summary of instances where information was refused 53
406(c)(2)
Section List of audit reports 55-59
405(b)(6)
Section Summary of significant reports 5-29
405(b)(7)
Section Audit reports with questioned costs 60
405(b)(8)
Section Recommendations that funds be put to better use 61
405(b)(9)
Section Summary of each audit, inspection, and evaluation report issued before the 32-52
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 62
405(b)(10)(B) management comment was returned within 60 days
Section Summary of each audit, inspection, and evaluation report issued before the 62-63
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 64
405(b)(12)
Section Instances of unresolved Federal Financial Management Improvement Act 22
405(b)(13) noncompliance
Section Results of peer reviews conducted of Treasury OIG by another OIG 64-65
405(b)(14)
Section List of outstanding recommendations from peer reviews 64-65
405(b)(15)
Section List of peer reviews conducted by Treasury OIG, including a list of outstanding 64-65
405(b)(16) recommendations from those peer reviews
Section Statistics for the period related to the number of (A) investigative reports issued, 31
405(b)(17)(A- (B) persons referred to the Department of Justice for criminal prosecution,
D) (C) persons referred to state and local authorities for criminal prosecution, and
(D) criminal indictments/informations
Section Description of metrics used to develop investigative statistics 31
405(b)(18)
Section Summary of each investigation involving a senior Government employee where 52
405(b)(19) allegation of misconduct was substantiated
Treasury Office of Inspector General Semiannual Report—September 2024 68
References to the Inspector General Act
Section Instances of whistleblower retaliation 53
405(b)(20)
Section Summary of attempts to interfere with Treasury OIG independence 54
405(b)(21)
Section Description of each inspection, evaluation, and audit that was closed and not 55-59
405(b)(22)(A) publicly disclosed
Section Description of each investigation closed, involving a senior Government employee, 52
405(b)(22)(B) that was not publicly disclosed
Section 405(e) Serious or flagrant problems, abuses, or deficiencies N/A
Section Report to Secretary when information or assistance is unreasonably refused 54
406(c)(2)
Treasury Office of Inspector General Semiannual Report—September 2024 69
Abbreviations
Abbreviations
ACE Automated Commercial Environment
ARC Administrative Resource Center
ARP American Rescue Plan of 2021
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
CBP U.S. Customs and Border Protection’s
CDFI Community Development Financial Institution
CDFI ERP CDFI Equitable Recovery Program
CEAR Commercial Enforcement Analysis and Response
CFR Code of Federal Regulations
Council Gulf Coast Ecosystem Restoration Council
COVID-19 Coronavirus Disease 2019
CRF Coronavirus Relief Fund
CSC Cargo Security and Controls Division
DATA Act Digital Accountability and Transparency Act of 2014
DHS Department of Homeland Security
DIF Deposit Insurance Fund
DO Departmental Offices
ECIP Emergency Capital Investment Program
EIDL Economic Injury and Disaster Loan
EO Executive Order
ERA1 Emergency Rental Assistance
ERA2 Emergency Rental Assistance
ERAP Emergency Rental Assistance Program
FAA financial agency agreement
FBI Federal Bureau of Investigation
FDIC Federal Deposit Insurance Corporation
FinCEN Financial Crimes Enforcement Network
Fiscal Service Bureau of the Fiscal Service
FISMA Federal Information Security Modernization Act of 2014
FY fiscal year
GAO Government Accountability Office
GDA Geospatial Data Act of 2018
GDL Good Delivery List
GLER General Law, Ethics and Regulation
Green Book Standards for Internal Control in the Federal Government
Treasury Office of Inspector General Semiannual Report—September 2024 70
Abbreviations
GSS General Support Systems
HHS Health and Human Services
ICE-HSI Immigration and Customs Enforcement Homeland Security
Investigations
IPA certified independent public accounting firm
IRS Internal Revenue Service
ISIS Islamic State of Iraq and Syria
IT Information Technology
LBMA London Bullion Market Association
MHDC Missouri Housing Development Commission
Mint United States Mint
MOU Memoranda of Understanding
NOAA National Oceanic and Atmospheric Administration
OASIS Office of Foreign Assets Control’s Administrative System for
Investigations and Sanctions
OCC Office of the Comptroller of the Currency
OFO Office of Field Operations
OIG Office of Inspector General
OMB Office of Management and Budget
OT Office of Trade
PIIA Payment Integrity Information Act of 2019
P.L. Public Law
PPP Paycheck Protection Program
PRAC Pandemic Response Accountability Committee
PSP Payroll Support Program
PSP1 Air Carrier Payroll Support Program
PSP2 Payroll Support Program Extension
PSP3 Payroll Support Program 3
RESTORE Act Resources and Ecosystems Sustainability, Tourist
Opportunities, and Revived Economies of the Gulf Coast States
Act of 2012
SBLF Small Business Leading Fund
Science Program Gulf Coast Ecosystem Restoration Science, Observation,
Monitoring, and Technology Program
SLR service level requirements
SOP standard operating procedures
TARP Troubled Asset Relief Program
Thurston County Thurston County, Washington
TIGTA Treasury Inspector General for Tax Administration
Treasury Office of Inspector General Semiannual Report—September 2024 71
Abbreviations
TMBCI Turtle Mountain Band of Chippewa Indians
Treasury Department of the Treasury
TRLED Trade Remedy Law Enforcement Directorate
TTO Trade Transformation Office
Uniform Guidance Uniform Administrative Requirements, Cost Principles, and
Audit Requirements for Federal Awards, 2 CFR Part 200
USAO U.S. Attorney’s Office
Virginia Commonwealth of Virginia
Treasury Office of Inspector General Semiannual Report—September 2024 72
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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