USAID, Treasury Plan Audits of Programs Related to PVS, Somalia Aid, and OFAC’s License Database

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November 15, 2012

In the fall of 2012, the Offices of the Inspector General (IG) for the United States Agency for International Development (USAID) and the Treasury Department released their “annual plans” for identifying programs under their jurisdictions to be audited in FY 2013.   Some of the programs to be reviewed include USAID’s West Bank and Gaza’s Partner Vetting System, USAID’s Compliance with Executive Order 13536 Prohibiting Material Support for Al-Shabaab in Somalia, and the Office of Foreign Assets Control’s (OFAC) Management of the Specially Designated Nationals and Blocked Persons List.  Additionally, Treasury says it may consider conducting a review of OFAC’s Licensing Database System, among other programs, in the future. 

(Thanks to Naz K. Modirzadeh and Chris Vaughn for bringing these to our attention!)

From USAID’s annual plan document:

“Audit of USAID/West Bank and Gaza’s Partner Vetting System: This audit will determine whether USAID/West Bank and Gaza implemented minimum security controls to protect the confidentiality, integrity, and availability of its PVS in managing and facilitating vetting requests of awardees.” [page 13]

“Audit of USAID’s Compliance with Executive Order 13536 Prohibiting Material Support for Al-Shabaab in Somalia: In FY 2011, the U.S. Government provided $133 million dollars in support to Somalia, a country with large portions controlled by Al-Shabaab. As a result, there is a high risk that Al-Shabaab may be aggressively trying to benefit from any assistance provided to the Somalian people. This audit will determine whether USAID has adequate controls to ensure compliance with EO 13536 in prohibiting material support for Al-Shabaab in Somalia.” [page 14]

From Treasury’s annual plan document:

“OFAC’s Management of the Specially Designated Nationals and Blocked Persons List: We plan to determine and assess OFAC’s management controls over the process of listing and delisting individuals and entities from the Specially Designated Nationals and Blocked Persons list and assess the effectiveness of the new data system in helping OFAC manage this process.”  [page 31]

“Treasury Executive Office of Asset Forfeiture’s Use of Treasury Forfeiture Fund Receipts to Support Law Enforcement: We plan to determine whether the Treasury Executive Office of Asset Forfeiture has appropriate controls to (1) award and distribute funds to eligible law enforcement agencies in accordance with applicable laws, regulations, and policies; and (2) ensure that distributed receipts are used for intended purposes. As part of this work, we plan to determine whether selected state and local government agencies use Treasury forfeiture funds in accordance with Treasury guidelines.” [page 30]

“FinCEN Implementation of USA PATRIOT Act Information-Sharing Procedures: The USA PATRIOT Act provides for the sharing of information between the government and financial institutions, and among financial institutions regarding individuals, entities, and organizations engaged in or reasonably suspected of engaging in terrorist acts or money laundering activities. In March 2005, FinCEN implemented a web-based secure communications system to expedite sharing of this information. We plan to determine the extent to which information sharing is occurring among the government and financial institutions.” [page 30]

Treasury audits under future considerations include:

“OFAC’s Licensing Database System Upgrade: OFAC uses a document management system to store licensing data obtained from license applications and related correspondence. In 2012, OFAC completed a systems development effort to better manage licensing information. The goal of the project is to provide OFAC with an integrated, largely paperless database that would allow it to better collect and manage information, conduct analysis, and improve efficiency. We plan to determine whether the upgrade to OFAC’s licensing system is meeting the needs of OFAC’s Licensing Division.” [page 35]

“Office of Terrorist Financing and Financial Crimes Interagency Collaboration With the National Security Community: We plan to assess the Office of Terrorist Financing and Financial Crimes’ collaboration with the national security community, including the law enforcement, regulatory, policy, diplomatic and intelligence communities as well as with the private sector and foreign governments in order to identify and address threats to the international financial system of illicit finance.” [page 35]