FAC Explorer

Audit 300302

FY End
2022-12-31
Total Expended
$12.22M
Findings
12
Programs
4
Organization: Global Fund to End Modern Slavery (DC)
Year: 2022 Accepted: 2024-03-29
Auditor: Bdo USA PC

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
389293 2022-002 Significant Deficiency - P
389294 2022-002 Significant Deficiency - P
389295 2022-002 Significant Deficiency - P
389296 2022-003 Significant Deficiency - M
389297 2022-003 Significant Deficiency - M
389298 2022-003 Significant Deficiency - M
965735 2022-002 Significant Deficiency - P
965736 2022-002 Significant Deficiency - P
965737 2022-002 Significant Deficiency - P
965738 2022-003 Significant Deficiency - M
965739 2022-003 Significant Deficiency - M
965740 2022-003 Significant Deficiency - M

Programs

ALN Program Spent Major Findings
19.019 Program to End Modern Slavery (pems2) $8.63M Yes 2
19.019 Program to End Modern Slavery (pems1) $2.15M Yes 2
19.019 Program to End Modern Slavery (pems5) $1.42M Yes 2
17.041 Program to End Modern Slavery $22,777 - 0

Contacts

Name Title Type
RJNBPL8T6HK3 Randy Willard Auditee
4107339113 John Griffin Auditor
No contacts on file

Notes to SEFA

Title: Basis of Preparation Accounting Policies: The accompanying Schedule of Expenditures of federal awards (the Schedule) includes the federal grant activity of the Global Fund to End Modern Slavery (the Fund) under programs of the federal government for the year ended December 31, 2022. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operation of the Fund, it is not intended to and does not present the financial position, change in net assets or cash flows of the Fund. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: Y Rate Explanation: The Fund has elected to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The accompanying Schedule of Expenditures of federal awards (the Schedule) includes the federal grant activity of the Global Fund to End Modern Slavery (the Fund) under programs of the federal government for the year ended December 31, 2022. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operation of the Fund, it is not intended to and does not present the financial position, change in net assets or cash flows of the Fund. The Fund receives funding from the Department of State through cooperative agreements. The Fund receives advances under these agreements through the Payment Management System, which is a financial management service for the Department of Health and Human Services.
Title: Summary of Significant Accounting Policies Accounting Policies: The accompanying Schedule of Expenditures of federal awards (the Schedule) includes the federal grant activity of the Global Fund to End Modern Slavery (the Fund) under programs of the federal government for the year ended December 31, 2022. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operation of the Fund, it is not intended to and does not present the financial position, change in net assets or cash flows of the Fund. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: Y Rate Explanation: The Fund has elected to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement.

Finding Details

Finding 2022-002
2022-002 Submission of Data Collection Form Information on Federal Program(s) U.S. Department of State Name of Program: Program to End Modern Slavery Assistance Listing Number: 19.019 Grant Award Number: S-SJTIP-17-CA-1018/S-SJTIP-18-CA-1014/ S-SJTIP-18-CA-3035 Grant Award Period: October 1, 2017 through June 30, 2022, October 1, 2018 through December 31, 2022, October 1, 2021 to September 30, 2024 Criteria - In accordance with 2 CFR Section 200.512(a) Report Submission - General, the audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition - The reporting package and data collection form for the year ended December 31, 2022 was not filed by the deadline of September 30, 2023 to the Federal Audit Clearinghouse. Cause- Due to turnover and reduction in staff, additional time was required to comply fully with reporting on, and audit of, compliance requirements of the federal award programs. Effect - The reporting package and data collection form for the year ended December 31, 2022, was not submitted to the Federal Audit Clearinghouse in a timely manner. Questioned Costs - None Context - The reporting package and data collection form for the year ended December 31, 2022 will be submitted to the Federal Audit Clearinghouse after the due date of September 30, 2023. Repeat Finding - This is not a repeat finding. Recommendation - We recommend the Fund continue to refine policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. View of Responsible Officials - Management agrees with the Federal award finding identified in the audit. The Fund’s response to this finding is described in the accompanying management’s corrective action plan.
Finding 2022-002
2022-002 Submission of Data Collection Form Information on Federal Program(s) U.S. Department of State Name of Program: Program to End Modern Slavery Assistance Listing Number: 19.019 Grant Award Number: S-SJTIP-17-CA-1018/S-SJTIP-18-CA-1014/ S-SJTIP-18-CA-3035 Grant Award Period: October 1, 2017 through June 30, 2022, October 1, 2018 through December 31, 2022, October 1, 2021 to September 30, 2024 Criteria - In accordance with 2 CFR Section 200.512(a) Report Submission - General, the audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition - The reporting package and data collection form for the year ended December 31, 2022 was not filed by the deadline of September 30, 2023 to the Federal Audit Clearinghouse. Cause- Due to turnover and reduction in staff, additional time was required to comply fully with reporting on, and audit of, compliance requirements of the federal award programs. Effect - The reporting package and data collection form for the year ended December 31, 2022, was not submitted to the Federal Audit Clearinghouse in a timely manner. Questioned Costs - None Context - The reporting package and data collection form for the year ended December 31, 2022 will be submitted to the Federal Audit Clearinghouse after the due date of September 30, 2023. Repeat Finding - This is not a repeat finding. Recommendation - We recommend the Fund continue to refine policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. View of Responsible Officials - Management agrees with the Federal award finding identified in the audit. The Fund’s response to this finding is described in the accompanying management’s corrective action plan.
Finding 2022-002
2022-002 Submission of Data Collection Form Information on Federal Program(s) U.S. Department of State Name of Program: Program to End Modern Slavery Assistance Listing Number: 19.019 Grant Award Number: S-SJTIP-17-CA-1018/S-SJTIP-18-CA-1014/ S-SJTIP-18-CA-3035 Grant Award Period: October 1, 2017 through June 30, 2022, October 1, 2018 through December 31, 2022, October 1, 2021 to September 30, 2024 Criteria - In accordance with 2 CFR Section 200.512(a) Report Submission - General, the audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition - The reporting package and data collection form for the year ended December 31, 2022 was not filed by the deadline of September 30, 2023 to the Federal Audit Clearinghouse. Cause- Due to turnover and reduction in staff, additional time was required to comply fully with reporting on, and audit of, compliance requirements of the federal award programs. Effect - The reporting package and data collection form for the year ended December 31, 2022, was not submitted to the Federal Audit Clearinghouse in a timely manner. Questioned Costs - None Context - The reporting package and data collection form for the year ended December 31, 2022 will be submitted to the Federal Audit Clearinghouse after the due date of September 30, 2023. Repeat Finding - This is not a repeat finding. Recommendation - We recommend the Fund continue to refine policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. View of Responsible Officials - Management agrees with the Federal award finding identified in the audit. The Fund’s response to this finding is described in the accompanying management’s corrective action plan.
Finding 2022-003
2022-003 Financial Impropriety Information on Federal Program(s) U.S. Department of State Name of Program: Program to End Modern Slavery Assistance Listing Number: 19.019 Grant Award Number: S-SJTIP-17-CA-1018/S-SJTIP-18-CA-1014/ S-SJTIP-18-CA-3035 Grant Award Period: October 1, 2017 through June 30, 2022, October 1, 2018 through December 31, 2022, October 1, 2021 to September 30, 2024 Criteria - §200.516(a) Audit findings(6) requires known or suspected fraud be reported by the auditors. Condition - During the year ended December 31, 2022, the Fund received an e-mail from one of its subrecipients stating that they received a whistleblower complaint about an alleged financial impropriety that occurred within their country office. The subrecipient conducted an internal audit, which confirmed in December 2022 some of the allegations including receipt of per diem for trips not attended and use of an office vehicle and fuel for personal use. In February 2023, the subrecipient also contracted with a consultant to perform a forensic audit of the suspected inappropriate procurement and corruption activities at their Uganda Country office for the period from January 1, 2019 through December 31, 2022. The forensic report highlighted certain amounts that were misappropriated from the PEMS 2 grant for the year ended December 31, 2022. The Fund did not suffer any financial loss, since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. In addition, in accordance with 2CFR 200.113, the Fund disclosed the financial impropriety incident to the Office of the Inspector General (OIG) for the Department of State and the cognizant Grants Officer was aware of substantiated misappropriation that impacted funding sub-awarded by the Fund to the subrecipient under the PEMS 2 grant. Cause - Individuals at the subrecipient organization committed inappropriate procurement and corruption activities. Effect - These conditions could result in unallowable expenses being charged to U.S. Government awards if the whistle blower complaint and subsequent investigation did not identify the financial impropriety. Questioned Costs - There are no questioned costs since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. Context - This matter was identified through a whistleblower complaint at the subrecipient organization during the year ended December 31, 2022. Repeat Finding - This is not a repeat finding. Recommendation - The Fund should continue to monitor and assess the control environment in which its subrecipients operate. The Fund should also ensure a detailed risk assessment of all subrecipients is regularly performed and reviewed. It should also assess whether future funding be provided to the subrecipient. View of Responsible Officials - Management agrees with the Federal award finding identified in the audit. The Fund’s response to this finding is described in the accompanying management’s corrective action plan.
Finding 2022-003
2022-003 Financial Impropriety Information on Federal Program(s) U.S. Department of State Name of Program: Program to End Modern Slavery Assistance Listing Number: 19.019 Grant Award Number: S-SJTIP-17-CA-1018/S-SJTIP-18-CA-1014/ S-SJTIP-18-CA-3035 Grant Award Period: October 1, 2017 through June 30, 2022, October 1, 2018 through December 31, 2022, October 1, 2021 to September 30, 2024 Criteria - §200.516(a) Audit findings(6) requires known or suspected fraud be reported by the auditors. Condition - During the year ended December 31, 2022, the Fund received an e-mail from one of its subrecipients stating that they received a whistleblower complaint about an alleged financial impropriety that occurred within their country office. The subrecipient conducted an internal audit, which confirmed in December 2022 some of the allegations including receipt of per diem for trips not attended and use of an office vehicle and fuel for personal use. In February 2023, the subrecipient also contracted with a consultant to perform a forensic audit of the suspected inappropriate procurement and corruption activities at their Uganda Country office for the period from January 1, 2019 through December 31, 2022. The forensic report highlighted certain amounts that were misappropriated from the PEMS 2 grant for the year ended December 31, 2022. The Fund did not suffer any financial loss, since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. In addition, in accordance with 2CFR 200.113, the Fund disclosed the financial impropriety incident to the Office of the Inspector General (OIG) for the Department of State and the cognizant Grants Officer was aware of substantiated misappropriation that impacted funding sub-awarded by the Fund to the subrecipient under the PEMS 2 grant. Cause - Individuals at the subrecipient organization committed inappropriate procurement and corruption activities. Effect - These conditions could result in unallowable expenses being charged to U.S. Government awards if the whistle blower complaint and subsequent investigation did not identify the financial impropriety. Questioned Costs - There are no questioned costs since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. Context - This matter was identified through a whistleblower complaint at the subrecipient organization during the year ended December 31, 2022. Repeat Finding - This is not a repeat finding. Recommendation - The Fund should continue to monitor and assess the control environment in which its subrecipients operate. The Fund should also ensure a detailed risk assessment of all subrecipients is regularly performed and reviewed. It should also assess whether future funding be provided to the subrecipient. View of Responsible Officials - Management agrees with the Federal award finding identified in the audit. The Fund’s response to this finding is described in the accompanying management’s corrective action plan.
Finding 2022-003
2022-003 Financial Impropriety Information on Federal Program(s) U.S. Department of State Name of Program: Program to End Modern Slavery Assistance Listing Number: 19.019 Grant Award Number: S-SJTIP-17-CA-1018/S-SJTIP-18-CA-1014/ S-SJTIP-18-CA-3035 Grant Award Period: October 1, 2017 through June 30, 2022, October 1, 2018 through December 31, 2022, October 1, 2021 to September 30, 2024 Criteria - §200.516(a) Audit findings(6) requires known or suspected fraud be reported by the auditors. Condition - During the year ended December 31, 2022, the Fund received an e-mail from one of its subrecipients stating that they received a whistleblower complaint about an alleged financial impropriety that occurred within their country office. The subrecipient conducted an internal audit, which confirmed in December 2022 some of the allegations including receipt of per diem for trips not attended and use of an office vehicle and fuel for personal use. In February 2023, the subrecipient also contracted with a consultant to perform a forensic audit of the suspected inappropriate procurement and corruption activities at their Uganda Country office for the period from January 1, 2019 through December 31, 2022. The forensic report highlighted certain amounts that were misappropriated from the PEMS 2 grant for the year ended December 31, 2022. The Fund did not suffer any financial loss, since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. In addition, in accordance with 2CFR 200.113, the Fund disclosed the financial impropriety incident to the Office of the Inspector General (OIG) for the Department of State and the cognizant Grants Officer was aware of substantiated misappropriation that impacted funding sub-awarded by the Fund to the subrecipient under the PEMS 2 grant. Cause - Individuals at the subrecipient organization committed inappropriate procurement and corruption activities. Effect - These conditions could result in unallowable expenses being charged to U.S. Government awards if the whistle blower complaint and subsequent investigation did not identify the financial impropriety. Questioned Costs - There are no questioned costs since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. Context - This matter was identified through a whistleblower complaint at the subrecipient organization during the year ended December 31, 2022. Repeat Finding - This is not a repeat finding. Recommendation - The Fund should continue to monitor and assess the control environment in which its subrecipients operate. The Fund should also ensure a detailed risk assessment of all subrecipients is regularly performed and reviewed. It should also assess whether future funding be provided to the subrecipient. View of Responsible Officials - Management agrees with the Federal award finding identified in the audit. The Fund’s response to this finding is described in the accompanying management’s corrective action plan.
Finding 2022-002
2022-002 Submission of Data Collection Form Information on Federal Program(s) U.S. Department of State Name of Program: Program to End Modern Slavery Assistance Listing Number: 19.019 Grant Award Number: S-SJTIP-17-CA-1018/S-SJTIP-18-CA-1014/ S-SJTIP-18-CA-3035 Grant Award Period: October 1, 2017 through June 30, 2022, October 1, 2018 through December 31, 2022, October 1, 2021 to September 30, 2024 Criteria - In accordance with 2 CFR Section 200.512(a) Report Submission - General, the audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition - The reporting package and data collection form for the year ended December 31, 2022 was not filed by the deadline of September 30, 2023 to the Federal Audit Clearinghouse. Cause- Due to turnover and reduction in staff, additional time was required to comply fully with reporting on, and audit of, compliance requirements of the federal award programs. Effect - The reporting package and data collection form for the year ended December 31, 2022, was not submitted to the Federal Audit Clearinghouse in a timely manner. Questioned Costs - None Context - The reporting package and data collection form for the year ended December 31, 2022 will be submitted to the Federal Audit Clearinghouse after the due date of September 30, 2023. Repeat Finding - This is not a repeat finding. Recommendation - We recommend the Fund continue to refine policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. View of Responsible Officials - Management agrees with the Federal award finding identified in the audit. The Fund’s response to this finding is described in the accompanying management’s corrective action plan.
Finding 2022-002
2022-002 Submission of Data Collection Form Information on Federal Program(s) U.S. Department of State Name of Program: Program to End Modern Slavery Assistance Listing Number: 19.019 Grant Award Number: S-SJTIP-17-CA-1018/S-SJTIP-18-CA-1014/ S-SJTIP-18-CA-3035 Grant Award Period: October 1, 2017 through June 30, 2022, October 1, 2018 through December 31, 2022, October 1, 2021 to September 30, 2024 Criteria - In accordance with 2 CFR Section 200.512(a) Report Submission - General, the audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition - The reporting package and data collection form for the year ended December 31, 2022 was not filed by the deadline of September 30, 2023 to the Federal Audit Clearinghouse. Cause- Due to turnover and reduction in staff, additional time was required to comply fully with reporting on, and audit of, compliance requirements of the federal award programs. Effect - The reporting package and data collection form for the year ended December 31, 2022, was not submitted to the Federal Audit Clearinghouse in a timely manner. Questioned Costs - None Context - The reporting package and data collection form for the year ended December 31, 2022 will be submitted to the Federal Audit Clearinghouse after the due date of September 30, 2023. Repeat Finding - This is not a repeat finding. Recommendation - We recommend the Fund continue to refine policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. View of Responsible Officials - Management agrees with the Federal award finding identified in the audit. The Fund’s response to this finding is described in the accompanying management’s corrective action plan.
Finding 2022-002
2022-002 Submission of Data Collection Form Information on Federal Program(s) U.S. Department of State Name of Program: Program to End Modern Slavery Assistance Listing Number: 19.019 Grant Award Number: S-SJTIP-17-CA-1018/S-SJTIP-18-CA-1014/ S-SJTIP-18-CA-3035 Grant Award Period: October 1, 2017 through June 30, 2022, October 1, 2018 through December 31, 2022, October 1, 2021 to September 30, 2024 Criteria - In accordance with 2 CFR Section 200.512(a) Report Submission - General, the audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report, or nine months after the end of the audit period, adjusted for any extensions permitted by the Office of Management and Budget. Condition - The reporting package and data collection form for the year ended December 31, 2022 was not filed by the deadline of September 30, 2023 to the Federal Audit Clearinghouse. Cause- Due to turnover and reduction in staff, additional time was required to comply fully with reporting on, and audit of, compliance requirements of the federal award programs. Effect - The reporting package and data collection form for the year ended December 31, 2022, was not submitted to the Federal Audit Clearinghouse in a timely manner. Questioned Costs - None Context - The reporting package and data collection form for the year ended December 31, 2022 will be submitted to the Federal Audit Clearinghouse after the due date of September 30, 2023. Repeat Finding - This is not a repeat finding. Recommendation - We recommend the Fund continue to refine policies and procedures, including tracking and monitoring of reporting requirements, to ensure that the audit, reporting package, and data collection form are electronically filed with the Federal Audit Clearinghouse within the applicable deadline. View of Responsible Officials - Management agrees with the Federal award finding identified in the audit. The Fund’s response to this finding is described in the accompanying management’s corrective action plan.
Finding 2022-003
2022-003 Financial Impropriety Information on Federal Program(s) U.S. Department of State Name of Program: Program to End Modern Slavery Assistance Listing Number: 19.019 Grant Award Number: S-SJTIP-17-CA-1018/S-SJTIP-18-CA-1014/ S-SJTIP-18-CA-3035 Grant Award Period: October 1, 2017 through June 30, 2022, October 1, 2018 through December 31, 2022, October 1, 2021 to September 30, 2024 Criteria - §200.516(a) Audit findings(6) requires known or suspected fraud be reported by the auditors. Condition - During the year ended December 31, 2022, the Fund received an e-mail from one of its subrecipients stating that they received a whistleblower complaint about an alleged financial impropriety that occurred within their country office. The subrecipient conducted an internal audit, which confirmed in December 2022 some of the allegations including receipt of per diem for trips not attended and use of an office vehicle and fuel for personal use. In February 2023, the subrecipient also contracted with a consultant to perform a forensic audit of the suspected inappropriate procurement and corruption activities at their Uganda Country office for the period from January 1, 2019 through December 31, 2022. The forensic report highlighted certain amounts that were misappropriated from the PEMS 2 grant for the year ended December 31, 2022. The Fund did not suffer any financial loss, since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. In addition, in accordance with 2CFR 200.113, the Fund disclosed the financial impropriety incident to the Office of the Inspector General (OIG) for the Department of State and the cognizant Grants Officer was aware of substantiated misappropriation that impacted funding sub-awarded by the Fund to the subrecipient under the PEMS 2 grant. Cause - Individuals at the subrecipient organization committed inappropriate procurement and corruption activities. Effect - These conditions could result in unallowable expenses being charged to U.S. Government awards if the whistle blower complaint and subsequent investigation did not identify the financial impropriety. Questioned Costs - There are no questioned costs since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. Context - This matter was identified through a whistleblower complaint at the subrecipient organization during the year ended December 31, 2022. Repeat Finding - This is not a repeat finding. Recommendation - The Fund should continue to monitor and assess the control environment in which its subrecipients operate. The Fund should also ensure a detailed risk assessment of all subrecipients is regularly performed and reviewed. It should also assess whether future funding be provided to the subrecipient. View of Responsible Officials - Management agrees with the Federal award finding identified in the audit. The Fund’s response to this finding is described in the accompanying management’s corrective action plan.
Finding 2022-003
2022-003 Financial Impropriety Information on Federal Program(s) U.S. Department of State Name of Program: Program to End Modern Slavery Assistance Listing Number: 19.019 Grant Award Number: S-SJTIP-17-CA-1018/S-SJTIP-18-CA-1014/ S-SJTIP-18-CA-3035 Grant Award Period: October 1, 2017 through June 30, 2022, October 1, 2018 through December 31, 2022, October 1, 2021 to September 30, 2024 Criteria - §200.516(a) Audit findings(6) requires known or suspected fraud be reported by the auditors. Condition - During the year ended December 31, 2022, the Fund received an e-mail from one of its subrecipients stating that they received a whistleblower complaint about an alleged financial impropriety that occurred within their country office. The subrecipient conducted an internal audit, which confirmed in December 2022 some of the allegations including receipt of per diem for trips not attended and use of an office vehicle and fuel for personal use. In February 2023, the subrecipient also contracted with a consultant to perform a forensic audit of the suspected inappropriate procurement and corruption activities at their Uganda Country office for the period from January 1, 2019 through December 31, 2022. The forensic report highlighted certain amounts that were misappropriated from the PEMS 2 grant for the year ended December 31, 2022. The Fund did not suffer any financial loss, since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. In addition, in accordance with 2CFR 200.113, the Fund disclosed the financial impropriety incident to the Office of the Inspector General (OIG) for the Department of State and the cognizant Grants Officer was aware of substantiated misappropriation that impacted funding sub-awarded by the Fund to the subrecipient under the PEMS 2 grant. Cause - Individuals at the subrecipient organization committed inappropriate procurement and corruption activities. Effect - These conditions could result in unallowable expenses being charged to U.S. Government awards if the whistle blower complaint and subsequent investigation did not identify the financial impropriety. Questioned Costs - There are no questioned costs since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. Context - This matter was identified through a whistleblower complaint at the subrecipient organization during the year ended December 31, 2022. Repeat Finding - This is not a repeat finding. Recommendation - The Fund should continue to monitor and assess the control environment in which its subrecipients operate. The Fund should also ensure a detailed risk assessment of all subrecipients is regularly performed and reviewed. It should also assess whether future funding be provided to the subrecipient. View of Responsible Officials - Management agrees with the Federal award finding identified in the audit. The Fund’s response to this finding is described in the accompanying management’s corrective action plan.
Finding 2022-003
2022-003 Financial Impropriety Information on Federal Program(s) U.S. Department of State Name of Program: Program to End Modern Slavery Assistance Listing Number: 19.019 Grant Award Number: S-SJTIP-17-CA-1018/S-SJTIP-18-CA-1014/ S-SJTIP-18-CA-3035 Grant Award Period: October 1, 2017 through June 30, 2022, October 1, 2018 through December 31, 2022, October 1, 2021 to September 30, 2024 Criteria - §200.516(a) Audit findings(6) requires known or suspected fraud be reported by the auditors. Condition - During the year ended December 31, 2022, the Fund received an e-mail from one of its subrecipients stating that they received a whistleblower complaint about an alleged financial impropriety that occurred within their country office. The subrecipient conducted an internal audit, which confirmed in December 2022 some of the allegations including receipt of per diem for trips not attended and use of an office vehicle and fuel for personal use. In February 2023, the subrecipient also contracted with a consultant to perform a forensic audit of the suspected inappropriate procurement and corruption activities at their Uganda Country office for the period from January 1, 2019 through December 31, 2022. The forensic report highlighted certain amounts that were misappropriated from the PEMS 2 grant for the year ended December 31, 2022. The Fund did not suffer any financial loss, since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. In addition, in accordance with 2CFR 200.113, the Fund disclosed the financial impropriety incident to the Office of the Inspector General (OIG) for the Department of State and the cognizant Grants Officer was aware of substantiated misappropriation that impacted funding sub-awarded by the Fund to the subrecipient under the PEMS 2 grant. Cause - Individuals at the subrecipient organization committed inappropriate procurement and corruption activities. Effect - These conditions could result in unallowable expenses being charged to U.S. Government awards if the whistle blower complaint and subsequent investigation did not identify the financial impropriety. Questioned Costs - There are no questioned costs since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. Context - This matter was identified through a whistleblower complaint at the subrecipient organization during the year ended December 31, 2022. Repeat Finding - This is not a repeat finding. Recommendation - The Fund should continue to monitor and assess the control environment in which its subrecipients operate. The Fund should also ensure a detailed risk assessment of all subrecipients is regularly performed and reviewed. It should also assess whether future funding be provided to the subrecipient. View of Responsible Officials - Management agrees with the Federal award finding identified in the audit. The Fund’s response to this finding is described in the accompanying management’s corrective action plan.