Answer: The Organization effectively screened third parties to avoid transactions with suspended or debarred entities.
Trend: However, GALT lacks documentation controls for the steps taken during this screening process.
List: Implement documentation procedures to track pre-transaction reviews and ensure compliance.
Finding Text
he Organization had proper controls in place to adequately screen and ensure it did not complete a covered transaction with a suspended or debarred third party, GALT did not have controls in place to document the steps undertaken as part of this pre-covered transaction review.
Corrective Action Plan
The Organization is documenting their review for proper suspension and debarment compliance prior to entering a transaction.