Finding 1235838 (2025-001)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2025
Accepted
2026-09-21
Audit: 411444
Organization: Panthera Corporation (NY)

AI Summary

  • Core Issue: The Corporation failed to provide necessary documentation for expenditures, leading to a material weakness in internal controls and noncompliance with federal requirements.
  • Impacted Requirements: Noncompliance with 2 CFR Sections 200.303(a), 200.405, and 200.403(g) regarding documentation and allowability of costs.
  • Recommended Follow-Up: Implement improved document retention and management procedures to ensure all required approvals and contracts are maintained for federal expenditures.

Finding Text

2025-001: Activities Allowed or Unallowed and Allowable Costs/Cost Principles - Material Weakness in Internal Control and Material Noncompliance Repeat of Prior Audit Finding 2024-001 Federal Program: Trans-National Crime Federal Agency: U.S. Department of State - Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2025 Criteria: 2 CFR Section 200.303(a) of the Uniform Guidance requires all non-Federal entities to establish, document, and maintain effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. In addition, 2 CFR Sections 200.405 and 200.403(g) require federal awards be expended only for allowable activities and be adequately documented, respectively. Condition/Context: The Corporation was unable to provide a signed contract or reconciliation to evidence allowability of the expenditures or documentation of review and approval for the following: • For 3 out of 40 selections, no evidence of approval of signed contracts could be provided (control and compliance). • For 1 out of 40 selections, no evidence of approval of time sheet could be provided (control and compliance). • For 11 out of 40 selections, no evidence of approval of payroll payments could be provided (control). This was not a statistically valid sample. Questioned Costs: Questioned costs were approximately $12,016. Cause: The Corporation did not retain/could not retrieve the signed contracts due to poor document retention. Effect: The Corporation has not complied with the specific requirements for activities allowed or unallowed and allowable costs/cost principles as described in the Uniform Guidance. Unallowable costs may have been charged to the federal program. Recommendation: We recommend that the Corporation review its process and implement procedures that would allow management to properly maintain all required documentation related to its federal expenditures.

Corrective Action Plan

Panthera continued strengthening its internal controls through 2025 and early 2026 by expanding its use of Rippling to support more consistent HR workflows, documentation, and approval tracking. We also transitioned portions of our international workforce from DEEL to Safeguard, which offers stronger compliance monitoring and country‑specific employment controls. This shift enhances our ability to maintain complete personnel files, ensure accurate payroll processing, and meet federal requirements for allowability of labor costs. In addition, the new timesheet module implemented across 2024–2025 continues to improve documentation of personnel activity and verification of payroll‑related charges. The organization also experienced a leadership transition with the departure of our CAO in late 2025 and the onboarding of a new Chief People Officer in early 2026. This change has brought renewed focus to HR governance, process standardization, and long‑term workforce planning, further reinforcing Panthera’s commitment to strong internal controls over federal expenditures.

Categories

Allowable Costs / Cost Principles

Programs in Audit

ALN Program Name Expenditures
19.705 TRANS-NATIONAL CRIME $922,151
15.620 AFRICAN ELEPHANT CONSERVATION FUND $83,388
15.619 RHINOCEROS AND TIGER CONSERVATION FUND $42,711
15.621 ASIAN ELEPHANT CONSERVATION FUND $16,297
15.640 LATIN AMERICA AND CARIBBEAN REGIONAL $11,829
10.684 INTERNATIONAL FORESTRY PROGRAMS $1,906