Finding Text
Finding 2023-001: Reporting of Known Embezzlement in Thailand
Information on the Federal Programs: N/A
Criteria or Specific Requirement (including statutory, regulatory, or other citation): Title 2 U.S.
Code of Federal Regulations Part 200, Uniform Administrative Requirements,Cost Principles, and Audit
Requirements for Federal Awards Part 200.302 Financial Management requires recipients to
adequately safeguard all assets and assure that they are used solely for authorized purposes.
Condition: Management of Alight was notified of an instance of embezzlement that occurred in
Thailand. Employees were submitting invoices from a fictitious vendor and affirming that the goods
were received. Management of Alight took appropriate action by conducting an investigation and
terminating all employees involved in the incident.
Cause: Alight did not adequately safeguard its assets. However, Alight's monitoring procedures did
detect the embezzlement and they have subsequently enhanced procedures surrounding cash
disbursements.
Effect or Potential Effect: After investigation, Alight did not find any evidence that a federal award
was affected, but Alight notified USAID and coded the stolen amount to unallowable expenses in the
general ledger (management did not charge the federal programs for these costs).
Questioned Costs: None.
Context: Alight failed to properly safeguard all assets. Alight must continue to monitor to ensure that
the systems of internal controls throughout its field offices are functioning as designed.
Identification as a Repeat Finding, if Applicable: See Finding 2022-001.
Recommendation: We strongly recommend that Alight review its current systems of internal controls,
and enhance them where necessary, especially in the higher risk locations, to ensure they are
functioning as designated and to prevent further occurrences of embezzlement.