Finding Text
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.