DHS - OIG-18-88 - 4

We recommend the Coast Guard's Assistant Commandant for Prevention Policy revise and strengthen the Coast Guard TWIC Verification and Enforcement Guide. At a minimum, the policy should: - streamline guidance for oversight of the TWIC program by consolidating requirements from other interim Coast Guard policy documents; - include more specific procedures for recording the results of electronic TWIC verifications in the Marine Information for Safety and Law Enforcement system, such as updating the reference to the appropriate user guide and requiring inspectors to add a narrative explanation when card readers are not used for verifications; - define Coast Guard facility inspectors as law enforcement personnel, clarify the inspectors' authority for performing regulatory confiscations of TWIC cards, and outline the required procedures for documenting regulatory confiscations in the Marine Information for Safety and Law Enforcement system and returning the cards to TSA; and - specify key documents that Coast Guard facility inspectors must upload in the Marine Information for Safety and Law Enforcement system for annual compliance exams and security spot checks at regulated facilities, including but not limited to the completed inspection checklist, Form CG-835F, enforcement actions, and evidence of corrective action taken.