Management Advisory: Implementation of Watch List Program Presents Potential Legal Risks and Limits Effectiveness

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Date Issued

Tuesday, February 4, 2025

Submitting OIG

Export-Import Bank of the United States OIG

Agencies Reviewed/Investigated

Export-Import Bank

Report Number

OIG-O-25-04

Report Type

Other

Agency Wide

Yes

Number of Recommendations

Questioned Costs

Funds for Better Use

Report updated under NDAA 5274

Open Recommendations

This report has 8 open recommendations.

Recommendation Number	Significant Recommendation	Recommended Questioned Costs	Recommended Funds for Better Use
1	No	$0	$0
The Portfolio Risk Management Office should enhance transparency in decision-making by establish a formal process for documenting rationales behind timeline changes and delays and provide public-facing updates on major transactions through a structured reporting mechanism.
2	No	$0	$0
The Office of General Counsel should update the Watch List procedures to include examples of risks warranting mitigating measures and what mitigating measures can be applied to parties when there is a match.
3	No	$0	$0
The Office of General Counsel should implement documentation requirements for actions taken as a result of Watch List matches, to include support for taking mitigating measures.
4	No	$0	$0
The Office of General Counsel should update the Watch List procedures to include examples of a suspicion and reputation of untrustworthy behavior and to add parties based on referrals from other agencies.
5	No	$0	$0
The Office of General Counsel should update the Watch List procedures to align with actual practices regarding parties EXIM determines should no longer be on the Watch List; the standards for deactivation or removal, including when there is a match to a party that should be deactivated or removed; and in the case of deactivation what the implications are for future searches and reactivation.
6	No	$0	$0
The Office of General Counsel, in coordination with the Office of the Chief Information Officer, should implement a process for automatically deactivating or removing parties that have been on the Watch List over 10 years without a match.
7	No	$0	$0
The Office of General Counsel should state and implement a requirement in the procedures and develop a process to concurrently notify OIG whenever there are new parties added to the Watch List, there are true matches on the Watch List, and there are parties removed or deactivated from the Watch List.
8	No	$0	$0
The Office General Counsel, in coordination with the Office of Communications, should upload the Watch List system of record notice to EXIM’s public website.