Open Recommendations

Provide analytical support from FAA's Safety Analysis Branch to CMOs to gather, analyze, and trend data for questions that have been answered "not observable" to support risk-based decision making.

Implement a plan with the Office of Acquisition and Logistics Project Management Office to ensure system access is more granular and the intent of the principle of least privilege is met.

Ensure all roles and accesses, including those provided by default access, are reviewed and certified periodically as required.

Implement a permanent solution to provide supervisors and information owners with visibility of all roles and accesses, including those provided by default access, granted to users.

OIG recommends the deputy assistant secretary for the FMBT Service implement a plan with the Office of Acquisition and Logistics Project Management Office to ensure system access is more granular and the intent of the principle of least privilege is met.

OIG recommends the deputy assistant secretary for the FMBT Service ensure all roles and accesses, including those provided by default access, are reviewed and certified periodically as required.

OIG recommends the deputy assistant secretary for the FMBT Service implement a permanent solution to provide supervisors and information owners with visibility of all roles and accesses, including those provided by default access, granted to users.

FHFA's Chief Financial Officer should seek recovery of $5,208 in overpayments questioned in this report, as appropriate.

FHFA's Chief Financial Officer should update FHFA’s invoice review policies and procedures to require CORs and Invoice Approvers to perform a documented review of invoice billing rates (e.g., confirmation against contract or task order tables) prior to payment approval.

FHFA's Chief Financial Officer should update FHFA’s invoice review training materials for CORs and Invoice Approvers to include clear step-by-step instructions on how to verify billing rates against contract terms and document verification.

FHFA's Chief Financial Officer should ensure that all staff with invoice approval authority complete the updated training.

FHFA's Chief Financial Officer should update procedures to set timeframes for OCFO personnel to request (a) a written statement on why an invoice was paid late; and (b) written corrective actions to be taken to prevent any future late payment issues.

FHFA's Chief Financial Officer should assign back-ups for OCFO personnel on leave to ensure that the control procedure to obtain written statements explaining why late payments occurred and corrective actions to be taken to prevent any future late payments is performed timely.

The Director of FinCEN should conduct and document an assessment of FinCEN’s decision to offer bulk data access, including the potential risks and how those risks are being mitigated.

The Director of FinCEN should update FinCEN’s bulk data access SOP to specify how to conduct and document reviews of requests and periodic reevaluations of agencies’ need for bulk data access, including which personnel are responsible for conducting these reviews and approving access.

The Director of FinCEN should conduct and document a reevaluation of the basis for granting each agency access to bulk data, in accordance with the bulk data SOP, to determine whether the overall benefits of continuing to provide such access outweigh the potential downsides and whether those downsides can be mitigated effectively.

The Director of FinCEN should review and update the BSA data SORN to ensure it identifies all routine uses and specifically and clearly describes the purpose of bulk data and how external agencies will use the data. Also, ensure FinCEN accurately details its administrative practices.

The Director of FinCEN should ensure that FinCEN, going forward, complies with SORN requirements in the Privacy Act, Treasury regulations, OMB guidance, and Treasury’s Handbook.

The Director of FinCEN should update FinCEN’s BSA data SOPs to require verification that an MOU has been executed with an agency before its users are granted access to BSA data.

The Director of FinCEN should ensure SOPs specifically cover platform program access and require the execution of an MOU with external agencies before providing their users platform program access.

The Director of FinCEN should update FinCEN’s BSA data SOPs to clearly specify the types of access to which they apply.

The Director of FinCEN should execute MOUs with all agencies participating in the platform program.

The Director of FinCEN should immediately review BSA data MOUs to determine which require updates and execute updated MOUs with those external agencies.

The Director of FinCEN should update FinCEN’s BSA data SOPs to require that FinCEN personnel periodically review MOUs to determine if they require an update, and if so, execute updated MOUs with those external agencies.

The Director of FinCEN should update FinCEN’s BSA data SOPs to ensure accurate tracking and consistent documentation of BSA data MOUs.