Open Recommendations

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.

The Director of FinCEN should update FinCEN’s BSA data SOPs to require a review to ensure FinCEN personnel appropriately maintain MOUs and related documentation. Ensure the update specifies that decision matrices are appropriately maintained.

The Director of FinCEN should update FinCEN’s BSA data SOPs to require that FinCEN identify and permit designees to sign MOUs in lieu of FinCEN’s Director and FinCEN personnel and external agency officials record the execution date on MOUs.

The IPA recommended that OCIO management reinforces policy requirements (through training or other means) for completing periodic monthly reviews of FARS OS privileged user access.

The IPA recommended that OCIO management performs ongoing monitoring to hold responsible control operators accountable for timely completion of such control activities.

The IPA recommended that Fiscal Service management reinforce policy requirements (through training or other means) for removing logical access of terminated and transferred Fiscal Service employees and contractors within 2 business days of their separation date.

The IPA recommended that Fiscal Service management perform ongoing monitoring to hold responsible control performers accountable for timely completion of such control activities

The IPA recommended that Fiscal Service develop and implement documentation to assign responsibility for ensuring adequacy of UNIX and database security and baseline settings.

The IPA recommended that Fiscal Service update existing UNIX and database configuration security baseline documents to ensure that these documents fully incorporate and enforce the components of the DISA STIGs. Management should document any deviations from the STIGs and note compensating controls that mitigate the security risk to an acceptable level.