Amele
amele2000
action_plan.docxRunning head: AUDIT ACTION PLAN 1
AUDIT ACTION PLAN 4
Federal Financial Management
Audit Action Plan
Prepare by
Edwige Kouassi
To
Prof: Elizabeth Scheffler
Audit Action Plan response on the Audit of the Drug Enforcement Administration’s Management and Oversight of its Confidential Source Program
The Drug Enforcement Administration (DEA) Confidential Source Program is crucial in the pursuit of prohibited narcotics. However, confidential sources can be inspired by other elements unrelated to fighting crime, which include financial gain and evading retribution. In 2015, the Department of Justice Office of the Inspector General (OIG) released a report on confidential source policies of DEA and its oversight. The reported indicated that DEA policies were not in full compliance with AG guidelines. The following are the findings by OIG:
Findings by OIG:
a. The DEA did not provide sufficient oversight in the establishment, use, and payment of the sources by the DEA Interdiction unit.
b. On occasional basis, there was no documentation of the all the interactions with sources.
c. The DEA guidelines to its Limited Use sources, dependence on the sources to achieve its interdiction mission, and relationships, especially long-term and lucrative, with the sources was questionable.
d. Noteworthy weaknesses in the DEA’s management, oversight and accountability of intelligence-related confidential source information, processes, and compensations were found.
e. It was established that some DEA confidential sources used “sub-sources” and the practice was cordoned by the DEA.
f. Notable deficiencies were recognized with the DEA’s oversight and management of confidential sources. It was noted that the headquarters-based confidential source units relies more on the judgment of field officers on various aspects of its confidentiality source program with no enough oversight to make sure that decisions linked with confidential sources set up, use, and compensation are right.
g. Additionally, DEA does not carry out exhaustive analysis of field office operations related to confidential sources and the little performed lack consistency and are not adequate.
The Objectives, Scope, and Methodology
Objective: The objective of the audit was to analyze the DEA’s management and oversight of its confidential source program, including oversight of payments to confidential sources. The audit was an extension of the OIG July 2015 report in The DEA’s Confidential Source Policies and Oversight of Higher-Risk Confidential Sources.
OIG Recommendations and Action Plan Response
The following are the recommendations from the Office of the Inspector general U.S Department of justice and the Action Plan Response from DEA
1. To scrutinize the process used in relation to Limited Use confidential sources for interdiction tasks as stated in the report. In addition, to coordinate with the department of inspector general in order to carry out evaluations of the benefits and risks.
Response: DEA concurs with the issues raised in the audit report on the practices used in relation to Limited Use of confidential sources for the interdiction tasks. In the previous months, DEA management has been analyzing their policy that governs Limited Use confidential sources and will adopt or modify the policies as appropriate in conjunction with the Department in order to address the issues raised and make sure that all processes are in line with the AG Guidelines.
2. The department should develop clear guidelines and more controls in relation to the appropriate utilization of the Limited Use confidential source class in order to make sure that the sources are used in accordance with the class definition and get suitable oversight that is proportionate with the amount of payment made to the sources.
Response: DEA is working on a plan to resolve the issues. The action is the same as that of response to the recommendation 1.
3. The department should create controls to make sure that there is comprehensive and appropriate management of documents and to tracking all interactions from the confidential sources.
Response: DEA provided a notification of the revised confidential source policies in an effort to promote consciousness amongst the members of DEA staff and to give clear guiding principle and controls in relation to the right use of the Limited Use of confidential sources class. Formal confidential source classification training has been carried out to make sure that handling of documents, tracking, and receiving information is done correctly. Further details of the training have been availed to OIG in a under another cover.
4. The department should consider developing and promulgating policies that prohibits DEA Special Agents from the utilization of unapproved private correspondence, such email accounts and text messages, to conduct federal operations, which includes interacting with confidential sources.
Response: The current DEA policies want Special Agents to preserve communication with confidential sources, irrespective of the technique used for the correspondence. The Office of Investigative Technology of DEA together with other offices of DEA, is assessing other methods in order to improve operational security, create awareness, and to train during the interaction with confidential sources via electronic mode. After identifying the best practices and techniques, the guiding principles will be formalized into agency policy to guarantee compliance in using only the authorized methods of correspondence when communicating with confidential sources.
5. To inspect the processes currently in use in relation to the utilization of confidential sources who give intelligence-related information. In this case, DEA should consider the following:
· Consulting with the DoJ and FBI to determine the need for processes to implement an autonomous evaluation of confidential sources for assessing the integrity and reliability of a particular source used in intelligence-related missions.
· There is need for the Intelligence Division to create processes for evaluating intelligence-related information and the services availed by the confidential sources in order to make sure that they meet the DEA’s threshold.
· The Intelligence Division should sufficiently track all the funds used in activities linked with the confidential sources.
Response: The Executive Management is in consultations with the FBI in order to discuss the mode in relation to confidential sources. DEA will compare the FBI’s mode with its processes and assess the applicability on its missions. Formal standard operation processes are being developed by the Intelligence Division, which will examine intelligence-related information given by confidential sources.
6. Evaluation of the relevance of the use of “sub-sources” and define whether the exercise should be outlawed or be formalized by formulating policies and procedures to moderate the risk factors.
Response: At present, DEA is evaluating its policies and processes on using sub-sources. The Executive management in consultations with FBI is discussing their methodology in relation to confidential sources and the utilization of sub-sources. DEA will compare both procedures and assess applicability to its operations. In conjunction with the department, DEA will change the policies as appropriately to make sure that all processes are in line with the AG guiding principles.
7. DEA should improve the oversight and management of the Confidential Source program by implementing the following measures:
· Frequently employing more and thorough confidential source management and oversight training in order to make sure that policy are clearly understood and applied.
· Make sure that there is uniformity of confidential source classification sources with criminal backgrounds together with who are the contemporarily used by several DEA offices.
· Make sure that controls on payments to restricted sources incorporate requirements for enough justification and consent.
· Firmer internal controls should be developed for the CSSC in order to make sure that uniformity, exactness, and completeness of information.
· A reconciliation process should be implemented to make sure that payment records are correct, complete, and have uniformity within the confidential source documents.
· Consider evaluating the roles and responsibilities that are linked with the management of the Confidential Source program in order to make sure that vigorous oversight of the establishment, utilization, and payments to confidential sources. It will also guarantee that the field offices are constantly and exhaustively implementing the DEA policy and the AG guidelines.
· Assessment of the head-office level utilization of CSSC for tactical, DEA-wide oversight and the evaluation as well as the observation of the confidential source information.
Response: Apart from issuing the revised confidential policy, a global communication was released highlighting key changes to the confidential source policy in order to guide staff members analyze it and to notify them of new requirements for confidential source documentation in relation to correctness and thoroughness of the establishment. A formalized training on CSC was started at the DEA academy to guarantee more frequent and thorough management and oversight.
References
Office of the Inspector General U.S. Department of Justice. (2015). Audit of the Drug
Enforcement Administration’s Management and Oversight of its Confidential Source Program. Office of the Inspector General U.S. Department of Justice, 1-73. Retrieved from https://oig.justice.gov/reports/2016/a1633.pdf
