Fraud Reporting & Working With USAID OIG Mar 17.pdf · OIG is a valuable resource in combatting...

Fraud Reporting & Working

With USAID OIG

AIGI Daniel Altman

SAC Jonathan Schofield

SAC Chris Reed

Council of International Development Companies

March 3, 2017

The Inspector General

• Appointed by the President and confirmed by the Senate

• Provides independent oversight through:• Program and financial audits• Investigations

• Reports findings to Agency head, Congress, the President, and the Public

• Full law enforcement authority in the United States

Ann Calvaresi BarrInspector General

OIG Investigations

OIG conducts independent investigations into allegations of fraud, corruption, criminal activity, and misconduct in USAID programs worldwide.

OIG is a valuable resource in combatting

fraud and corruption

Where We Operate

San Salvador

Port Au Prince

Dakar

Pretoria

Cairo

Frankfurt

Manila

Kabul

Islamabad

D.C.Tel Aviv

Kampala

Hub Offices

Major Investigative Areas

• Procurement fraud involving USAID projects

• Bribery and kickbacks• Diversion of commodities

and funds to terrorist groups or sanctioned entities

• Misconduct by USAID personnel

• Conflicts of interest

Where does OIG get allegations?

• Self-disclosures by

implementers

• Hotline calls

• Audits/inspections

• Referrals from other

agencies

• Other investigations

Strategic Priority #1

Prevent, deter, detect, and neutralize organized crime targeting USAID’s supply chain for life saving medications, commodities, and associated programming

Strategic Priority #2

Prevent, deter, detect, and neutralize organized crime targeting USAID-funded humanitarian programs including those supporting USG efforts to defeat ISIS

Strategic Priority #3

Collaborate with USAID and industry to establish a standardized Agency-approved process for handling fraud and corruption complaints referred by OIG

Fraud Reporting Systems

Mandatory Reporting for ContractsFAR 52.203-13

Timely disclosure, in writing, to the agency OIG, with a copy to the Contracting Officer, whenever, in connection with the award, performance, or closeout of any Government contract performed by the Contractor or a subcontractor thereunder, the Contractor has credible evidence that a principal, employee, agent, or subcontractor of the Contractor has committed a violation of Federal criminal law involving fraud, conflict of interest, bribery, or gratuity violations found in Title 18 U.S.C. or a violation of the civil False Claims Act (31 U.S.C. 3729-3733).

Counter Trafficking in Persons

FAR 52.222-50: The Contractor shall inform the Contracting Officer immediately of—

(1) Any information it receives from any source (including host country law enforcement) that alleges a Contractor, employee, subcontractor, or subcontractor employee has engaged in conduct that violates this policy; and

(2) Any actions taken against Contractor employees, subcontractors, or subcontractor employees pursuant to this clause.

2 CFR 200.113 and Standard Provision M26 (July 2015)

Consistent with 2 CFR 200.113, applicants and recipients must disclose, in a timely manner, in writing to the USAID OIG, with a copy to the cognizant agreement officer, all violations of federal criminal law involving fraud, bribery, or gratuity violations potentially affecting the Federal award.

Subrecipients must also disclose to OIG and the prime recipient (U.S. and non-U.S. NGOs)

Recipient must include this requirement in all subawards and contracts

Questions from CIDC members…

• Does OIG require grantee fraud reporting?

• How does OIG do industry outreach?

• Does OIG website generate a complaint #?

• What is credible evidence?

• How does OIG interact with SDO? How are

referrals made? Cold comfort letters?

• Trends in mandatory disclosures?

• Average length of an investigation?

• What is your primary source of investigative leads?

Hotline?

• IG subpoenas vs. civil investigative demands

• Middle East and Asia:

SAC Chris Reed

202-712-1710 (office)

chreed@usaid.gov

• Rest of the world:

SAC John Schofield

202-712-5899

jschofield@usaid.gov

• AIGI Daniel Altman202-712-0075

daltman@usaid.gov