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On the Compliance Audit of the Ministry Of Transport (MoT) For the Period July 1, 2015 to June 30, 2016 February, 2018 Yusador S. Gaye, CPA, CGMA Auditor General, R.L. AUDITOR GENERAL'S REPORT

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Page 1: AUDITOR GENERAL'S REPORT - gac.gov.lrgac.gov.lr/auditDoc/Auditor Generals Report on the Compliance Audit... · Francis Aire Yoube HR Director 2012-2015 9. Hannah G. L. Sheriff HR

On the Compliance Audit of the Ministry Of Transport (MoT)

For the Period July 1, 2015 to June 30, 2016

February, 2018 Yusador S. Gaye, CPA, CGMA Auditor General, R.L.

AUDITOR GENERAL'S REPORT

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Auditor General’s Report On the Audit of The Ministry of Transport (MoT) For The Period 1 July 2015 to 30 June 2016

2 Promoting Accountability of Public Resources

Table of Contents 1 DETAILED FINDINGS AND RECOMMENDATIONS ..................................................... 8

1.1 Financial Issues ................................................................................................. 8 1.1.1 Petroleum Products .......................................................................................... 8

1.1.2 Payment made to third party ............................................................................ 9

1.1.3 Unretired Foreign Travels ............................................................................... 10

1.1.4 Delivery Notes ............................................................................................... 11

1.1.5 Re-imbursement from operational funds .......................................................... 12

1.1.6 Unsupported Payment .................................................................................... 14

1.2 Revenue ........................................................................................................... 15 1.2.1 Vehicle Registration ........................................................................................ 15

1.2.2 Eligibility Certificates ...................................................................................... 16

1.3 Control Issues .................................................................................................. 17 1.3.1 Unused Motor Vehicle Certificates .................................................................... 17

1.3.2 Fixed Assets .................................................................................................. 19

1.3.3 IT Strategic Plan ............................................................................................ 20

1.3.4 IT Organizational Structure/ Segregation of Duties ........................................... 21

1.3.5 Service Level Agreement ................................................................................ 22

1.3.6 Offsite Backup Storage ................................................................................... 23

1.3.7 Antivirus ........................................................................................................ 24

1.3.8 IT Business Continuity plan/disaster Recovery plan ........................................... 25

1.3.9 IT Environmental Control ................................................................................ 26

2 ACKNOWLEDGEMENT............................................................................................. 27 Annexure ...................................................................................................................... 27

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Auditor General’s Report On the Audit of The Ministry of Transport (MoT) For The Period 1 July 2015 to 30 June 2016

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Acronyms/Abbreviations/Symbol Acronyms/Abbreviations/Symbol Meaning

AG Auditor General AMEU African Methodist Episcopal University AMEZU African Methodist Episcopal Zion University BEP Bid Evaluation Panel CBL Central Bank of Liberia CGMA Chartered Global Management Accountant COSO Committee of Sponsoring Organizations CPA Certified Public Accountant FAP Fundamental Accounting Principles FAR Fixed Asset Register GAC General Auditing Commission GCA Guidelines Compliance Audit GOL Government of Liberia GPA Grade Point Average ICT Information Communication Technology INTOSAI International Transparency of Supreme Audit Institution ISSAI International Standards of Supreme Audit Institution IBLL International Bank Liberia Limited IT Internet Technology LBR Liberia Business Registry LD, L$ Liberian Dollars LIBTELCO Liberia Telecommunication Corporation LPO Local Purchase orders LRA Liberia Revenue Authority M & E Monitoring and Evaluation MFDP Ministry of Finance and Development Planning MOT Ministry of transport MOU Memorandum of understanding PFM ACT Public Finance Management Act PPCC Public Procurement and Concession Committee PPC Act Public Procurement Concession Act SLAs Services Level Agreements ToR Terms of Reference UL University of Liberia UMU United Methodist University USD, US$ United States Dollars UV Ultra Violets VRS Vehicles Registration System WAACE West Africa Architecture Contractors and Engineer

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Auditor General’s Report On the Audit of The Ministry of Transport (MoT) For The Period 1 July 2015 to 30 June 2016

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Compliance Audit Report on the Ministry of Transport for the period 1 July 2015 to 30 June 2016.

We have audited the activities and financial transactions of the Ministry of Transport compliance with relevant laws and regulations for the period 1 July 2015 to 30 June 2016 consistent with the Auditor General’s mandate as provided for in Section 2.1.3 of the General Auditing Commission (GAC) Act of 2014 as well as the Audit Engagement Terms of Reference (ToR).

Management's Responsibility Management is responsible for the preparation of financial records in accordance with the stated laws and regulations. The audit was conducted on the basis or understanding that the Management of MOT has the responsibility to establish and maintain internal controls necessary to:

• Enable it undertake its contracts award, goods delivery, evaluation and reporting in an effective and efficient manner as well as the preparation of documentation on the procurement that are free from material misstatements whether due to fraud or error and in compliance with authorities that govern them;

• Provide reasonable assurance that adopted policies and prescribed procedures are adhered

to and errors and irregularities, including fraud and illegal acts are prevented or detected; and to provide us with access to the following:

o All information of which the Ministry of Transport Management is aware of that is relevant to its contract awards, goods delivery, evaluation and reporting as well as their related documentation;

o Any additional information that we may request from Management for the

purposes of the review; and

o Unrestricted access to persons within the Ministry of Transport from whom we determine it necessary to obtain reviewed evidence.

Auditor's Responsibility Our responsibility is to independently express a conclusion on the financial records of the Ministry of Transport based on our audit. Our audit was conducted in accordance with the International Standards of Supreme Audit Institutions (ISSAIs), Fundamental Auditing Principles (FAP) and Guidelines for Compliance Audit (GCA). Those principles require that we comply with ethical requirements and plan and perform the audit so as to obtain reasonable assurance as to whether the use of MOT’s Funds are in compliance, in all material respects, with stated laws and regulations. An audit involves performing procedures to obtain sufficient appropriate evidence to support our conclusion. The procedures performed depend on the auditor's professional judgment, including assessing the risk of material non-compliance, whether due to fraud or error. The audit procedures performed are those we believe are appropriate in the circumstances. We believe that the audit evidence gathered is sufficient and appropriate to provide the basis for our conclusion.

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Basis for Adverse Conclusion No evidence that payments made by tax payers for vehicle registration amounting to US$ 21,775.00 and L$140,000.00 could be traced to the Liberia Revenue Authority records or transitory account maintained at the International Bank Liberia. No evidence of the distribution of 6,912.14 gallons of petroleum product value at US$20,668.11. The Management failed to submit for review three (3) payments vouchers amounting to US$12,657.00. No evidence of delivery notes for payment amounting to US$3,000.00 made for stationery. No evidence that payments made by tax payers for eligibility certificate (revenue instruments) amounting to US$4,424.00 and L$78,140.00 could be traced to the Liberia Revenue Authority records or transitory account maintained at the International Bank Liberia. The Management did not maintain fixed assets register (FAR) that would show a list of coded assets, date of purchase, cost, location and current condition. As a result we could not carry on physical verification of fixed assets to establish the ownership of assets acquired. Additionally, there was no evidence of a fixed asset disposal log. Adverse Conclusion Based on the audit work performed, we found that, because of the significance of the matters noted in the Basis for the Adverse Conclusion paragraphs above, the activities and financial transactions of the Ministry of Transport are not in compliance, in all material respects, with stated laws and regulations. Monrovia, Liberia February, 2018

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Background

The audit of the Ministry of Transport was commissioned by the Auditor General (AG) under the statutory mandate of the Auditor- General as provided for under Section 2.1.3 of the General Auditing Commission (GAC) Act of 2014. The audit covered the fiscal year, 1 July 2015 to 30 June 2016. The mandate of the Ministry of Transport, as provided for by an Act of the Legislature on August 25, 1987, includes among others to promulgate and administer the transportation and insurance laws, as well as to plan and execute policies related to all modes of land, sea and air transportation services. The Ministry also administers and implements the Transportation Law, the insurance Law, within the Republic of Liberia and aboard; it represents the Government’s interest in all negotiations in connection with the Government participation in shipping and to represent the Government; Maritime Law and also plan and execute policies relating to all modes of land, rail, and sea transport service. It also disseminate information related to this Act and information related thereto; and develop rules, instructions, regulations and related documentation on public procurement and concessions procedures, including designing formats in furtherance of the Act; etc. Key Personnel

No. Name Rank Tenure 1. Samuel Wulu Minister 2017-Present 2 Angela Bush- Cassell Minister 2014-2016 3. Bushuben M. Keita Deputy Minister Administration/Insurance 2014-Present 4. Juanita Traub Bropleh Deputy Minister/ Land & Rail Transport 2015 - Present 5. Nickey D. Jah Assist. Minister Administration/Insurance 2012-Present 6. Abu B. Kamara Assistant Minister/Land & Rail Transport 2012-2015 7 Kansualism B.Kansuah Assistant Minister/Land & Rail Transport 2016-Present 8. Francis Aire Yoube HR Director 2012-2015 9. Hannah G. L. Sheriff HR Director 2015-Present 10. Arthur L. Gliklay Comptroller 2012-Present Audit Objectives The main objective of the audit is to gather sufficient appropriate audit evidence to conclude whether the activities and financial records of the Ministry of Transport Management for the period 1 July 2015 to 30 June 2016 are in compliance, in all material respects with policies, procedures, applicable laws, regulations, and are free of material errors. Audit Methodology The audit was conducted in accordance with International Standards of Supreme Audit Institutions (ISSAIs) Fundamental Auditing Principles and Guidelines for Compliance Audit. Those standards require that we plan and perform the audit to obtain reasonable assurance that the financial information provided by the Ministry of Transport are in compliance, in all material respects with policies, procedures, applicable laws, regulations, and are free of material errors. In furtherance of this, we undertook audit procedures as would enable us to attain the above objective.

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Our audit also took cognizance of the requirements under the Auditor General’s mandate as spelt out under Sections 2.1.3 of the GAC Act of 2014. Our audit approach included observation, inquiries, inspections, re-performance, confirmation, and analytical procedures on areas we considered as high risk. While the audit was not directed at reporting the following, we have reported on the below issues which came to our attention during the course of the audit:

• Non- effective performance of the program - relates to management’s responsibility to undertake activities in a non-effective and non-efficient manner.

• Non-delivery of goods and services – relates to management’s non-exercise of responsibility

to ensure that all goods and services procured are delivered.

• Instances of non-compliance with applicable laws and regulations - relate to management’s non-exercise of responsibility to use resources, and fulfill accountability requirements, in accordance with applicable agreements, laws and regulations governing contracts award, goods and service delivery, evaluation and reporting.

• Waste – relates to management’s non-exercise of responsibility to obtain and apply

resources in an economical manner, without any public money being wasted.

• Instances of abuse- relates to management’s non- exercise of responsibility to meet the expectations of the National Legislature and the public as they relate to appropriate standards of behavior.

Limitation of Responsibility We reviewed the systems and management controls operated by the Ministry of Transport management only to the extent we considered necessary for the effective conduct of this audit. As a result, our review may not have detected all weaknesses that existed or all improvements that could be made.

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1 DETAILED FINDINGS AND RECOMMENDATIONS 1.1 Financial Issues 1.1.1 Petroleum Products

Observation

1.1.1.1 Regulation P.9 (2) of the PFM Act of 2009 states “Payments except for statutory transfers and debt service shall be supported by invoices, bills and other documents in addition to the payment vouchers”.

1.1.1.2 It was observed during the conduct of the audit that Management procured the total of 33,923.41 gallons of petroleum product value at US$101,430.00. There was no evidence of the distribution of 33,923.41 gallons of petroleum product value at US$101,431.00. See table 1 below for details:

Table 1: Petroleum Products not accounted for

Monthly Utility Fuel

Distribution

Financial Statements

(A) US$

Total gallons actual

Procurement (B)

Value of Total

gallons of product

procured $ C=(B) x(E)

Total Gallon

s Signed for (D)

Unit Price

(US $) signed for (E)

Value of

gallon signed for US$ F=(D)x(

E)

Total Gallons to

be accounted

for G=(B)-(D)

Value of total

gallons to be

accounted for H= (E) X (G)

US$ 2015/2016 101,431.00 33,923.41 101,430.00 N/A 2.99 N/A 33,923.41 101,431.00

Risk

1.1.1.3 Petroleum products procured without evidence of distribution could cast doubt on the regularity of the transactions and undermine accountability and transparency in the public sector. Recommendation

1.1.1.4 The Management should provide substantive justification for the unaccounted 33,923.41 gallons of petroleum products amounting to US$101,431.00 without evidence of distribution log for 2015/2016.

1.1.1.5 Going forward, the Management should ensure that there are signed petroleum products receipts and distribution logs to track all procured quantities of fuel.

Management’s Response

1.1.1.6 For the period under review, the actual amount expended by the MOT to procure fuel and lubricant was USD451, 072.00 and not USD901, 000.00. It is informative to note that the USD910,000.00 may be the Legislature approved budgetary appropriation which differs from the actual outturn.

Former Minister Eugene Lenn Nagbe’s Response

1.1.1.7 As Minister of Transport then, my responsibility was to institute where there are no controls or strengthen where there are and to make sure the Ministry under my watch adhere to all Public financial management and procurement laws/rules or regulations

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but through the relevant department(s) within the Ministry. The department of Administration with my supervision administered the acquisition, distribution and report of Scratch Cards and Petroleum products during the period under review. All documentations relating to these transactions can be made readily available by the department of administration specifically the office of the comptroller.

1.1.1.8 Also, as Auditors, I am sure you are aware that Budgetary Appropriations,

Allotments and actual budget execution figures are different. The actual expended figure under petroleum products for instance is US$451,072 instead of US$901,000 as asserted by you.

Auditor General’s Position

1.1.1.9 We obtained the amounts used to purchase the petroleum products from the paid vouchers during the audit. We reviewed the documents provided by the Management in response to the Management Letter which amounts to US$80,762.89. Therefore, we have adjusted the total gallons of gasoline to 6,912.14 values at US$20,668.11 ($101,431.41 – $80,762.89) to be accounted for by Management.

1.1.2 Payment made to third party

Observation 1.1.2.1 Regulation B 28 of the PFM Act of 2009 states that “a payment shall be made only to

the person or persons named on the payment voucher or to their representatives duly and legally authorized in writing to receive the payment.”

1.1.2.2 It was observed during the conduct of the audit that Management made payment to

third party amounting to L$88,000.00 from the operational fund account rather than in the name of the service providers/ vendors during the periods under audit. See Table 2 below for details:

Table 2: Payments made to third party

Date Payee Description Internal Voucher Check# L$ 2015/2016 MORRIS K.

TUAH-GEBOR JR.

FEEDING STAFFS ASSIGNED AT GSA

2134 67 88,000.00 MAR.11,16

Risk

1.1.2.3 Checks raised in the names of employees or individuals for procurement of goods/ services could be diverted to personal use thus leading to misappropriation of funds.

Recommendation

1.1.2.4 The Management should provide substantive justification with appropriate documentation for authorizing payments amounting to L$88,000.00 in the name of MoT staff other than the vendor/ service provider.

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1.1.2.5 Going forward, the Management should make payment only in the names of vendors/service providers or their authorized representative.

Management’s Response 1.1.2.6 These payments were not intended for the procurement of goods and services for

which payments should have been made to vendors but instead they were basically incidental payments such as allowances, periderms and miscellaneous expenditures for the convening of the METAGRI roving seminar and other programs in the various counties and the central offices in Monrovia.

Former Minister Eugene Lenn Nagbe’s Response

1.1.2.7 Unfortunately, these payments were not procurement related so was not meant for vendors and service providers. All documents relating to these transactions supporting my argument can be made available by the department of Finance by the MOT.

Auditor General’s Position

1.1.2.8 Management’s assertion that these payments were not intended for goods and services is not supported. The additional documents submitted in response to the Management Letter show that the payments were made for goods, catering services and bulk payments to a staff for several staff travels to Guinea and Liberia. The payments for travels should have been made individually to all the staff who undertook the travels and not in the name of a staff for disbursements to other staff members. These payments constitute third party payments because they were not made to the beneficiaries or their authorized representatives.

1.1.2.9 Further, the documents submitted by Management show that there was only one expenditure related to METAGRI and not all the expenditure as claimed by Management. Therefore, all the staff members in whose names the bulk payments were made should account for the amounts. Therefore, Management is in breach of financial discipline in line with Regulation A. 20 of the PFM Act of 2009.

1.1.3 Unretired Foreign Travels

Observation 1.1.3.1 Section 27 of the Foreign Travel Ordinance of 2012 requires that “Upon return from

abroad, officials are required to submit to the Ministry of Finance, a Travel settlement form as per Annexure II within 21 days from the date of return from tour or before date of next journey, whichever is earlier. In very exceptional cases where the second tour is performed immediately after return from the first tour, the second advance may be granted with the specific written approval of the ministry concerned explaining the reasons thereof.”

1.1.3.2 Section 28 of the Foreign Travel Ordinance of 2012 requires that “No future travel

advances shall be paid to anyone who has failed to submit the prescribed travel Disbursement form, for any previous journey within 21 days. The entire travel advance will be recovered from those who fail to submit the travel settlement form on return from their visit a broad, and those who subsequently leave the services of the Government, from any arrears due to them by the Government.”

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1.1.3.3 It was observed during the conduct of the audit that a foreign travel payment amounting to US$2,987.00 were made without evidence of a foreign travel retirement or a completion of the travel settlement form during the 2015/16 periods under audit. See Table 3 below for details.

Table 3: Unretired Foreign Travels

Date Payee Description Voucher # Amt US$ 20 Nov.2015 Angela Cassel Bush Foreign daily subsistence allowances 253572 2,987.50

Risk 1.1.3.4 The failure to retire travel allowances could undermine public accountability and abuse

of public resources. Recommendation

1.1.3.5 The Management should ensure that officials making travels on its behalf comply with the Executive Travel Ordinance.

1.1.3.6 The Management should ensure that all officials who made travels on behalf of MoT

retire the total of US$2,987.50 disburse as allowances during time of travel.

Management’s Response 1.1.3.7 Management recognizes the audit’s observation on unretired travels made by officials

and staff of MOT during the period under audit. The fact is that the ministers sent their travels retirement information to MFDP without copies sent to MOT Finance Division. However, see attached copies of those management had received from some officials and staff. Going forward, management will ensure the retirement of all travels expenses.

Auditor General’s Position

1.1.3.8 Management’s assertion is not materially supported. The Management should recover the unretired travel advances from all staff and former staff in line with the Travel Ordinance. Also, the Management and the Ministry of Finance and Development Planning should enforce the travel ordinance so that any traveler who fails to retire his/her travel advance is denied the opportunity to undertake subsequent travel in line with the travel ordinance.

1.1.4 Delivery Notes

Observation 1.1.4.1 Section 43 (1) of the PPC Act of 2005 amended and restated 2010 states that “The

Procuring Entity shall preserve all documentation relating to the procurement proceedings in accordance with applicable rules concerning archiving of Government documentation, but at a minimum it shall be kept for a period of six (6) years following the date of final.”

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1.1.4.2 It was observed during the conduct of the audit that payment amounting to US$3,000.00 was made for stationery without evidence of delivery notes. See Table 4 below for details.

Table 4: No evidence of delivery notes

Date Payee Description Vouchers # Amt. US$ 2015/2016

15 Dec. 2015 Lion stationery Stationery 2718363 3,000.00

Risk 1.1.4.3 Payments made without delivery notes could lead to diversion of items procured to

personal use/ theft.

Recommendation 1.1.4.4 The Management should provide substantive justification for payments amounting to

US$3,000.00 without delivery notes. Management’s Response

1.1.4.5 All payments for procurement of goods and services were duly supported by the requisite supporting documents: Local purchase order, quotations, payment vouchers, Invoices, delivery notes, Good receipt notes and checks.

Former Minister Eugene Lenn Nagbe’s Response

1.1.4.6 All goods paid for had delivery notes attached to them in face as the basis of my signature as Minister. These delivery notes form the basis for the vendor to request payment through credit invoice and all other documents including an LPO. If these payments are external payment that is by the MFDP, delivery notes and etc. must be attached before payment is consummated. The department of Finance has copies of these but you may also do third party verification with the MFDP.

Auditor General’s Position

1.1.4.7 We reviewed the additional documents provided by Management and realized that the Management yet to account for payment without delivery note amounting to US$3,000.00. Further, Management is in breach of financial discipline in line with Regulation A.20 in line with the PFM Act of 2009.

1.1.5 Re-imbursement from operational funds

Observation

1.1.5.1 Regulation F6 (1) of the PFM Act of 2009 states that “financial obligations undertaken by residents, who do not act on behalf of the Government, Social Security Corporation, or Central Bank of Liberia, shall constitute private debt.”

1.1.5.2 Regulation F6 (2) of the PFM Act of 2009 states that ”Private debt shall not be

guaranteed by the government and shall not be a liability of the government Social Security Corporation or the Central Bank of Liberia, except for the cases where a government guarantee has been issued according to the appropriate procedure.”

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1.1.5.3 It was observed during the conduct of the audit that payments for reimbursements amounting to US$2,146.42 were made from the operational fund accounts in the name of individuals without evidence that a Government guarantee has been ensure according to the appropriate procedures during the 2015/16 fiscal year. See Table 5 below for details.

Table 5: Reimbursement from Operational funds

Date Payee Description Internal voucher Check# Amt US$

Jan. 14,2015 Buster Morris

Reimbursement for the purchase of a seal embosser for use by MoT

2014 25

361.00 Nov. 24,2015 Keturah

Flahma Payment for reimbursement in favor of Minister Bush for expenditure incurred on behalf of Ministry Transport

2342

75 580.00

Mar. 24, 16 Keturah Flahma

Re-imbursement to the Ministry of Transport for Retro reflective jackets purchase for the Ministry inspector

2139 73

1,205.42 Total 2,146.42

Risk

1.1.5.4 The use of private money for official transaction without the appropriate procedures in place could lead to waste and abuse as payment could be made for personal items.

Recommendation

1.1.5.5 The Management should provide substantive justification for using private money for official transaction.

1.1.5.6 Going forward, the Management should ensure that the appropriate procedures are in

place before reimbursements are made for private money used for official transactions.

Management’s Response 1.1.5.7 These reimbursements were not private debts as mentioned in this finding. These were

legitimate claims against the MOT for which payments were made. These were extra expenditure incurred by the employees procuring goods and services for the MOT.

Former Minister Eugene Lenn Nagbe’s Response

1.1.5.8 These payments or reimbursements were legitimate claims against the MOT and with receipts that informed our decision to pay. Further documents can be found within the department of Finance.

Auditor General’s Position

1.1.5.9 The procurements of goods and services should be made by the procurement unit rather than employee incurring expenditure on behalf of the Ministry. If an employee has an emergency situation and has to procured, the employee should contact the procurement unit to ensure that the procurement meets the requirement of the PPC Act.

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1.1.5.10 Further, we reviewed the documents provided by the Management in response to the Management Letter which amounts to US$361.00. Therefore, we have adjusted payments for reimbursement from operational funds to US$1,785.42 ($2,146.42 – $361.00) to be accounted for by Management. The Management is in breach of financial discipline in line with Regulation A.20 of the PFM Act of 2009.

1.1.6 Unsupported Payment

Observation

1.1.6.1 Regulation P.9 (1), and (3) of the PFM Regulation of 2009 states, “All disbursements or payments of public moneys shall be properly supported by pre-numbered payment vouchers.”

1.1.6.2 Regulation (3) “All payment vouchers shall be typewritten or made out in ink or ball point pen and shall contain or have attached particulars of the services, goods or works procured including dates, numbers, rates so that they can be checked without references to any other document.”

1.1.6.3 It was observed during the conduct of the audit that the Management failed to submit

for review three (3) payments vouchers amounting to US$12,657.00 See Table 6 below for details.

Table 6: Unsupported payments No Date Names Vouchers # Amounts US$ Comments 1. City Car Rental V#0253 1,545.00 No payment voucher 2. 23/Nov./2015 Subsistence

Allowance V#

3,762.00 No payment voucher

3. 19/July/2016 MOT V# 0003 7,350.00 No payment voucher Total 12,657.00

Risk

1.1.6.4 Failure on the part of Management to submit payments vouchers and other supporting documents could cast doubt on the regularity of the transactions and undermine public sector accountability and transparency.

Recommendation

1.1.6.5 The Management should provide substantive justification for making payments without supporting documentation.

1.1.6.6 The Management should provide all necessary documents for the unsupported

payments.

Management’s Response 1.1.6.7 The GAC assertion that these payments were unsupported is a misrepresentation of the

facts. These payments were duly supported, except for two of the transactions (Stargate and Secure Risk). Notwithstanding, these payment vouchers were previously audited by the GAC during a special financial investigation conducted on the Weigh Bridge for which the management did not receive a copy of published report . Besides,

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the mathematical calculation as it relates to the aggregate amount of the mentioned unsupported six unseen payment vouchers is inaccurate. The respective payment vouchers amount was misstated.

Former Minister Eugene Lenn Nagbe’s Response

1.1.6.8 The unsupported payment by your table total should been US$76,267.99 instead the US$75,508 mention by you. However, all payments were supported under my watch that informed the basis for my signature as Minister. Whenever payments are incomplete in terms of supporting documents, I would not approve such. Payment vouchers for all payments including procurement related documents are both kept by the MOT finance department or the MFDP because payments to Stargate and Secure Risk were made by the MFDP on payment voucher that came from the MOT finance department.

Auditor General’s Position

1.1.6.9 We reviewed additional documents provided by the Management and adjusted the unsupported payments realizing that the Management has to account for the amount amounting to US$12,657.00. Further, Management is in breach of financial discipline in line with Regulation A. 20 of the PFM Act of 2009.

1.2 Revenue

1.2.1 Vehicle Registration Observation

1.2.1.1 Section 7 of the Revenue code of Liberia of 2000 states that “Unless expressly provided otherwise by law, all tax revenues shall be considered General Revenues of Liberia, and shall be paid into the Consolidated Fund and available for appropriation by the Legislature for the general purposes of the Government.”

1.2.1.2 According to the MOU entered into on the 4th day of March 2015 by the Government of

Liberia, the Union Strong Group and International Bank of Liberia states that “the GoL of Liberia through the MFDP and LRA, in agreement with the Central Bank of Liberia, shall establish two (2) transitory accounts into which proceeds from the sale of the vehicle license plates and registration stickers will be deposited. One account shall be for United States Dollars payments and the other shall be for Liberian Dollars payments.”

1.2.1.3 It was observed during the conduct of the audit that the vehicle registration data submitted for the period under audit shows tax payers made payments for vehicle registration amounting to US$21,775.00 and L$140,000.00 which could not be traced to the Liberia Revenue Authority records or Transitory Account maintain with the International Bank Liberia Limited for the period. See annexure I below.

Risk 1.2.1.4 Vehicle Registration payments not being traced to LRA records or International Bank

Liberia accounts could be diverted to personal use or misappropriated thereby denying the Government of Liberia the needed revenue.

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Recommendation 1.2.1.5 The Management should provide substantive justification for revenue amounting to

US$21,775.00 and L$140,000.00 that could not be traced to LRA records or the transitory account at IBLL for 2015/2016.

1.2.1.6 Going forward, the Management should ensure that all vehicle registration payments

are deposited in the IBLL transitory accounts.

Management’s Response 1.2.1.7 The Auditors were unable to trace and identify the actual deposits to the LRA records or

transitory account due to the overlapping of the seal on the receipt numbers. 1.2.1.8 Notwithstanding, these monies were actually deposited to the LRA revenue account at

International Bank Liberia Limited as depicted by the registration documents gathered from the Land and Rail Department of the Ministry of Transport in reconciliation with LRA Motor Vehicle Registration Revenue receipt data.

Former Minister Eugene Lenn Nagbe’s Response

1.2.1.9 There were agreements and procedures between the CBL, IBLL, LRA and MOT as stated by you that all payments directly be made to the special accounts. The MOT was responsible to bill the clients and verify payments before the issuance of the license plates and eligibility certificates something the Ministry did. These payments can be traced to the LRA except receipts issued by the banks were allegedly fraudulent.

Auditor General’s Position

1.2.1.10 Management’s assertion that “The Auditors were unable to trace and identify the actual deposits to the LRA records or transitory account due to the overlapping of the seal on the receipt numbers” is not materially supported. The receipts numbers received from Management in response to the Management letter did not match with documents received from the Liberia Revenue Authority and International Bank Liberia Limited. Therefore, we refer this matter to the Liberia Anti-Corruption Commission for further investigation.

1.2.2 Eligibility Certificates

Observation

1.2.2.1 Section 7 of the Revenue code of Liberia (2000) Tax and Revenue states that “Unless expressly provided otherwise by law, all tax revenues shall be considered General Revenues of Liberia, and shall be paid into the Consolidated Fund and available for appropriation by the Legislature for the general purposes of the Government.”

1.2.2.2 It was observed during the conduct of the audit that the records of eligibility certificates

(revenue instruments) for the period under audit indicate that taxpayers made payments amounting to US$4,424.00 and L$78,140.00. These payments could not be traced to the LRA records. See annexure II below.

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Risk 1.2.2.3 Eligibility Certificates payments that could not be traced to the LRA records and GT

Bank statement could lead to Government’s resources being diverted to personal use.

Recommendation 1.2.2.4 The Management should provide substantive justification for uncollected revenue in the

amounts of US$4,424.00 and L$78,140.00.

Management’s Response 1.2.2.5 The Auditors were unable to trace and identify the actual deposits to the LRA records or

transitory account due to the overlapping of the seal on the receipt numbers. 1.2.2.6 Notwithstanding, these monies were actually deposited to the LRA revenue account at

International Bank Liberia Limited as depicted by the registration documents gathered from the Land and Rail Department of the Ministry of Transport in reconciliation with LRA Eligibility Certificate Revenue receipt data.

Former Minister Eugene Lenn Nagbe’s Response

1.2.2.7 There were agreements and procedures between the CBL, IBLL, LRA and MOT as stated by you that all payments directly be made to the special accounts. The MOT was responsible to bill the clients and verify payments before the issuance of the license plates and eligibility certificates something the Ministry did. These payments can be traced to the LRA except receipts issued by the banks were allegedly fraudulent. Auditor General’s Position

1.2.2.8 Management’s assertion that “The Auditors were unable to trace and identify the actual deposits to the LRA records or transitory account due to the overlapping of the seal on the receipt numbers” is not materially supported. The receipts numbers received from Management in response to the Management Letter did not match the documents received from the Liberia Revenue Authority and International Bank Liberia Limited. Therefore, we refer this matter to the Liberia Anti-Corruption Commission for further investigation.

1.3 Control Issues 1.3.1 Unused Motor Vehicle Certificates

Observation 1.3.1.1 Regulation B.25 (1) of the PFM Act of 2009 states, “A head of government agency shall

ensure that moneys are utilized in a manner that secures both optimum value for money and the intention of the Legislature.”

1.3.1.2 It was observed during the conduct of the audit that payments amounting to US$56,250.00 and US$3,600.00 were made for 125,000 pieces of Motor Vehicle Registration Certificate Papers and 200 pieces of Ultra Violet Flashlights; however, 39,000 pieces of certificate papers and 197 pieces of UV flashlights amounting to US$17,550.00 and US$3,546.00 respectively are stored at the MoT without evidence

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that they will be utilized. Additionally, we observed leakages in the environment the items are being kept during the fiscal period. See table 8 below for details:

Table 8: Unused Motor Vehicle certificates

Expenditure Date

Payee

Description

Unit Pric

e US$ (A)

Quantity

procured (B)

Cost of quantity procured

US$ C=(A*B)

Used quant

ity D

Unused

quantity (E)

Cost of Total

Unused US$

F=(A*E)

Cost of Total used

US$ D=(A*D)

June 10,2015

Union Strong Group Inc.

Motor Vehicle Registration Certificates papers.

0.45 125,000 56,250.00

86,000 39,000 17,550.00

38,700.00 JUNE 10,2015

Union Strong Group Inc.

Ultra Violet Flashlight.

18 200 3,600.00

3 197 3,546.00

54.00 Total 21,096.00 38,754.00

Risk 1.3.1.3 The Management’s failure to safeguard Motor Vehicles Certificate papers and UV flash

lights could lead to waste of resources and undermines the achievement of value for money.

1.3.1.4 The Management failure to procure the needed quantity of certificate papers and UV

Flash lights could lead to was and abuse of Government resources and undermines public Sector accountability.

Recommendation

1.3.1.5 The Management should provide substantive justification for the procurement of motor vehicle excess certificates and UV flash lights that had not been utilized.

1.3.1.6 Going forward, the Management should always verify the past performance reports on

motor vehicle registration to avoid procurement of excess motor vehicle certificate papers for future use.

Management’s Response

1.3.1.7 Procurement was based on GOL/MOT’s plan to decentralize the registration of vehicles in the various counties involving vigorous inspection that needed materials and logistics such as preprinted extra certificate forms, Uv flashlight for detecting fake documents ect.

1.3.1.8 Management is taking all necessary steps to safeguard and utilize these items for the

anticipated purposes.

Former Minister Eugene Lenn Nagbe’s Response 1.3.1.9 Acceptable that these materials including light are still being kept in the warehouse of

the MOT. The Ministry is trying to decentralize it operations across country so as soon as these arrangements are complete; they will be supplied in the various counties.

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Auditor General’s Position 1.3.1.10 Management’s assertion is not materially supported. The equipment are being kept in

an unsafe environment. There are watermark on some of the certificates which could render them unusable. Also, the County Service Centers are now operational around Liberia and the certificates are still not being utilized. The Management of the MoT should avoid wasteful expenditure that cost the Government financial loss. Therefore, Management is in breach of financial discipline in line with Regulation A.20 of the PFM Act of 2009.

1.3.2 Fixed Assets

Observation 1.3.2.1 Regulation V.1 (2) of the PFM Act of 2009 states that “The Head of Government Agency

must take full responsibility of assets assigned to him by the General Services Agency and ensure that proper control systems exist for assets and that:(a) preventive mechanisms are in place to eliminate theft, losses, wastage and misuse; And (b) inventory levels are at an optimum and economical level”.

1.3.2.2 It was observed during the conduct of the audit that the Management did not maintain

fixed assets register (FAR) that would show a list of coded assets, date of purchase, cost, location and current condition. As a result we could not carry on physical verification of fixed assets to establish the ownership of assets acquired. Additionally, there was no evidence of fixed asset disposal log.

Risk

1.3.2.3 In the absence of fixed assets listing, the ownership and the existence of the assets cannot be assured and could be susceptible to theft. Recommendation

1.3.2.4 The Management should provide substantive justification for not providing fixed assets listing for all assets acquired for the period under audit.

1.3.2.5 Going forward, the Management should ensure that fixed assets registry is maintained

so as to keep track of all assets acquired and disposed for the period under audit. Additionally, proper fixed assets internal controls policies and procedures aligned with PFM regulations should be adopted and implemented for the maintenance of fixed assets. Management’s Response

1.3.2.6 The Management acknowledges the auditor’s recommendation and would like to inform the GAC that its fixed Assets Register is presently being updated. A copy of the register will be submitted to the GAC following the completion of the on-going coding and updating of MOT’s assets by management and the General Services Agency.

Former Minister Eugene Lenn Nagbe’s Response

1.3.2.7 Findings acknowledged and the MOT is updating its fixed assets registry by assigning a specific staff who will be responsible from time to time as required.

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Auditor General’s Position 1.3.2.8 We acknowledge Management’s acceptance of our recommendation. Management’s

acceptance would be validated during subsequent audit. However, Management’s is in breach of financial discipline in line with Regulation A.20 of the PFM Act of 2009.

1.3.3 IT Strategic Plan

Observation 1.3.3.1 COBIT 4.1 PO 1.4 provides that “a strategic plan should be created in cooperation with

relevant stakeholders. It should define how IT goals will contribute to the enterprise’s strategic objectives and related costs and risks. It should include how IT will support IT-enabled investments programmes, IT services and IT assets. IT should define how the objectives will be met the measurements to be used and the procedures to obtain formal sign-off from the stakeholders. The IT strategic plan should cover investment/operational budget, funding sources, sourcing strategy, acquisition strategy, and legal and regulatory requirements. The strategic plan should be sufficiently detailed to allow for the definition of tactical IT plan.”

1.3.3.2 It was observed during the conduct of the audit that there was no evidence that the

Ministry maintained an IT Strategic Plan for the periods 2012 through 2014 to provide an overall IT strategic direction for the entity.

Risk

1.3.3.3 The non-establishment of an IT strategic plan could result in IT goals not contributing to the entity’s strategic objectives and related costs and risks.

Recommendation

1.3.3.4 The Management should create its IT Strategic Plan to guide the operations of the entity.

Management’s Response

1.3.3.5 Management acknowledges the audit observation on all aspects of IT administration and management. However, management would not carry out such capital intensive venture in the absence of Nation Government budgetary support.

1.3.3.6 Management is also anticipating venturing into an agreement with a renounced partner

that could handle the Ministry’s IT infrastructure. It is expected that all the audit’s observations and recommendations on IT will be settled.

Auditor General’s Position

1.3.3.7 We acknowledge Management’s acceptance of our recommendation. We will validate Management’s acceptance during subsequent audit.

1.3.4 IT Strategy Committee and IT Steering Committee

Observation 1.3.4.1 COBIT 4.1 PO 4.2 requires entities to establish an IT strategy committee at the board

level. This committee should ensure that IT governance, as part of enterprise

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governance, is adequately addressed; advised on strategic direction, and review major investment on behalf of the full board.

1.3.4.2 COBIT 4.1 PO 4.3 requires the establishment of IT steering committee (or equivalent)

composed of executive, business and IT management to: • Determine prioritization of IT enabled investment programmes in line with the

enterprise’s business strategy and priorities.

• Track status of projects and resolve resource conflict.

• Monitor service level and service improvement. 1.3.4.3 It was observed during the audit that there was no evidence of an IT steering

committee to address issues relating to IT projects, IT operations and IT control environment. Risk

1.3.4.4 The non-establishment of an IT strategic committee and IT steering committee at the board level could result in IT governance, not being adequately addressed.

Recommendation

1.3.4.5 The Management should establish an IT steering committee, which should carry out her core function to adequately monitor the service level and ensure improvement of the IT governance.

1.3.4.6 The Management should establish an IT strategic committee to carry out her core function, to adequately address the IT governance issues which include formulating strategic direction and reviewing major investment as it relates to enterprise governance.

Management’s Response 1.3.4.7 Management acknowledges the audit observation on all aspects of IT administration

and management. However, management would not carry out such capital intensive venture in the absence of Nation budgetary support.

1.3.4.8 Management is also anticipating venturing into an agreement with a renounced partner

that could handle the Ministry’s IT infrastructure. It is expected that all the audit’s observations and recommendations on IT will be settled. Auditor General’s Position

1.3.4.9 We acknowledge Management’s acceptance of our recommendation. We will validate Management’s acceptance during subsequent audit.

1.3.5 IT Organizational Structure/ Segregation of Duties

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Observation 1.3.5.1 COBIT 4.1 PO4.5 provides for the establishment of an internal organizational structure

that reflects business needs. In addition, put a process in place for periodically reviewing the IT organizational structure to adjust staffing requirements and sourcing strategies to meet expected business objectives and changing circumstances.

1.3.5.2 PO4.11 Segregation of Duties Implement a division of roles and responsibilities that reduces the possibility for a single individual to compromise a critical process. Make sure that personnel are performing only authorized duties relevant to their respective jobs and positions.

1.3.5.3 It was observed during the audit that there was evidence that the Ministry develop its

IT organizational chart. There was no documented term of reference for IT staff defining their roles and responsibilities. The Ministry also does not have a documented process flow.

Risk

1.3.5.4 Undefined IT roles and responsibilities could result in the IT function that is non-responsive to the needs of the Ministry. Recommendation

1.3.5.5 Management documents its process flow and also defines the roles and responsibilities of IT staff.

Management’s Response

1.3.5.6 Management acknowledges the audit observation on all aspects of IT administration and management. However, management would not carry out such capital intensive venture in the absence of Nation Government budgetary support.

1.3.5.7 Management is also anticipating venturing into an agreement with a renounced partner

that could handle the Ministry’s IT infrastructure. It is expected that all the audit’s observations and recommendations on IT will be settled.

Auditor General’s Position

1.3.5.8 We acknowledge Management’s acceptance of our recommendation. We will validate Management’s acceptance during subsequent audit.

1.3.6 Service Level Agreement

Observation 1.3.6.1 DS1.3 Service Level Agreements Define and agree to SLAs for all critical IT services

based on customer requirements and IT capabilities. This should cover customer commitments; service support requirements; quantitative and qualitative metrics for measuring the service signed off on by the stakeholders; funding and commercial arrangements, if applicable; and roles and responsibilities, including oversight of the SLA. Consider items such as availability, reliability, performance, capacity for growth, levels of support, continuity planning, security and demand constraints.

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1.3.6.2 It was observed during the conduct of audit that there was no evidence Service Level Agreement between LIBTELCO and the Ministry stating the technical commitments and responsibilities for the provision of internet services.

Risk

1.3.6.3 The absence of service level agreement could deny management of quality services as may be required.

1.3.6.4 The non-establishment of service level agreements could result in poor understanding

of IT cost, benefits, strategy and policies.

Recommendation 1.3.6.5 The Management should establish a service level agreement that will outline the

technical commitments and responsibilities for the provision of internet services.

Management’s Response 1.3.6.6 Management acknowledges the audit observation on all aspects of IT administration

and management. However, management would not carry out such capital intensive venture in the absence of Nation Government budgetary support.

1.3.6.7 Management is also anticipating venturing into an agreement with a renounced partner

that could handle the Ministry’s IT infrastructure. It is expected that all the audit’s observations and recommendations on IT will be settled.

Auditor General’s Position

1.3.6.8 We acknowledge Management’s acceptance of our recommendation. We will validate Management’s acceptance during subsequent audit.

1.3.7 Offsite Backup Storage

Observation 1.3.7.1 DS4.9 Offsite Backup Storage Store offsite all critical backup media, documentation and

other IT resources necessary for IT recovery and business continuity plans. Determine the content of backup storage in collaboration between business process owners and IT personnel. Management of the offsite storage facility should respond to the data classification policy and the enterprise’s media storage practices. IT management should ensure that offsite arrangements are periodically assessed, at least annually, for content, environmental protection and security. Ensure compatibility of hardware and software to restore archived data, and periodically test and refresh archived data.

1.3.7.2 It was observed during the audit that there was no evidence that the Ministry has an

outside backup storage. Risk

1.3.7.3 If backups are not stored at an offsite location by the Ministry it might not recover the Ministry’s data in the case of disaster.

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Recommendation 1.3.7.4 The Ministry should ensure that its backup data is stored at an offsite Data Center.

Management’s Response 1.3.7.5 Management acknowledges the audit observation on all aspects of IT administration

and management. However, management would not carry out such capital intensive venture in the absence of Nation Government budgetary support.

1.3.7.6 Management is also anticipating venturing into an agreement with a renounced partner

that could handle the Ministry’s IT infrastructure. It is expected that all the audit’s observations and recommendations on IT will be settled.

Auditor General’s Position

1.3.7.7 We acknowledge Management’s acceptance of our recommendation. We will validate Management’s acceptance during subsequent audit.

1.3.8 Antivirus

Observation 1.3.8.1 DS5.9 Malicious Software Prevention, Detection and Correction Put preventive,

detective and corrective measures in place (especially up-to-date security patches and virus control) across the organization to protect information systems and technology from malware (e.g., viruses, worms, spyware, spam).

1.3.8.2 It was observed during the conduct of the audit that there is no evidence of the

installation of antivirus on all of the computers used within the Ministry for the processing of the vehicle registration system (VRS).

Risk

1.3.8.3 The absence of antivirus on computers used to process transactions on VRS could lead to the corruption of IT services and data.

Recommendation

1.3.8.4 The Management should install antivirus on all computers processing transaction on VRS.

Management’s Response

1.3.8.5 Management acknowledges the audit observation on all aspects of IT administration and management. However, management would not carry out such capital intensive venture in the absence of Nation Government budgetary support.

1.3.8.6 Management is also anticipating venturing into an agreement with a renounced partner

that could handle the Ministry’s IT infrastructure. It is expected that all the audit’s observations and recommendations on IT will be settled. Auditor General’s Response

1.3.8.7 We acknowledge Management’s acceptance of our recommendation. We will validate Management’s acceptance during subsequent audit.

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1.3.9 IT Business Continuity plan/disaster Recovery plan Observation

1.3.9.1 DS4.2 of CoBit 4.1: “Develop IT continuity plans based on the framework and designed to reduce the impact of a major disruption on key business functions and processes. The plans should be based on risk understanding of potential business impacts and address requirements for resilience, alternative processing and recovery capability of all critical IT services. They should also cover usage guidelines, roles and responsibilities, procedures, communication processes, and the testing approach.”

1.3.9.2 DS4.8 of CoBit 4.1: “IT Services Recovery and Resumption Plan the actions to be taken

for the period when IT is recovering and resuming services. This may include activation of backup sites, initiation of alternative processing, customer and stakeholder communication, and resumption procedures. Ensure that the business understands IT recovery times and the necessary technology investments to support business recovery and resumption needs.”

1.3.9.3 It was observed during the conduct of the audit that there was no evidence that the Ministry developed a documented IT business continuity plan that will enable business to continue offering critical services in the events of disruptions. Risk

1.3.9.4 The absence of an adequate up-to-date tested business continuity plan could lead to failure and breakdown of the IT system.

1.3.9.5 The potential impact of not planning adequately for disaster recovery could also lead to

loss of service to users, loss of credibility, incomplete and inaccurate records.

Recommendation 1.3.9.6 The Management should prepare a business continuity plan. The plan should be tested

periodically and implemented to ensure that it continues to meet business needs.

Management’s Response 1.3.9.7 Management acknowledges the audit observation on all aspects of IT administration

and management. However, management would not carry out such capital intensive venture in the absence of Nation Government budgetary support.

1.3.9.8 Management is also anticipating venturing into an agreement with a renounced partner

that could handle the Ministry’s IT infrastructure. It is expected that all the audit’s observations and recommendations on IT will be settled.

Auditor General’s Position

1.3.9.9 We acknowledge Management’s acceptance of our recommendation. We will validate Management’s acceptance during subsequent audit.

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1.3.10 IT Environmental Control

Observation 1.3.10.1 DS12.4 of CoBit 4.1 states that “Protection against Environmental Factors Design and

implement measures for protection against environmental factors. Install specialized equipment and devices to monitor and control the environment.”

1.3.10.2 DS12.5 of CoBit 4.1 states that “Physical Facilities, Management should manage

facilities, including power and communications equipment, in line with laws and regulations, technical and business requirements, vendor specifications, and health and safety guidelines.

1.3.10.3 It was observed during the conduct of the audit that there was no evidence that

Ministry establish an appropriate control to monitor, regulate and minimize disaster. The IT environment lacks the following:

• Fire alarm, • Fire suppression systems

Risk

1.3.10.4 The absence of approved laws and regulations to maintained environmental control could result in damage to hardware and theft of IT equipment.

1.3.10.5 Failure to install or maintain fire precaution measures and practices fire drills regularly

could expose equipment and personnel to disaster in case fire.

Recommendation 1.3.10.6 The Management should install and maintain fire precaution such as: fire alarm and fire

suppression systems to help safeguard IT equipment. 1.3.10.7 The Management should prepare approved laws and regulations to protect the IT

environment from disaster.

Management’s Response 1.3.10.8 Management acknowledges the audit observation on all aspects of IT administration

and management. However, management would not carry out such capital intensive venture in the absence of Nation Government budgetary support.

1.3.10.9 Management is also anticipating venturing into an agreement with a renounced partner

that could handle the Ministry’s IT infrastructure. It is expected that all the audit’s observations and recommendations on IT will be settled.

Auditor General’s Response

1.3.10.10 We acknowledge Management’s acceptance of our recommendation. We will validate Management’s acceptance during subsequent audit.

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2 ACKNOWLEDGEMENT

2.1 We acknowledge the cooperation and assistance provided to the GAC Audit Team by the staff of the Ministry of Transport (MOT) and other individuals as well as institutions who contributed to the success of this audit. The efforts and commitment of GAC staff in conducting this audit are also gratefully acknowledged.

Monrovia, Liberia February, 2018

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Annexure

Annexure I: Vehicle Registration Payment date Receipt number Plate number Owner Amt US$ Amt L$ 01-Mar-16 827016 3 8270163 C20046 GOOD LUCK HARDWARE ENTERPRISE 200.00 09-Jun-16 810563 7 8105637 H10568 BRIDGEWAY CORPORATION 530.00 01-Feb-16 809701 1 8097011 4229 TX VICENT T. BNAGBE 170.00 10-May-16 827609 9 8276099 A65705 RAMSES BRIGHT 200.00 20-Jul-15 808593 5 8085935 B1450 T. WILLIAM SAYDEE JARBA 200.00 08-Jan-16 827006 9 8270069 A62112 ATLANTIC RESOURCES LIMITED 200.00 19-Mar-16 827471 8 8274718 A30564 NANCY Y. KPADEH 125.00 05-Mar-16 810462 810462 A68908* DENISE FINDLEY 200.00 09-May-16 810310 1 8103101 A50833 BEEVER COMMUNICATIONS INC 150.00 18-May-16 827488 5 8274885 H12476 CHINA CHONG QING INTERNATIONAL CONSTRUCTION CORPORATION(CICO)LI 510.00 11-Mar-16 827143 1 8271431 DHL-10 DHL INTERNATIONAL LIBERIA LIMITED 250.00 12-Jun-16 810579 9 8105799 KD-786 LION STATIONERY STORE 32,200.00 24-May-16 827483 7 8274837 H12484 CICO LIBERIA INCORPORATED 510.00 17-May-16 810362 0 8103620 A61325 JANNAVE C. MASSAQUOI 200.00 12-Jan-16 765573 0 7655730 A40041 JOSEPH NDEBEH MORLU 140.00 03-May-16 827421 9 8274219 A56497 AARON G. MARSHALL 150.00 03-Mar-16 827221 5 8272215 A62598 H.J. BUSINESS CENTER 200.00 10-May-16 810556 8 8105568 A61348 MANO MANUFACTURING COMPANY 200.00 24-May-16 827750 827750 A25279 BERRIAN ALEXANDER 100.00 04-Mar-16 809787 9 8097879 2754 TX YASSAH JOHNSON 190.00 05-Feb-16 808910 4 8089104 A27014 ARTHUR B. ABDULLAI 100.00 11-Mar-16 827144 6 8271446 A60066 GOLDEN GATE LIBERIA INCORPORATED 200.00 04-Mar-16 827057 7 8270577 GIZ-111 GIZ LIBERIA 380.00 04-Feb-16 827106 9 8271069 EPO-016 EQUATORIAL PALM OIL INCORPORATED 330.00 30-Jun-16 827876 9 8278769 A62038 RAJIA INTERNATIONAL TRADING COMPANY 190.00 20-May-16 810302 5 8103025 H10598 CSE LIBERIA 540.00

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Payment date Receipt number Plate number Owner Amt US$ Amt L$ 18-May-16 827675 7 8276757 A63185 THE CARTER CENTER INCORPORATED 200.00 19-Jan-16 131082 1 1310821 5249 TX J. KOLLIE KORVAH 190.00 23-Jun-16 827878 6 8278786 A21776 HENRY D. COOPER 100.00 23-May-16 810398 4 8103984 H10592 FARAFINA ENTERPRISE 520.00 21-May-16 827883 7 8278837 B1743 MAMBA POINT HOTEL 200.00 28-May-16 827709 5 8277095 A20089 REJOLAR BUSINESS CENTER 100.00 21-Jun-16 827794 5 8277945 A10008 AFRICA INSURANCE CORPORATED OF LIBERIA 65.00 12-May-16 810341 6 8103416 A64896 RAW TRADING INCORPORATED 200.00 19-May-16 827726 9 8277269 MGF 1 MOSES G. FORKPAH 320.00 17-Jun-16 810473 7 8104737 A20126 MOHAMMED A. SOW 90.00 09-May-16 810271 2 8102712 A10081 SETHI BROTHERS INCORPORATED 75.00 26-Feb-16 827010 0 8270100 A50153 ANTIONE TRADING 150.00 16-Jul-15 808668 808668 C30190 UNIION CARGO HANDING & TRANSPORT 300.00 05-Jan-16 809982 1 8099821 A25754 J. OTHELLO NOWON, SR. 100.00 13-May-16 827543 2 8275432 A60383 JUSMART ENGINEERS [LIB] LILMITED 200.00 10-Mar-16 827124 8 8271248 CAT 17 LIBERIA EQUIPMENT LIMITED 300.00 29-Jun-16 810644 810644 A52031 MAYBAH BAYOUR 150.00 22-Jun-16 827783 3 8277833 A51720 HYUNGSUB CHO 150.00 16-May-16 810354 5 8103545 A51593 HAWA BYRD 150.00 09-Jun-16 827669 3 8276693 A31479 EMMANUEL S. TARPEH 125.00 23-Jun-16 827791 2 8277912 A62107 CHINA CHONG QING INT'L CONSTRUCTION CORPORATION {LIBERIA] 190.00 06-Aug-15 810385 6 8103856 A60810 SETHI BROTHERS INC. 200.00 31-May-16 810404 6 8104046 A62198 FIRESTONE LIBERIA INCORPORATED 200.00 25-May-16 810451 810451 A10360 ANTOINETTE NIMELY 75.00 11-Mar-16 827134 5 8271345 A21253 MOHAMMED ALI DIALLO 100.00 03-Sep-15 590506 8 5905068 A68194 SIGMA GROUP INCORPORATED 230.00 10-Jun-16 810646 5 8106465 A50419 EDGAR S. SYNDNEY 150.00 24-May-16 827602 2 8276022 A64388 WELTHUNGERHILFE 200.00

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Payment date Receipt number Plate number Owner Amt US$ Amt L$ 30-Mar-16 810304 7 8103047 A64006 OXFAM GB 200.00 12-May-16 810407 4 8104074 A60532 CYRIL JONES 200.00 06-May-16 810570 3 8105703 A21019 MAI DUDLEY 100.00 27-Jun-16 810584 4 8105844 SLBC-1 JOHN FESTUS BUNDOR, SR 300.00 20-Jun-16 827763 3 8277633 A20871 VARNEY G. SHERMAN 100.00 04-May-16 810276 7 8102767 H10421 FOUANI BROTHERS CORPORATION 45,000.00 25-Feb-16 827005 0 8270050 A61915 CLETUS SEGBE WOTORSON 200.00 16-Oct-15 589951 4 5899514 A35589 PATIENCE S. MORRIS KANTIE 125.00 10-Feb-16 827466 2 8274662 A52540 UNIQUE BUSINESS CORORATION 150.00 06-Jun-16 827866 4 8278664 A21693 FIRESTONE LIBERIA INCORPORATED 100.00 27-Jan-16 909985 8 9099858 A65422 TECHSULT LIBERIA INCORPORATED 200.00 15-Jun-16 810543 6 8105436 H10755 FIRESTONE LIBERIA INCORPORATED 580.00 04-May-16 810276 6 8102766 C50117 FOUANI BROTHERS CORPORATION 45,000.00 28-Mar-16 827235 0 8272350 A60134* LIBERIA ELECTRICITY CORPORATION (LEC) 200.00 03-Mar-16 827057 1 8270571 A20896 DAOUDA M. SESAY 100.00 29-Feb-16 807258 7 8072587 1254 TX SAMUEL TETROIEN NIMELEY 170.00 06-Jan-16 810326 0 8103260 H10349 LIBERIA CEMENT CORPORATION (CEMENCO) 620.00 13-Apr-16 810346 6 8103466 A20987 ERIC P. MUNZ 100.00 07-Jun-16 810502 0 8105020 A51020 STEPHEN GARFIELD TREXLER 150.00 21-Jun-16 827994 1 8279941 A33996 ZAYZAY G. MULBAH 125.00 23-Mar-16 827026 7 8270267 C50046 ABDU KENNEH 500.00 21-Mar-16 810379 810379 A24630 YOME W.TITUS 100.00 27-May-16 827633 9 8276339 A21067 GAROU I. SHERIFF 100.00 10-Feb-16 827548 7 8275487 A20137 IBRAHIM BARRIE FOREX BUREAU INCORPORATED 100.00 09-Jun-16 810562 4 8105624 A34844 BRIDGEWAY CORPORATION 125.00 09-Jun-16 810634 0 8106340 H12076 A.M. JALLAH CAR RENTAL SERVICES 540.00 22-May-16 810578 3 8105783 A21955 JENNIAVE J. BROWNE 100.00 07-Jan-16 909542 2 9095422 A33294 CHADI SEKLAOUI 125.00

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Payment date Receipt number Plate number Owner Amt US$ Amt L$ 25-May-16 827604 4 8276044 A20138 JAMES T. KOLLIE 100.00 18-May-16 827482 5 8274825 H12466 CICO LIBERIA INCORPORATED 510.00 09-Jan-16 808086 4 8080864 A52918 DUASON V. KAMARA 150.00 19-May-16 827657 7 8276577 A26449 THERESA GONO 100.00 15-Mar-16 827205 1 8272051 JSI-5 JOHN SNOW, INCORPORATED 320.00 27-Feb-16 827165 9 8271659 A61167 KUKU YOUNGER DORBOR 200.00 08-Mar-16 827106 3 8271063 NSTAR-25 NORTH STAR ENTERPRISE 360.00 05-May-16 847017 3 8470173 A60289 B. FRANCICAN SIS. & SIS. M.L. BROWN 190.00 09-Mar-16 810077 0 8100770 A60950 EMMANUEL KUMAH 17,800.00 05-Feb-16 827020 1 8270201 A40824 THOMAS SAYSAY 140.00 04-Mar-16 827069 5 8270695 A60786* CELLCOM TELECOMMUNICATION INCORPORATED 200.00 03-Mar-16 809917 809917 A30577 AFRICA # ONE ENTERPRISE INCORPORATED 300.00 05-May-16 827442 9 8274429 A60288 ABEL MASSALEE 200.00 04-Feb-16 827015 7 8270157 A20236 MUSA S. SIDIBEY 100.00 10-May-16 827476 0 8274760 A23197 ANTHONY N. DAVIS 100.00 06-Jun-16 810487 0 8104870 A61140 M. LEELA KPUKUYOU 200.00 23-Apr-16 827342 2 8273422 SMT-3 SWEDISH MACHINERY & TRUCKS LIBERIA INCORPORATED 320.00 02-Jun-16 827732 5 8277325 A65271 UNITED GROUP SUPPLYINC. 200.00 25-Jan-16 131007 8 1310078 B1600 VARLEE BAYOR 200.00 03-Mar-16 827066 2 8270662 C30063 HARBEL SUPERMARKET CORP 300.00 07-Sep-15 589947 4 5899474 4086 TX VARMUYAN DOLLEY 190.00 23-Mar-16 827232 5 8272325 A20030 G.K. BUSINESS CENTER 100.00 28-Mar-16 827232 1 8272321 A62561 RAJKUMAR KRIUSHNASAMY 200.00 24-Feb-16 827006 7 8270067 A60013 ALPHA LOGGING & WOOD PROCESSING INCORPORATED 200.00 9/7/2015 589947 4 5899474 4086 TX VARMUYAN DOLLEY 190.00 05-Apr-16 827263 4 8272634 A21972 GOODWILL BUSINESS CENTER 100.00 Total 21,775.00 140,000.00

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Annexure II: Eligibility Certificates Date Of

Payment Names Of Entity Addressed/Location Nature Of Business Revenue Receipt # Amount Paid US$ Amount Paid L$

1/15/2016 THUNDERBIRD CORPORATION VAI TOWN AUTO PARTS DEALERSHIP 1305381 200.00 0 1/15/2016 CACTUS ENTERPRISE RANDALL AUTO PARTS DEALERSHIP 1302504 200.00 0 12/17/2015 E.E.E AUTO SPARE PARTS CLARA TOWN AUTO PARTS 1311200 100.00 0 6/28/2016 SIDIKE SWARY AUTOPARTS CLARA TOWN AUTO PARTS 1324625 100.00 -0- 6/6/2016 AUTO ELEGANCE CAREY STREET AUTO PARTS 1286263 150.00 -0- 6/6/2016 DAVIS AUTO PARTS G.S.A ROAD AUTO PARTS 1314660 100.00 -0- 6/6/2016 MARGA AUTO PARTS SHOP REDLIGHT AUTO PARTS 8097265 100.00 -0- 6/7/2016 ELVES TRANSPORT THINKER VILLAGE TRANSPORT COMPANY 1308872 200.00 -0- 6/7/2016 MUM MEH GARAGE CONGO TOWN SERVICE GARAGE 131053 100.00 -0- 6/30/2015 BLESSED M.M AUTO SERVICES MECHLIN STREET AUTO SPARTS PARTS 1280040 100.00 -0- 6/8/2015 AUTO ELEGANCE CAREY STREET SERVICE GARAGE OPERATION 1286263 150.00 -0-

7/26/2015 A.B.K TRANSPORT AND LOGISTICS JACOB TOWN, PAYNESVILLE TRANSPORT COMPANY 1287589 200.00 -0-

8/10/2015 OZ. TRADING CENTER FREEPORT AUTO PARTS 129556 -0- 8,500.00

8/27/2015 MARSK TRANSPORT SERVICE INC. NEW GEORGIA TRANSPORT SERVICE 1296700 200.00 -0-

9/3/2015 DIVINE WPRK OF GOD REDLIGHT AUTO PARTS 1297242 100.00 10/15/2015 LIBERIA TYRE CENTER JOHNSON STREET TYRE DEALERSHIP 1301551 200.00 -0-

10/22/2015 ABRAHAM SPARE PARTS CENTER RANDALL STREET MOTORBIKE DEALERSHIP 1302381 500.00 -0-

12/1/2015 ADVANTURE ENTERPRISE MOTORBIKE 1306138 500.00 10/15/2015 KALAYAMADI ENTERPRISE GARDNERVILLE CAR RENTAL 1302500 200.00 12/5/2015 FARO AUTO PARTS SHOP GRAND GEDEH COUNTY AUTO PARTS 130342 100.00 12/1/2015 DIVINE FAVOR AUTO PARTS GRAND GEDEH COUNTY AUTO PARTS 130220 100.00 7/4/2015 HIS GRACE AUTO PARTS GRAND GEDEH COUNTY AUTO PARTS 130271 100.00 12/16/2015 DIVINE GRACE AUTO PARTS GRAND GEDEH COUNTY AUTO PARTS 130202 124.00 8/13/2015 MOHAMMED S. DIALLO 4 GRAND GEDEH COUNTY AUTO PARTS 171578 8,500.00 8/13/2015 MUSA ZAZA GRAND GEDEH COUNTY AUTO PARTS 171553 9,640.00 8/13/2015 MY STORE GRAND GEDEH COUNTY AUTO PARTS 171552 21,500.00 8/15/2015 ABRAHAM S. BARRY GRAND GEDEH COUNTY AUTO PARTS 171551 21,500.00 10/20/2015 MOHAMMED S. KEITA GRAND GEDEH COUNTY AUTO PARTS 170489 8,500.00 Total 4,424.00 78,140.00

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