Running 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.
Scope and Methodology: The performance audit was done in harmony with the generally acknowledged government auditing standards. The standards requires a good plan and carry out the audit to obtain satisfactory and appropriate evidence that avails reasonable foundation for the findings. The realize the objective if the audit, focus was given to DEA confidential sources who were always active in any of the D ...
Running head AUDIT ACTION PLAN 1AUDIT ACTION PLAN 4.docx
1. Running head: AUDIT ACTION PLAN 1
AUDIT ACTION PLAN 4
Federal Financial Management
Audit Action Plan
Prepare by
Edwige Kouassi
To
Prof: Elizabeth Scheffler
2. 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
3. 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.
Scope and Methodology: The performance audit was done in
harmony with the generally acknowledged government auditing
standards. The standards requires a good plan and carry out the
audit to obtain satisfactory and appropriate evidence that avails
reasonable foundation for the findings. The realize the objective
if the audit, focus was given to DEA confidential sources who
were always active in any of the DEA’s local offices from FY
2011 to FY 2015. The DEA confidential source data was
scrutinized at several locations. Several officials from the DoJ
were interviewed.
4. 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
5. 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
6. 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
7. 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
Paper 4
Based on our readings in this last unit (essays by Sachs,
8. Battistoni, Arnold, Mantsio, and Parker), formulate an argument
about poverty, primarily how to solve it as a problem. Be sure
to describe why your proposed solution is the best one. Your
thesis should clearly but briefly convey this information.
In formulating your position, consider the essays we have read
for class: which points do you agree with and which ones do
you disagree with? Be sure you are able to explain why you
agree or disagree with other authors as you must acknowledge
and refute opposition to your argument. (Hint: when you are
critiquing authors, keep in mind the fallacies and the
requirements for essays we discussed in class, and remember
that acknowledging opposition to your argument only makes
your point stronger.)
Your paper should include a title, introduction, several body
paragraphs, conclusion, and Works Cited page. Your
introduction should include a thesis. Your thesis should briefly
respond to the prompts in paragraph one.
Each body paragraph should begin with a topic sentence that
conveys one of your subpoints. Each subpoint should then be
supported with examples and illustrations from the essays we
have read for class. Be sure that you thoroughly comment on
each example and on how each subpoint (or paragraph) relates
to your overall argument. (Hint: one example of how to
organize your body is to cluster your paragraphs around
different solutions to the problem of poverty, ending with what
you deem the best one. Another approach might be to identify
topics that more than one of the essays discusses and use those
topics for body paragraphs.)
You should organize your body paragraphs in a logical manner,
transitioning smoothly from one to the next. Your paragraphs
need to utilize more than one source; in other words, do NOT
organize your paragraphs according to your sources, devoting a
9. paragraph to each source. Instead, organize your paragraphs
according to YOUR argument and bring in sources to support
your argument as needed. Doing so, each body paragraph will
likely draw on more than one source for support (though if one
of your body paragraphs utilizes only one source, that is okay,
as long as it is only the one paragraph). Remember to make your
transitions from example to example smooth, and from source to
source, smooth.
In your conclusion, discuss why this issue is important,
particularly outside of the classroom: what is at stake?
Remember that most examples from sources should be
paraphrased, that direct quotes, when used, should be brief, and
that all paraphrases and quotes are cited correctly, both
parenthetically (in-text) and on your Works Cited page.
This paper must utilize at least 3 sources. You may use essays
we read earlier in the semester in addition to or instead of our
last five readings. You may also incorporate outside sources but
are not required to do so. Keep in mind that researching outside
sources is often time-consuming—in other words, I do not
recommend it. If you choose to do outside research, keep in
mind that incorporating more than 5 sources is not appropriate
for a paper this short.
Do not summarize your sources; this paper is about what YOU
think rather than what others argue about the topic. Assume
your reader is familiar with your sources and with the debates
surrounding the issue.
Consult your Writing Today for guidelines on style and
grammar; remember that you are responsible for all of the errors
we have discussed in class and that mistakes will affect your
grade. Avoid personal pronouns and follow the formatting
guidelines in your syllabus. Remember that points will be
10. deducted from late papers.
You should plan on revising your paper several times. You will
have an opportunity for feedback during our workshop, and you
may also ask for my suggestions.