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    September 30, 2014

    Included herein is the District of Columbia Auditors report entitled ANC 8B Operations Were NotFully Compliant with the Law. This audit was conducted as required by the Advisory NeighborhoodCommissions Act (the Act). The objectives of this audit were to determine whether ANC 8B was incompliance with the requirements of the Act and whether they had established adequate internalcontrols to ensure proper stewardship of the public funds allocated to them.

    We would like to thank ANC 8Bs commissioners for their assistance and cooperation during thisaudit. We look forward to working with ANC 8B in the future.

    Sincerely,

    Lawrence PerryActing District of Columbia Auditor

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    ANC 8B Financial OperationsWere Not Fully Compliant withLaw

    What ODCA Found

    ANC 8B is one of 40 Advisory Neighborhood Commissions(ANCs) in the District of Columbia. The ANCs were created

    by the Advisory Neighborhood Commissions Act of 1975(the Act). The Act empowers the ANCs to advise the Councilof the District of Columbia, the Mayor, and the agencies ofthe government of the District of Columbia on matters ofgovernment policy or action that affect that Commissionarea. In addition, the Act authorizes an annual allocation offunds to each ANC, to be distributed quarterly. These fundsare to be used for public purposes within the Commission

    area.

    Overall, we found that ANC 8B complied generally with therequirements of the law; however, compliance can bestrengthened. Specifically, we found that some expenditures

    were not properly documented or justified and that severalwere for purposes not authorized by law.

    We further found that ANC 8B did not consistently file therequired quarterly reports with the Office of the District ofColumbia Auditor in a timely manner. Failure to file thesereports on time led to delays in receiving their quarterlyallotments.

    September 30, 2014

    Why ODCA Did This Audit

    The audit was conducted per the AdvisoryNeighborhood Commissions Act of 1975, whichrequires the District Auditor to audit the financialaccounts of selected ANCs each year.

    What ODCA Recommends

    1. We recommend that ANC 8Bs Commissioners,at their first meeting of each calendar year,should adopt and publish a schedule of regularcommission meetings for the remainder of thecalendar year.

    2. We recommend that ANC 8Bs Commissionersshould maintain an approved written record ofeach public meeting in a secure location.

    3.

    We recommend that ANC 8Bs Treasurershould ensure that ANC 8Bs quarterlyfinancial reports are complete, accurate andfiled with the Auditor by required due dates.

    4. We recommend that the ANC 8B Treasurershould reconcile bank statements to thecheckbook within 15 days of the receipt of the

    bank statement and that the bank statement

    and the reconciliation should be reviewed andapproved by the Chairperson or ViceChairperson.

    5. We recommend that ANC 8B should establishwritten policies and procedures detailing therequirements for hiring and approvingexpenditures for consultants providingpersonal services and incorporate theseprocedures into their by-laws.

    6. We recommend that ANC 8B should review thecurrent grant policy, improve its internalcontrols for their grant program and comply

    with the D.C. Code and the Auditors

    Guidelines.7. ANC 8B should establish a written records

    transition policy for Commissioners that arenot re-elected or whom are no longer serving asofficers.

    For more information regarding this report,please contact Anovia Daniels, Communications

    Analyst/ANC Outreach, [email protected] 202-727-3600.

    mailto:[email protected]:[email protected]:[email protected]:[email protected]
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    Table of Contents

    Background ................................................................................................................. 2

    Objectives, Scope and Methodology ............................................................................. 6

    Audit Results ............................................................................................................... 8

    1. ANC 8B did not document that the required number of public meetings were held during theaudit period ................................................................................................................................ 8

    2.

    ANC 8B failed to file quarterly reports by the due dates ......................................................... 10

    3.

    ANC 8B did not properly manage the ANCs bank account and checkbook.............................11

    4.

    ANC 8B did not effectively and transparently manage personal services and/or contracted

    expenditures ............................................................................................................................. 135. ANC 8B failed to properly award grants .................................................................................. 16

    6. ANC 8B did not have a transition plan in place to ensure the safe and secure transfer offinancial records and administrative documents ..................................................................... 18

    Audit Results Summary .............................................................................................. 19

    Conclusion ................................................................................................................ 20

    Agency Comments ...................................................................................................... 21

    Appendix I .................................................................................................................... i

    Appendix II ................................................................................................................ iv

    Appendix III ............................................................................................................... ix

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    ANC 8B Financial Operations Were Not Fully Compliant with LawOffice of the District of Columbia AuditorSeptember 30, 2014 Page 3

    ANC 8B Boundaries

    Figures 2-5 present the ANC 8B Commissioners and Officers for fiscalyears (FY) 2009 through 1st Quarter 2013 (October 1, 2008 throughDecember 31, 2012).

    ANC 8B Commissioners and Officers for FY 2009

    SMD Title First Name Last Name

    8B01 Commissioner Mary Buckley

    8B02 Chairperson David Brewer

    8B03 Secretary Darrel Gaston

    8B04 Treasurer J.B. Shoatz

    8B05 Commissioner Tijwanna Phillips

    8B06 Vice Chair Mitchell Hawkins, III

    8B07 Commissioner Von Pariss

    ANC 8B Commissioners and Officers for FY 2010

    SMD Title First Name Last Name

    8B01 Commissioner Mary Buckley

    8B02 Chairperson David Brewer

    8B03 Secretary Darrel Gaston

    8B04 Treasurer J.B. Shoatz

    8B05 Commissioner Tijwanna Phillips

    8B06 Vice Chair Mitchell Hawkins, III

    8B07 Commissioner Von Pariss

    Figure 2

    Figure 3

    Figure 1

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    ANC 8B Financial Operations Were Not Fully Compliant with LawOffice of the District of Columbia AuditorSeptember 30, 2014 Page 4

    ANC 8B Commissioners and Officers for FY 2011

    SMD Title First Name Last Name

    8B01 Commissioner Khadijah Watson

    8B02 Commissioner David Brewer

    8B03 Chairperson Darrel Gaston

    8B04 Treasurer J.B. Shoatz

    8B05 Commissioner Tijwanna Phillips

    8B06 Commissioner Mitchell Hawkins, III

    8B07 Commissioner Louise Thorne

    ANC 8B Commissioners and Officers for FYs 2012 and 1stQuarter 2013

    SMD Title First Name Last Name

    8B01 Commissioner Khadijah Watson

    8B02 Commissioner Unknown

    8B03 Chairperson Darrel Gaston

    8B04 Treasurer J.B. Shoatz

    8B05 Commissioner Tijwanna Phillips

    8B06 Commissioner Mitchell Hawkins, III

    8B07 Commissioner Louise Thorne

    ANC 8B Annual Appropriations and Disbursements

    ANC 8Bs appropriated funding for FYs 2009, 2010, 2011, 2012 and

    the 1stquarter of 2013 totaled $77,584.72. According to ANC 8Bs

    quarterly reports, they disbursed a total of $101,657.75 between FY

    2009 and 1stquarter FY 2013 1stquarter. 3

    Figure 6 summarizes, by category, ANC 8Bs reported spendingbetween FY 2009 and the first quarter of FY 2013. Note that theseamounts were reported by ANC 8B on their required quarterlyreports.

    3ANC 8B had a beginning balance of $49,872.54 (as of October 1, 2008) plus theallotments of $77,584.72 for a total of $127,457.26 which was available fordisbursements during the audit period.

    Figure 4

    Figure 5

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    ANC 8B Financial Operations Were Not Fully Compliant With the LawOffice of the District of Columbia AuditorSeptember 30, 2014 Page 5

    Disbursements ANC 8B Reported Between FY 2009 and 1stQuarter FY 2013

    Disbursements FY 2009 FY 2010 FY 2011 FY 20121st

    QuarterFY 2013

    GrandTotal

    %

    Net Salaries & Wages $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 0%

    Workers Compensation $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 0%

    Insurance (Total): $0.00 $25.00 $25.00 $0.00 $0.00 $50.00

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    ANC 8B Financial Operations Were Not Fully Compliant With the LawOffice of the District of Columbia AuditorSeptember 30, 2014 Page 6

    Objectives, Scope and Methodology

    Objectives

    Pursuant to District of Columbia Code 1-309.13(d)(2), the District

    of Columbia Auditor (Auditor) conducted a discretionary audit of

    the financial accounts of the Advisory Neighborhood Commission

    (ANC) 8B.4

    The objectives of this audit were to determine whether:

    1. ANC 8Bs financial activities complied with applicable laws

    and regulations; and

    2.

    Internal controls were established to protect the ANCsassets from fraud, waste and abuse.

    Scope

    The audit period covered fiscal years (FY) 2009 through 1 stQuarter

    2013 (October 1, 2008 through December 31, 2012) and included a

    review of ANC 8B financial records, quarterly financial reports,

    grant agreements, and other relevant documents.

    Methodology

    To evaluate compliance with applicable laws and regulations wereviewed the Advisory Neighborhood Commissions Act of 1975, asamended (the Act), Suggested Financial Management Guidelinesestablished by the District of Columbia Auditor, written opinionsissued by the Districts Office of Attorney General (OAG), as well as,financial records and documents maintained by ANC 8B.

    To determine whether internal controls were established to protectANC 8B assets we examined canceled checks, bank statements,quarterly financial reports, meeting minutes, receipts and invoices,

    grant applications, contracts and interviewed applicable ANCOfficers.

    We conducted this performance audit in accordance with generallyaccepted government auditing standards. Those standards requirethat we plan and perform the audit to obtain sufficient, appropriate

    4District of Columbia Code 1-309.13(d)(2), provides that [t]he Auditor may auditthe financial accounts of a Commission, at the discretion of the Auditor....

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    ANC 8B Financial Operations Were Not Fully Compliant With the LawOffice of the District of Columbia AuditorSeptember 30, 2014 Page 7

    evidence to provide a reasonable basis for our findings andconclusions based on our audit objectives. We believe that theevidence obtained provides a reasonable basis for our findings andconclusions based on our audit objectives.

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    ANC 8B Financial Operations Were Not Fully Compliant With the LawOffice of the District of Columbia AuditorSeptember 30, 2014 Page 8

    Audit Results

    Overall, we found that Advisory Neighborhood Commission (ANC)8B failed to comply with several key requirements of the AdvisoryNeighborhood Commission Act of 1975, as amended (the Act). Thisfailure to comply with the law resulted in the disallowance of$13,293.91 of non-supported or non-allowable disbursements duringour audit period. Further, we found that ANC 8B did not establishand implement sufficient internal controls to protect District fundsfrom fraud, waste, or abuse.

    ANC 8B did not document that the required numberof public meetings were held during the audit period

    The Act provides that [e]ach Commission shall meet in publicsession at regular intervals at least 9 times per year.. . 5and furtherprovides that one purpose of the Commission meetings is ... to hearthe views of residents within the Commission area and other affectedpersons on problems or issues of concern within the Commissionarea and on proposed District government actions that affect theCommission area.6

    We could not verify that ANC 8B held the required public meetings infiscal years (FY) 2009, 2010, 2011, and 2012. In order to determinethe number of public meetings held, we reviewed the meeting

    minutes submitted to the Auditor by ANC 8B or that we found ontheir website for FYs 2009, 2010, 2011, and 2012 and the first quarterof FY 13. We found evidence that ANC 8B held five meetings in FY2009, eight in FY 2010, five in FY 2011, nine in FY 2012, and two inthe first quarter of FY 13.

    In the absence of public meetings, the residents of ANC 8B and otherstakeholders may not have had an opportunity to express their viewson problems or issues that occurred in FYs 2009, 2010, 2011, and2012 if public meetings were not held.

    Recommendations:

    1. ANC 8Bs Commissioners, at their first meeting of eachcalendar year, should adopt and publish a schedule ofregular commission meetings for the remainder of thecalendar year.

    5D.C. Code 1-309.11 (b) (1)6D.C. Code 1-309.11 (b) (3)

    Auditor could notverify that ANC 8Bheld the required

    public meetings inFYs 2009, 2010,2011, and 2012

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    ANC 8B Financial Operations Were Not Fully Compliant With the LawOffice of the District of Columbia AuditorSeptember 30, 2014 Page 11

    ANC 8B did not properly manage the ANCs bankaccount and checkbook

    The Act provides, among other things, that any expenditure of fundsby a Commission shall be recorded by the Treasurer in theCommission's books of accounts and no expenditure of any amount

    shall be made without the specific authorization of the Commission.9Further, the Act requires that expenditures, made by check, shall besigned by at least two officers of the Commission, one of whom shall

    be the Treasurer or Chairperson, be pre-numbered, be issued inconsecutive order, and bear the name of the Commission andDistrict of Columbia Government on its face. The Auditors

    Suggested ANC Financial Management Guidelinesfurther suggeststhat the Treasurer should reconcile the bank statement to thecheckbook within 15 days of receipt of the bank statement.

    Additionally, the guidelines provide that the bank statement and thereconciliation should be reviewed by the Chairperson or otherofficer of the ANC who should indicate their review by initialing the

    bank reconciliation and bank statement.

    We found the following irregularities upon our review of ANC 8Bsfinancial documentation.

    Two checks contained the signing ANC officers name on theback of the check, where an endorsement signature wouldnormally be found. The payees name was also on the back ofthe check, making it difficult to determine exactly whathappened in these situations. Further, ANC 8B did notprovide adequate supporting documentation for theseexpenditures. (See Figure 7.)

    There was no indication that bank statements werereconciled or that the bank statements were reviewed by anofficer other than the Treasurer.

    Two checks, totaling $2,875.00, were only signed by oneofficer. (See Figure 8.)

    In writing checks, ANC 8B frequently wrote checks out ofsequence and voided large blocks of checks.

    9D.C. Code 1-309.13 (f)(1) through f(2)(A)(i)

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    ANC 8B Financial Operations Were Not Fully Compliant With the LawOffice of the District of Columbia AuditorSeptember 30, 2014 Page 12

    ANC 8B Questionable Check Endorsements 10

    CheckNumber

    Date Amount Payee/Purpose Endorser

    1674 10/12/2012 $350.00Devon Flood/Text marks 411

    Payee andChair

    1702 12/31/2012 $1,800.00Noah HarmonyShoatz/CleaningContract

    Payee andTreasurer

    Total $2,150.00

    Single Signature Checks

    CheckNumber

    Date Amount Payee/Purpose Signer

    1684 11/27/2012 $875.00Document Managers/Newsletter Treasurer

    1685 11/29/2012 $2,000.00Woodland Tigers/CommunityContribution

    Treasurer

    Total $2,875.00

    ANC 8Bs failure to adhere to the financial requirements of the ANC

    Act and financial management guidelines issued by the District of

    Columbia Auditor raised the risk of improper or illegal expenditures.

    It should be noted that the amounts listed in Figures 7, 8, and 9

    were withheld from subsequent allotments. In addition, thereputation of ANC 8B and its Commissioners was also placed at risk

    by this mismanagement.

    Recommendations:

    4.

    The ANC 8B Treasurer should reconcile bank statements tothe checkbook within 15 days of the receipt of the bankstatement and that the bank statement and thereconciliation should be reviewed and approved by theChairperson or Vice Chairperson.

    10Please see Appendix One for images of these checks.

    Figure 7

    Figure 8

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    ANC 8B Financial Operations Were Not Fully Compliant With the LawOffice of the District of Columbia AuditorSeptember 30, 2014 Page 13

    ANC 8B did not effectively and transparently managepersonal services and/or contracted expenditures

    The Act states in part that Disbursements of Commission fundsexceeding $50 for personal service expenditures shall be specificallyapproved by the Commission at a public meeting prior to thedisbursement.11 Additionally, ANC 8Bs Bylaws state thatCommissioners can only make purchase for less than $25.00

    without prior approval.

    During FYs 2009, 2010 and the 1st quarter of 2013 ANC 8B hiredcontractors and individuals to provide office cleaning, officesupport, computer assistance, and flyer distribution. ANC 8Bobtained these services either through a signed contract and/orinvoice from the company or individual.

    We found however the following irregularities regarding personalservices expenditures:

    Payments to a specified company were approved at a publicmeeting however checks for services were written to anindividual. (See figure 10)

    No approval was found in meeting minutes prior toexpenditures. (See Figure 11)

    A contract was negotiated after payment was made. (seeFigure 11)

    Contracted Expenditures in FYs 2009-201012

    11D.C. Code 1-309.13 (g)12See Appendix Three for a copy of check #1554.

    FYCheck

    NumberDate Amount

    Payee/Purpose

    Irregularities

    Companies

    2009 1554 5/5/2009 $900

    IntisarMunir/CleaningService

    Contract approvedfor Maid to Go;check madepayable toindividual

    2010 1592 1/19/2010 $900

    IntisarMunir/Cleaning

    Service

    Contract approvedfor Maid to Go;check made

    payable toindividual

    Total $1,800

    Figure 9

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    ANC 8B Financial Operations Were Not Fully Compliant With the LawOffice of the District of Columbia AuditorSeptember 30, 2014 Page 14

    Contracted Expenditures in 1stQuarter 2013

    ANC 8Bs failure to adhere to the financial requirements of the ANC

    Act and financial management guidelines issued by the Office

    FYCheck

    NumberDate Amount

    Payee/Purpose

    Irregularities

    Companies

    20131st Qtr

    1673 10/12/2012 $1,134.00SmartSigns/DogSigns

    Properapprovallanguage not inminutes

    20131st Qtr

    1696 12/19/2012 $1,000.00On an OnProduction/

    Website

    Check writtenin one monthand contractnegotiated afterpayment

    20131st Qtr

    1702 12/31/2012 $1,800.00

    NoahHarmonyShoatz/OfficeCleaning 1-yr

    No supportingdocumentation

    Total $3,934.00

    Individuals

    20131st Qtr

    169212/28/201

    2$100.00

    KalvaMace/TVEquipment

    No supportingdocumentation

    20131st Qtr

    1695 12/29/2013 $350.00DevonFlood/ANC411

    No supportingdocumentation

    20131st Qtr

    1697 12/13/2012 $50.31DarrellJeter/Reimbursement

    No supportingdocumentation

    20131st Qtr

    170512/30/201

    2$80.00

    KalvaMace/Office

    Lock

    No supporting

    documentation

    20131st Qtr

    1706 12/31/2013 $75.00

    JamesLitman/NewsletterDistribution

    Properapprovallanguage not inminutes

    20131st Qtr

    1708 12/31/2013 $75.00

    FaheemahShabazz/NewsletterDistribution

    Properapprovallanguage not inminutes

    20131st Qtr

    1709 12/31/2013 $75.00

    KelsoStewart/NewsletterDistribution

    Properapprovallanguage not inminutes

    20131st Qtr

    171012/30/201

    2$75.00

    EmanuelWalker/NewsletterDistribution

    Properapprovallanguage not inminutes

    Total $880.31

    Figure 10

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    ANC 8B Financial Operations Were Not Fully Compliant With the LawOffice of the District of Columbia AuditorSeptember 30, 2014 Page 15

    District of Columbia Auditor raised the risk of improper or illegal

    expenditures. Further, the ANC had funds withheld from allotments

    which resulted in a loss of funds. In addition, the reputation of ANC

    8B and its Commissioners was also placed at risk by this

    mismanagement.

    Recommendation:

    5. ANC 8B should establish written policies and proceduresdetailing the requirements for hiring and approvingexpenditures for consultants providing personal services andincorporate these procedures into their by-laws.

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    ANC 8B Financial Operations Were Not Fully Compliant With the LawOffice of the District of Columbia AuditorSeptember 30, 2014 Page 16

    ANC 8B failed to properly award grants

    The Act provides that A grant may not be awarded unless the grantis awarded pursuant to a vote of the Commission at a public meetingfollowing the public presentation of the grant request. ACommission may approve grants only to organizations that are

    public in nature and benefit persons who reside or work within theCommission area. The services provided by the grantee organizationmust not be duplicative of any that are already performed by theDistrict government.13

    The Act also requires that an applicant for a grant must submit anapplication in writing to the Commission, which includes adescription of the proposed project; a statement of expected public

    benefits; and the total cost of the project.14In addition, [w]ithin 60days following the issuance of a grant, the grant recipient shallforward to the Commission a statement as to the use of the fundsconsistent with the grant application, complete with receipts which

    support the expenditures.15

    The review found that ANC 8B issued five grants totaling $3,590.00but did not correctly follow the grant process. All grants werededucted from ANC 8Bs related allotment.

    Figure 12 presents a list of ANC 8Bs grants awarded in FY 2011,2012 and the 1stquarter of FY 2013 and shows the documentationmissing for each one.

    ANC 8B Grants Awarded in FY 2011, 2012 and 1st QuarterFY 2013

    No.Name ofGrantee

    CheckDate

    GrantAmount

    GrantApplication

    Receipts/Statementon Grant

    UseProvided

    1Congress HeightsC.A.

    5/17/2011 $500 No No/No

    2William LockridgeFoundation

    11/08/11 $280 No No/No

    3 Total Sunshine 11/15/11 $250 No No/No

    4William LockridgeFoundation

    10/16/12 $560 No No/No

    5 Woodland Tigers 11/29/12 $2,000 No No/Yes

    Total $3,590

    Source:ANC 8B Quarterly Reports

    13D.C. Code 1-309.13 (m) (1)14D.C. Code 1-30.13 (m) (2)15D.C. Code 1-30.13 (m) (3)

    Figure 11

    ANC 8B lost$3,590 for grantsthat were notproperly

    administered

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    ANC 8B Financial Operations Were Not Fully Compliant With the LawOffice of the District of Columbia AuditorSeptember 30, 2014 Page 17

    Recommendation:

    6. ANC 8B should review the current grant policy, improve itsinternal controls for their grant program and comply with theD.C. Code and the Auditors Guidelines.

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    ANC 8B Financial Operations Were Not Fully Compliant With the LawOffice of the District of Columbia AuditorSeptember 30, 2014 Page 21

    Agency Comments

    On September 5, 2014, we submitted a draft version of this report toANC 8B and requested written comments by September 19, 2014.

    The Auditor did not receive any written comments by the deadlinegiven.

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    ii

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    iii

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    iv

    Appendix II

    ANC 8B Counter Checks

    Counter checks were obtained and used for the intended purpose of paying an ANC debt. Counterchecks, because they are not sequentially numbered, are not an allowable form of payment.

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    v

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    vii

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    viii

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    ix

    Appendix III

    ANC 8B Checks for Contracts

    ANC 8B contracted for cleaning service with Maids to Go, but checks were written directly to IntisarMunir.

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