fraud reporting & working with usaid oig mar 17.pdf · oig is a valuable resource in combatting...
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Fraud Reporting & Working
With USAID OIG
AIGI Daniel Altman
SAC Jonathan Schofield
SAC Chris Reed
Council of International Development Companies
March 3, 2017
The Inspector General
• Appointed by the President and confirmed by the Senate
• Provides independent oversight through:• Program and financial audits• Investigations
• Reports findings to Agency head, Congress, the President, and the Public
• Full law enforcement authority in the United States
Ann Calvaresi BarrInspector General
OIG Investigations
OIG conducts independent investigations into allegations of fraud, corruption, criminal activity, and misconduct in USAID programs worldwide.
OIG is a valuable resource in combatting
fraud and corruption
Where We Operate
San Salvador
Port Au Prince
Dakar
Pretoria
Cairo
Frankfurt
Manila
Kabul
Islamabad
D.C.Tel Aviv
Kampala
Hub Offices
Major Investigative Areas
• Procurement fraud involving USAID projects
• Bribery and kickbacks• Diversion of commodities
and funds to terrorist groups or sanctioned entities
• Misconduct by USAID personnel
• Conflicts of interest
Where does OIG get allegations?
• Self-disclosures by
implementers
• Hotline calls
• Audits/inspections
• Referrals from other
agencies
• Other investigations
Strategic Priority #1
Prevent, deter, detect, and neutralize organized crime targeting USAID’s supply chain for life saving medications, commodities, and associated programming
Strategic Priority #2
Prevent, deter, detect, and neutralize organized crime targeting USAID-funded humanitarian programs including those supporting USG efforts to defeat ISIS
Strategic Priority #3
Collaborate with USAID and industry to establish a standardized Agency-approved process for handling fraud and corruption complaints referred by OIG
Fraud Reporting Systems
Mandatory Reporting for ContractsFAR 52.203-13
Timely disclosure, in writing, to the agency OIG, with a copy to the Contracting Officer, whenever, in connection with the award, performance, or closeout of any Government contract performed by the Contractor or a subcontractor thereunder, the Contractor has credible evidence that a principal, employee, agent, or subcontractor of the Contractor has committed a violation of Federal criminal law involving fraud, conflict of interest, bribery, or gratuity violations found in Title 18 U.S.C. or a violation of the civil False Claims Act (31 U.S.C. 3729-3733).
Counter Trafficking in Persons
FAR 52.222-50: The Contractor shall inform the Contracting Officer immediately of—
(1) Any information it receives from any source (including host country law enforcement) that alleges a Contractor, employee, subcontractor, or subcontractor employee has engaged in conduct that violates this policy; and
(2) Any actions taken against Contractor employees, subcontractors, or subcontractor employees pursuant to this clause.
2 CFR 200.113 and Standard Provision M26 (July 2015)
Consistent with 2 CFR 200.113, applicants and recipients must disclose, in a timely manner, in writing to the USAID OIG, with a copy to the cognizant agreement officer, all violations of federal criminal law involving fraud, bribery, or gratuity violations potentially affecting the Federal award.
Subrecipients must also disclose to OIG and the prime recipient (U.S. and non-U.S. NGOs)
Recipient must include this requirement in all subawards and contracts
Questions from CIDC members…
• Does OIG require grantee fraud reporting?
• How does OIG do industry outreach?
• Does OIG website generate a complaint #?
• What is credible evidence?
• How does OIG interact with SDO? How are
referrals made? Cold comfort letters?
• Trends in mandatory disclosures?
• Average length of an investigation?
• What is your primary source of investigative leads?
Hotline?
• IG subpoenas vs. civil investigative demands
• Middle East and Asia:
SAC Chris Reed
202-712-1710 (office)
• Rest of the world:
SAC John Schofield
202-712-5899
• AIGI Daniel Altman202-712-0075