Details from DHS' OIG Report on CBP FY 2009 Internal Controls (Part IV - Bonded Warehouses, FTZs)
The Department of Homeland Security's Office of Inspector General has issued a report containing an independent audit conducted by KPMG LLP that addresses the strengths and weaknesses of U.S. Customs and Border Protection's fiscal year 2009 internal controls over financial reporting.
This is Part IV of a multi-part series of summaries of this report and provides an overview of the report's findings regarding CBP's FY 2009 significant deficiencies1 in bonded warehouses (BWs) and foreign trade zones (FTZs) processes. Bonded warehouses and FTZs processes were also found to be a significant deficiency in FY 2008. See future issues of ITT for additional summaries.
Internal Control Weaknesses in Bonded Warehouse/FTZ Processes
The auditors found several weaknesses in CBP's BW/FTZ processes. CBP does not have comprehensive guidance related to the determination and documentation of risk assessments. CBP does not have formal, comprehensive guidance related to the monitoring of the BW and FTZ programs by HQ and the Field Offices throughout the year. At the time of testwork, CBP did not have a comprehensive information system to document risk assessments, track both scheduled and completed compliance reviews, and perform HQ and Field Office monitoring and analysis of the BW and FTZ programs.
CBP cannot effectively monitor the BW/FTZ program if a complete population of all BWs and FTZs is not compiled. The lack of specific guidance for determining risk assessment leads to inconsistent procedures in assessing risk at the port level.
Internal Control Weaknesses Included ACE Testing, Compliance Reviews, Etc.
The auditors detailed the weaknesses as follows:
ACE BW/FTZ databases. While CBP has developed national databases within the Automated Commercial Environment (ACE), which contain an inventory of all BWs and FTZs, such databases have not been tested for completeness. In addition, these databases are not currently used to document the assessed risk of each BW or FTZ, compliance reviews scheduled, or the results of compliance reviews. Furthermore, there are no requirements for HQ or the Field Offices to compare this database to the compliance review schedules submitted by the ports to ensure that all compliance reviews are being performed.
Compliance review handbooks. The BW and FTZ Compliance Review Handbooks did not have specific guidance, in the form of a questionnaire or checklist, for determining the risk assessment of a BW or FTZ.
BW/FTZ survey. In FY 2009, HQ implemented an electronic survey that it completes at the end of the fiscal year to determine the status of the BW and FTZ programs; however, the survey did not conclude on the effectiveness of compliance reviews. In addition, the survey did not contain detailed descriptions of common discrepancies identified in those compliance reviews, risks presented by those discrepancies, or techniques for mitigating those risks.
Port issues. As part of the auditors' testwork at ten ports with BW and FTZ facilities, they noted the following specific findings related to BW and FTZ internal controls: (1) he risk assessment for one FTZ at one port was not performed; and (2) the risk assessment for one BW at one port was marked as low risk; however, the errors noted in the compliance review documentation more accurately reflect a medium risk.
Recommendations for Improving the BW and FTZ Programs
The auditors recommended that CBP take the following actions (see report for details):
Continue to develop standardized procedures for HQ or Field Office oversight;
Continue the current implementation of national databases of all BWs and FTZs within ACE and develop procedures to ensure completeness;
Continue to develop and implement standard procedures for conducting risk assessments for all BWs and FTZs;
Create a standard format for compliance review schedules to be utilized by all ports for transmission to CBP-HQ;
Utilize and enhance its electronic port survey system to provide more detailed and timely information on the BW and FTZ programs to enable meaningful analysis by HQ;
Increase HQ and Field Office oversight to ensure that compliance reviews are being conducted properly and timely in accordance with the Compliance Review Handbooks; and
Continue to offer and enhance annual training to CBP BW/FTZ personnel to provide updates and changes to the program, and reinforce requirements over the program.
1A significant deficiency is a deficiency, or a combination of deficiencies, in internal control that is less severe than a material weakness, yet important enough to merit attention by those charged with governance.
(See ITT's Online Archives or 03/15/10 news, 10031515, for Part III of BP's multi-part series of summaries on this report, with a link Part II.)
DHS OIG report (OIG-10-51, dated February 2010) available at http://www.dhs.gov/xoig/assets/mgmtrpts/OIG_10-51_Feb10.pdf