NARCOTICS INTERDICTION:

Treasury Forfeiture Fund

Reimbursements to Puerto Rico

OIG-01-095 September 26, 2001

Office of Inspector General

*******

The Department of the Treasury
Contents

TFF Reimbursements to Puerto Rico (OIG 01 095) Page 1

Audit Report.........................................................................................................3

Results in Brief....................................................................................................4

Background.........................................................................................................5

Findings and Recommendations............................................................................7

Difference in EOAF and Local Agency Overtime Hours .....................................7

Recommendations ..........................................................................................9

EOAF Overtime Reimbursements Made Prior To Local

Agency Payments...........................................................................................9

Recommendation..........................................................................................11

The Puerto Rico Treasury Commingled and Delayed

Transfer of EOAF Payments ..........................................................................11

Recommendation..........................................................................................12

Non-Permissible Use of Vehicles Purchased With

Treasury Forfeiture Fund Assets....................................................................13

Recommendation..........................................................................................14

Appendices

Appendix 1: Objectives, Scope, and Methodology..........................................16

Appendix 2 Summary of Overtime Hours Paid By Local Puerto Rico 

Agencies Versus EOAF Reimbursements.....................................18

Appendix 3: Underpayment of Hours by LEAs................................................19

Appendix 4: Management Comments ............................................................20

Appendix 5: Major Contributors to This Report...............................................22

Appendix 6: Report Distribution.....................................................................23
Contents

TFF Reimbursements to Puerto Rico (OIG 01 095) Page 2

Abbreviations

EOAF Executive Office for Asset Forfeiture

FY Fiscal Year

HACIENDA Departamento de Hacienda (Puerto Rico Treasury)

LEA Law Enforcement Agency

NIE Negociado de Investigaciones Especiales

OCDETF Organized Crime Drug Enforcement Task Force

OIG Office of Inspector General

PRPD Puerto Rico Police Department

TFF Treasury Forfeiture Fund
OIG Audit

Report

The Department of the Treasury

Office of Inspector General

TFF Reimbursements to Puerto Rico (OIG 01 095) Page 3

September 26, 2001

Mr. Raymond M. Dineen

Director

Executive Office for Asset Forfeiture

The Treasury Forfeiture Fund (TFF) was established in 1992 to replace 

the U.S. Customs Service Forfeiture Fund, becoming the Department 

of the Treasury’s counterpart to the Department of Justice Assets 

Forfeiture Fund. All law enforcement organizations within Treasury 

participate, and also the U. S. Coast Guard, which historically 

participated in the Customs fund. The TFF reimburses state and local 

Law Enforcement Agencies (LEAs) for overtime salary expenses 

associated with their participation in a joint operation Task Force. 

Additionally, TFF provides equitable sharing payments to these 

agencies for work done that led to a forfeiture.

A significant benefit of the fund is its contribution to strengthening the 

overall law enforcement capabilities of fund participants and enhancing 

cooperation among foreign, federal, state and local LEAs through the 

equitable sharing of forfeited assets.

We conducted an audit of the above program at your request in a 

memorandum dated February 18, 2000. The overall objective of this 

audit was to determine if the TFF reimbursements to the Puerto Rico 

Treasury were valid, properly controlled, and used in accordance with 

Executive Office for Asset Forfeiture (EOAF) requirements. We 

conducted our work from May 2000 through February 2001 at EOAF 

Headquarters in Washington, DC; Customs Special Agent-In-Charge 

Office (SAIC); Puerto Rico Police Department (PRPD); Puerto Rico 

Treasury also known as the Departamento de Hacienda (Hacienda); 

and the Negociado de Investigaciones Especiales (NIE), all located in 

San Juan, Puerto Rico. A more detailed description of our objective, 

scope and methodology is provided as Appendix 1.
TFF Reimbursements to Puerto Rico (OIG 01 095) Page 4

Results in Brief

Our review disclosed that the Hacienda, PRPD and NIE had not 

properly controlled, used and accounted for EOAF reimbursements. 

Discrepancies found were mostly bookkeeping and procedural. No 

one discrepancy was material in and of itself. However, the cumulative 

effect of all the discrepancies needs to be addressed and the 

necessary corrective actions taken by the LEAs and EOAF.

The Puerto Rico LEAs paid their agents for overtime hours that were 

different from those reimbursed by EOAF. The LEAs did not pay 

agents approximately $4,598 in funds provided by EOAF. Conversely, 

these agencies also paid for 2,331 hours overtime that were not 

reimbursed by EOAF. In addition, we documented many instances 

when local agents were paid from 2 to 20 months after the overtime 

was worked and requested reimbursements were paid by EOAF.

We identified that EOAF reimbursements made to the LEAs were 

deposited into a Puerto Rico Treasury general fund suspense account 

along with other Puerto Rico Treasury receipts, without a way to 

specifically identify revenue accounts. As a result, EOAF payments 

were commingled and disbursements by the Puerto Rico Treasury to 

the local LEAs were delayed. Further, our physical observation of 

selected items purchased with TFF funds disclosed that four vehicles 

were used for non-enforcement purposes.

The aforementioned conditions are the result of the LEAs failure to: 

• use the certified hours from the Treasury reimbursement 

document as their source for input into their payroll system,

• comply with signed agreements that dictate timely payments of 

their agents,

• establish the proper accounting mechanism to track TFF funds, 

and

• adhere to the permissible use of assets purchased with TFF 

funds.
TFF Reimbursements to Puerto Rico (OIG 01 095) Page 5

We made recommendations to address the problems we identified. 

These included ensuring that the Puerto Rico LEAs comply with 

their signed agreements to pay overtime to their agents; make 

overtime payments in a timely manner; establish the proper 

accounting mechanism to track TFF funds; and, follow guidelines 

for the permissible use of assets purchased with TFF funds.

EOAF management agreed to instruct the Puerto Rico LEAs to 

comply with signed agreements regarding the payment of overtime; 

establishment of separate accounts to identify and account for TFF 

funds; and, adhere to the permissible use of policy for assets 

purchased with equitable shared monies.

We believe that completion of these corrective actions will 

strengthen the Treasury Forfeiture Fund Reimbursement Program in 

Puerto Rico. The complete text of EOAF's response is provided in 

Appendix 3.

Background

On October 6, 1992, Congress enacted legislation establishing the 

TFF to replace the U.S. Customs Service Forfeiture Fund. The new 

fund became the Treasury’s counterpart to the Department of Justice 

Assets Forfeiture Fund. All law enforcement organizations within 

Treasury participate. The U. S. Coast Guard, which historically 

participated in the Customs fund, is also a fund participant. As of 

October 1, 1993, the TFF reimburses state and local LEAs for 

overtime salary expenses associated with their participation in a 

joint operation Task Force. A more significant benefit of the fund is 

its contribution to strengthening the overall law enforcement 

capabilities of fund participants and enhancing cooperation among 

foreign, federal, state and local LEAs through the equitable sharing of 

forfeited assets from joint operations.

Money from the TFF may be used to pay reimbursable costs incurred 

by local, county, and state LEAs when their members participate in 

joint operations with Treasury LEAs. Reimbursement payments are 

authorized for overtime salaries, travel, fuel, training, equipment, and 

other similar costs incurred in a joint law enforcement operation.
TFF Reimbursements to Puerto Rico (OIG 01 095) Page 6

The following general guidelines are applicable to this policy.

• The costs to be funded must be costs of a local, county or state law 

enforcement officer. This authority does not include costs of 

federal personnel, private parties, administrative personnel, or other 

local, county or state officials who are not classified as “law

enforcement officers.” It will, however, include permissible costs 

incurred by local state prosecutors.

• The local, county or state law enforcement officer(s) must be 

involved in a joint law enforcement operation with the federal 

government. Not all-joint activity is a “joint operation.” A more 

detailed definition of “joint” operation is presented below. All costs 

to be funded must be directly related to the joint law enforcement 

operation.

• The joint law enforcement operation must be with a Treasury law 

enforcement agency participating in the TFF. At this time, this 

policy covers joint operations, including Organized Crime Drug 

Enforcement Task Force (OCDETF) cases, where the Treasury law 

enforcement agency is the lead or sole federal agency. The 

Treasury LEAs are:

a) Bureau of Alcohol, Tobacco and Firearms;

b) Internal Revenue Service, Criminal Investigation Division;

c) United States Customs Service; and

d) United States Secret Service.

• Payments can only be used for those expenses that are authorized 

by statute. It is clear that the statute does not authorize payment of 

regular salaries of local, county, or state officers, whether directly or 

indirectly.

Payments may be made to the extent they are included in the Treasury 

law enforcement agency’s Fiscal Year (FY) Plan, and the monies are 

available within the fund to satisfy the request. As a general rule, the 

reimbursable payment of overtime costs incurred by local, county or 

state LEAs participating in a Treasury law enforcement agency 

investigation shall be limited to $13,000 per FY, per officer.
TFF Reimbursements to Puerto Rico (OIG 01 095) Page 7

EOAF overtime payments and asset sharing distributions made to the 

Puerto Rico agencies are summarized in the following table:

Table 1. EOAF Payments and Distributions

FY 1997 FY 1998 FY 1999 TOTAL

Overtime

Reimbursements

$ 39,496 $213,308 $304,428 $ 557,232

Asset Sharing 

Payments

637,163 348,164 69,385 1,054,712

TOTALS $676,659 $561,472 $373,813 $1,611,944

Findings and Recommendations

Finding 1 Difference in EOAF and Local Agency Overtime Hours

The Puerto Rico LEAs paid their agents for overtime hours that differed 

from those hours requested and subsequently reimbursed by the 

EOAF. The differences occurred primarily because the LEAs did not 

pay the agents for the same overtime hours that were approved, 

certified, and later submitted on the Treasury reimbursement 

document.

EOAF Directive 18 (revised October 1995) states: “....money from the 

TFF may be used to pay reimbursable costs incurred by local, county, 

and state police law enforcement agencies when their members 

participate in joint operations with Treasury law enforcement agencies. 

Overtime salaries and other similar costs incurred in a joint law 

enforcement operation will be authorized for payment.”

The Agreement Between Treasury LEAs and Local, County and State 

LEAs for the Reimbursement of Expenses signed by the local agency 

heads states: “The Treasury Asset forfeiture fund will reimburse the 

agency for approved overtime costs and authorized travel and per 

diem expenses for personnel assigned to the Task Force. The Agency 

is responsible for paying its employees for their overtime, travel and 

per diem expenses. To ensure proper and complete utilization of 
TFF Reimbursements to Puerto Rico (OIG 01 095) Page 8

overtime and expense allocations, reimbursement claims must be 

submitted monthly on the Reimbursement Request Form.” Further, the 

agreement states: “The Agency acknowledges that they remain fully 

responsible for their obligations as the employer of the officer(s) 

assigned to the task force and are responsible for the payment of 

overtime earnings, withholdings, insurance coverage and all other 

requirements by law, regulation, ordinance or contract regardless of 

the reimbursable overtime charges incurred.”

We found that the differences in overtime hours paid to the agents by 

the Puerto Rico local agencies were a routine occurrence. On an 

operation-by-operation basis, there was no logic as to how many 

overtime hours were over/underpaid by the local agencies. Sometimes 

it was more; other times it was less. However, as depicted in the chart 

in Appendix 2, the EOAF made reimbursements on 5 operations for 

345.20 hours that were not paid by the LEAs to their agents. Based on 

EOAF payment records, the average hourly rate for all operations was 

$13.32. Using this average, approximately $4,598 was misused by 

Puerto Rico LEAs. These funds could have been put to better use by 

the EOAF if they were not to be used by the LEAs for overtime. See 

Appendix 3 for a summary analysis of the 5 operations that involved 

underpayments. 

Also, based on our review of 16 joint law enforcement operations for 

FY 1997, 1998, and 1999 involving the Hacienda, NIE and PRPD, the 

net result was that the local agencies overpaid their agents for 2,331 

hours of overtime. See Appendix 2 for a summary analysis of the 

underpayment differences of hours reimbursed by EOAF and those 

paid by the LEAs. The net overpayment of 2,331 hours by the LEAs is 

of no negative financial consequence to the TFF.

To maintain consistency and program integrity it is imperative that 

corrective actions are taken by Puerto Rico LEAs payroll divisions to 

pay their agents for the same number of hours that are later certified 

by the supervisor, local law enforcement agency head, and the 

Treasury agency head. At exit conferences with the local agency 

heads we suggested and they concurred that their payroll divisions use 

the hours from the Treasury reimbursement document as their source 

for input.
TFF Reimbursements to Puerto Rico (OIG 01 095) Page 9

Recommendations

1. The Director of the EOAF should instruct the Puerto Rico LEAs to 

comply with their signed agreements and to pay overtime certified 

on the Treasury reimbursement document.

Management Comment. EOAF management concurred with our 

recommendation and will instruct the Puerto Rico agency heads 

that they must comply with the signed agreements and pay the 

overtime that is certified on the Treasury reimbursement document.

OIG Comment. The OIG believes the corrective actions taken 

or planned address the intent of the recommendation.

2. The Director of the EOAF should request that the LEAs either 

reimburse the TFF for the $4,598 or make the appropriate 

payments to the agents.

Management Comment. EOAF management agreed to instruct 

the LEAs to pay their agents the funds that were reimbursed by the 

Treasury Forfeiture Fund. However, they do not agree that any 

action should be taken with regards to the $4,598.00 since this is 

an estimate.

OIG Comment. The OIG believes the corrective actions taken 

or planned address the intent of the recommendation.

Finding 2 EOAF Overtime Reimbursements Made Prior to Local

Agency Payments

We found that Puerto Rico local law enforcement agents were being paid 

from 2 to 20 months after the overtime was worked and the requested 

reimbursements were submitted by the Puerto Rico local agencies to the 

EOAF. We reviewed a total of 16 operations and 715 payroll records for 

FYs 1997, 1998, and 1999. (See Table 2 below).
TFF Reimbursements to Puerto Rico (OIG 01 095) Page 10

Table 2. Break Down of Payroll Records by Agency

Law Enforcement Agency

Number of

Payroll Records

Departamento de Hacienda 112

NIE 155*

Puerto Rico Police Department 448

Total Payroll Records 715

*As of the end of our fieldwork, February 2001, the NIE had not provided us with 6 of 

the 155 payroll documents we requested. Further, NIE had not provided an 

explanation for the six missing payroll documents.

EOAF Directive 18 states that money from the TFF may be used to 

pay reimbursable costs incurred by local, county, and state police law 

enforcement agencies when their members participate in joint 

operations with Treasury law enforcement agencies. Also, each 

participating local, county, or state law enforcement agency shall 

submit on agency letterhead certified as accurate copies of payroll 

records, or statements of overtime costs incurred, to support the 

request for reimbursement to the lead Treasury law enforcement 

agency for review and authorization for payment. It is also clear that 

the statute does not authorize the payment of direct salaries of law 

enforcement agencies.

We reviewed 112 payroll records from the Hacienda. Payments to the 

respective law enforcement agents were made 2 to 10 months after 

the overtime was worked. The majority of these payments were made 

between 3 and 5 months later. Our review of 155 of 161 payroll 

records from the NIE disclosed that payments to agents were made 

from 2 to 20 months after the overtime work was performed. The 

majority of the 155 payments occurred between 4 and 7 months later. 

In addition, of the 448 PRPD payroll records we reviewed, in 99 

instances their agents were paid 2 to 10 months after the overtime was 

worked. Delays in these payments were evenly spread over the 2 to 

10 month period.

We documented that the Hacienda, NIE and PRPD had submitted 

requests for reimbursements to the EOAF for overtime expenses prior 

to payments being made to their agents. We interviewed human 

resource personnel within the three LEAs regarding the late payments. 

They could not provide us with valid explanations as to why the payroll 
TFF Reimbursements to Puerto Rico (OIG 01 095) Page 11

records and corresponding payments were untimely processed. The 

EOAF reimbursements were used inappropriately as the equivalent of 

a float of funds by the Puerto Rico LEAs.

Recommendation

1. The Director of the EOAF should inform the local LEAs and 

participating Treasury bureaus that overtime payments are not 

being made timely. Also, the Director of the EOAF should 

instruct the LEAs to comply with signed agreements that dictate 

timely payments.

Management Comment. EOAF management concurred with the 

OIG recommendation and will instruct Treasury law enforcement 

agencies to ensure that requests for reimbursements comply with 

the signed agreements.

OIG Comment. The OIG believes the corrective actions taken 

or planned address the intent of the recommendation.

Finding 3 The Puerto Rico Treasury Commingled and Delayed 

Transfer of EOAF Payments

The Hacienda’s use of general suspense accounts for the deposit of 

overtime and asset sharing payments, without a way to specifically 

identify revenue accounts, has resulted in EOAF payments being 

commingled with other Puerto Rico government receipts.

The Hacienda deposits EOAF reimbursements for overtime and asset 

sharing payments into general suspense accounts. This is contrary to 

Treasury’s Guideline to Equitable Sharing, dated October 1, 1996, 

which requires the establishment of a separate revenue account solely 

for the use of the Treasury sharing proceeds. Additionally, the process 

to identify the appropriate local law enforcement agency due the 

payments is neither timely nor efficient. This process has also 

contributed to delayed disbursements of EOAF receipts.

We found, in one example, 26 asset sharing payments to the PRPD for 

approximately $1,054,727 that had been held in the Hacienda’s 

suspense account from 1 to 11 months before it was transferred to the 

PRPD. The NIE, in another example, was reimbursed overtime 
TFF Reimbursements to Puerto Rico (OIG 01 095) Page 12

payments of $121,571 by the EOAF for five joint operations between 

FY 1997 and FY 1999. As of the end of audit fieldwork in February 

2001, the Hacienda had not transferred $99,282 to the appropriate NIE 

account. The following table provides a summary of the NIE 

reimbursements and receipts.

Table 3. NIE Reimbursements and Receipts

Operation

Number

Total Overtime

Reimbursement

s

Overtime

Reimbursement

Receipts

Documented by 

NIE

Overtime

Reimbursement

Receipts Not

Documented by 

NIE

9465 $30,000 $ -0- $30,000

8527 38,807 -0- 38,807

9047 30,289 12,510 17,779

8017 17,475 9,779 7,696

7049 5,000 -0- 5,000

TOTALS $121,571 $22,289 $99,282

The commingling of funds and their delayed transfer by the Puerto 

Rico Treasury resulted in the inability to track and account for TFF 

funds, and ultimately their misuse. In our opinion, the Puerto Rico 

Treasury should establish separate accounts for each local agency for 

TFF payments. Also, the Hacienda should transfer the TFF payments 

to the local LEAs immediately upon receipt.

Recommendation

1. The Director of the EOAF should instruct the Hacienda and the 

local LEAs to establish the proper accounting mechanism to track 

TFF funds.

Management Comment. EOAF concurred with the OIG finding 

that Treasury funds should not be commingled with the funds of a 

local agency. EOAF will instruct the Puerto Rico agencies to 

establish either a separate bank account or a separate accounting 

code to identify and account for Treasury equitable sharing monies.

OIG Comment. The OIG believes the corrective actions taken 

or planned address the intent of the recommendation.
TFF Reimbursements to Puerto Rico (OIG 01 095) Page 13

Finding 4 Non-permissible Use of Vehicles Purchased With 

Treasury Forfeiture Fund Assets

Generally, purchases of equipment and vehicles with TFF funds were 

for permissible law enforcement purposes. However, we found that 4 

of 20 vehicles in our sample were being used for non-law enforcement 

purposes.

We physically verified the locations of 114 sample items and 

determined if items that were purchased were for permissible law 

enforcement purposes. The judgmental sample of PRPD and 

Hacienda purchases consisted of TFF assets from FY 1998 and

FY 1999. Our sample included 108 PRPD items as follows:

Table 4. PRPD Sample Items

ITEMS QUANTITY

RADIOS 26

CAMERAS 48

VEHICLES 20

OTHER MISC 14

TOTAL 108

In addition to the items above, we selected a sample of six Hacienda 

items as follows:
TFF Reimbursements to Puerto Rico (OIG 01 095) Page 14

Table 5. Hacienda Sample Items

ITEMS QUANTITY

RECORDER 1

COMPUTER CASE 1

ECONOMY CASE 1

LUGGAGE CART 1

GYMNASIUM RENTAL* 1

CONFERENCE 1

TOTAL 6

*Note: The gymnasium rental was one contract that included payment 

for 17 months.

The vast majority of the items were appropriately purchased and used. 

However, we determined that four vehicles purchased by the PRPD 

with TFF funds were being used to transport Puerto Rico’s governor, 

ex-governor, superintendent, and ex-superintendent of police. 

Treasury’s Guideline to Equitable Sharing, revised October 1, 1996, 

shared cash or proceeds of forfeited property must be used for law 

enforcement purposes, and the use of shared funds for political or 

personal purposes is not permissible.

In our opinion, the transporting of government officials does not qualify 

as permissible use of TFF assets. The use of TFF assets is intended 

to strengthen the overall law enforcement capability of fund 

participants, and any improper use of assets such as these four 

vehicles only serves to undermine the goals and integrity of the 

equitable sharing program.

At the exit conference, the Chief of Police for the PRPD agreed to 

transfer the vehicles for law enforcement use.

Recommendation

1. The Director of the EOAF should remind the PRPD of the nonpermissible use of assets purchased with TFF funds as outlined in 
TFF Reimbursements to Puerto Rico (OIG 01 095) Page 15

the Guide to Equitable Sharing for Foreign Countries and Federal, 

State, and Local LEAs.

Management Comment. EOAF management agreed with the 

proposed action by the PRPD chief of police to transfer the use 

of the vehicles, although EOAF believes that the use of the 

vehicles is a judgment call. They agree that actions to transfer 

the vehicles for less questionable law enforcement use will 

more clearly comply with the Treasury equitable sharing 

guidelines.

OIG Comment. The OIG believes the corrective actions 

taken or planned address the intent of the recommendation.

* * * * * *

We would like to extend our appreciation to EOAF, Customs, and 

personnel from the Puerto Rico LEAs for the cooperation and 

courtesies extended to our staff during the review. If you have any 

questions, please contact me at 713-706-4611 or the Field Audit 

Manager, at 305-591-0959. Major contributors to the report are 

listed in Appendix 5.

George W. Tabb

Regional Inspector General for Audit
Appendix 1

Objectives, Scope, and Methodology

TFF Reimbursements to Puerto Rico (OIG 01 095) Page 16

The overall objective of this audit was to determine if TFF 

reimbursements to the Puerto Rico Treasury, also known as the 

Departamento de Hacienda, were valid, properly controlled, and used 

in accordance with statutory requirements. To achieve this objective 

we determined:

• If there were valid agreements between federal and participating 

LEAs. Also, whether any other required certifications were on file,

• If the operations for which reimbursements were made qualified as 

joint operations, and

• If there were reimbursements made to the Hacienda. If so, for how 

much, when and for what purpose.

We reviewed all related TFF policies and guidelines regarding 

payments, use of reimbursable funds, and all accounting records for 

which reimbursements were made to the Puerto Rico Treasury from 

FY 1997 through FY 1999. The audit fieldwork was conducted at the 

EOAF Headquarters in Washington, D.C.; Customs SAIC Office, 

PRPD, Puerto Rico Treasury (Hacienda), Negociado de 

Investigaciones Especiales (NIE), all located in San Juan, Puerto 

Rico. All audit steps were coordinated and performed in conjunction 

with special agents of the Office of Inspector General. Although the 

audit primarily focused on overtime reimbursements and asset sharing 

disbursements to Puerto Rico agencies, the audit included:

• interviewing personnel responsible for the requisition, 

reimbursement, and expenditure of forfeiture funds;

• obtaining, reviewing, documenting policies, procedures, and all 

related accounting records from initial request through 

reimbursement and expenditures;

• determining if policies and procedures were adhered to and if funds 

were used per statutory requirements; and,
Appendix 1

Objectives, Scope, and Methodology

TFF Reimbursements to Puerto Rico (OIG 01 095) Page 17

• physically verifying the existence and law enforcement use of 

purchases made with TFF assets.

The audit fieldwork was performed from May 2000 through February 

2001 in accordance with generally accepted government auditing 

standards.
Appendix 2

Summary of Overtime Hours Paid By Local Puerto Rico Agencies 

Versus EOAF Reimbursements

TFF Reimbursements to Puerto Rico (OIG 01 095) Page 18

 1 2 3

Operation

Number

Hours Paid

By Agencies

Hours 

Reimbursed

By EOAF

Overpayment / 

Underpayment(-)

By Agencies

Hacienda

7053 979.75 800.50 179.25

8016 1886.97 1850.20 36.77

9049 8613.80 8218.63 395.17

NIE

7049 424.55 321.00 103.55

8017 1196.25 1181.00 15.25

8527 3040.10 3042.10 -2.00

9047 2153.96 2141.00 12.96

9465 1985.50 1974.50 11.00

PRPD

7050 519.00 311.50 207.50

7051 1292.00 726.00 566.00

7052 2085.00 1013.50 1071.50

8019 4133.50 4055.00 78.50

8020 2084.00 2119.50 -35.50

8021 2059.10 2200.00 -140.90

8400 2254.50 2361.50 -107.00

9048 13286.00 13345.80 -59.80

TOTALS 47993.98 45661.73 2331.25

Column 3 = Column 1 minus Column 2
Appendix 3

Underpayment Of Hours By LEAs

TFF Reimbursements to Puerto Rico (OIG 01 095) Page 19

The potential funds put to better use for Finding 1, 

Recommendation 2 relates to the Puerto Rico LEAs paying their 

agents for overtime hours that were less than the correctly certified 

hours that were reimbursed by the EOAF. The potential funds put 

to better use are a one time occurrence involving five operations 

between fiscal years 1998 and 1999. The differences in hours 

paid and the related operations are outlined below.

Operation

Numbers

1

Hours Paid by 

LEAS

2

Hours Reimbursed 

by EOAF

3

Overpayment/

Underpayment (-) 

by LEAS

NIE

8527 3,040.10 3,042.10 (2.00)

PRPD

8020 2,084.00 2,119.50 (35.50)

8021 2,059.10 2,200.00 (140.90)

8400 2,254.50 2,361.50 (107.00)

9044 13,286.00 13,345.80 (59.80

Total 22,723.70 23,068.90 (345.20)

Column 3 = Column 1 minus Column 2
Appendix 4

Management Comments

TFF Reimbursements to Puerto Rico (OIG 01 095) Page 20
Appendix 4

Management Comments

TFF Reimbursements to Puerto Rico (OIG 01 095) Page 21
Appendix 5

Major Contributors to this Report

TFF Reimbursements to Puerto Rico (OIG 01 095) Page 22

George W. Tabb, Regional Inspector General for Audit (Southern)

Ethel Taylor-Young, Acting Field Audit Manager (Miami)

Ken Coleman, Audit Manager (Houston)

Denny Kallusingh, Auditor-in-Charge

Linda J. Howarton, Auditor

Julia Fleisher, Auditor

Alejandro Hernandez, Auditor
Appendix 6

Report Distribution

TFF Reimbursements to Puerto Rico (OIG 01 095) Page 23

The Department of the Treasury

Office of Strategic Planning and Evaluations

Office of Accounting and Internal Control

Office of Budget

Treasury Executive Office of Asset Forfeiture 

Director EAOF

Program Manager EOAF

U. S. Customs Service

Special Agent-in-Charge (SAIC), Puerto Rico

Director, Evaluations Oversight, Office of Planning

Office of Management and Budget

OIG Budget Examiner