Audit Report

OIG-20-040

BILL AND COIN MANUFACTURING 

Audit of Bureau of Engraving and Printing’s 

Implementation of Security Features and 

Meaningful Access for the Blind and Visually 

Impaired into New Note Design

June 30, 2020

Office of Inspector General

Department of the Treasury
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i 

Contents

Audit Report

Results in Brief ...................................................................................................2

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

Audit Results......................................................................................................9

Finding 1 BEP is Implementing Security Features and Incorporating Meaningful 

Access for the Blind and Visually Impaired into New Note Designs, but 

Refinement of Guidance and Additional Schedule Detail Would Prove 

Beneficial ......................................................................................9

Recommendations ........................................................................12

Finding 2 ACD Governance Not Operating As Intended ................................... 14

Recommendation.......................................................................... 16 

Other Matter 

Proposed 2020 Note Redesign Impacted By Security Feature

Development .............................................................................. 17 

Appendices

Appendix 1: Objectives, Scope, and Methodology................................................. 22

Appendix 2: Additional Background..................................................................... 24

Appendix 3: Management Response.................................................................... 28

Appendix 4: Major Contributors to This Report.....................................................30

Appendix 5: Report Distribution .........................................................................31

Abbreviations

ACD Advanced Counterfeit Deterrence Steering Committee

BDP Banknote Development Process

BEP Bureau of Engraving and Printing

Board Board of Governors of the Federal Reserve System

currency United States Currency

CTO Currency Technology Office 

GAO Government Accountability Office
ii 

ICC Interagency Currency Committee

IMS Integrated Master Schedule

JAMES Joint Audit Management Enterprise System

MOU memorandum of understanding

Note Federal Reserve note

OIG Office of Inspector General

PAC Program Approval Committee

Secret Service United States Secret Service

TAC Technology Approval Committee

TDP Technology Development Process

Treasury Department of the Treasury

USCP United States Currency Program
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Audit of Bureau of Engraving and Printing’s Implementation of Security 

Features and Meaningful Access for the Blind and Visually Impaired into 

New Note Design (OIG-20-040) 

1

June 30, 2020

Leonard R. Olijar 

Director

Bureau of Engraving and Printing 

This report presents the results of our audit of the Department of 

the Treasury (Treasury) Bureau of Engraving and Printing’s (BEP) 

implementation of security and meaningful access features into

Federal Reserve notes (note) through new design processes and 

governance. This audit was in our fiscal year 2019 Office of 

Inspector General (OIG) annual audit plan.1 Our objective was to

determine whether BEP is properly implementing security features 

into the United States currency (currency) as part of its counterfeit 

deterrence program and incorporating tactile features and highcontrast numerals in future currency designs to improve meaningful 

access for blind and visually impaired individuals in accordance with 

requirements approved by the Secretary of the Treasury.2 

To accomplish our objective, we interviewed personnel from BEP, 

the Board of Governors of the Federal Reserve System (Board), 

United States Secret Service (Secret Service), and other relevant 

stakeholders to gain an understanding of their involvement in new 

note design, including the development and implementation of 

security and tactile features. We also reviewed applicable 

documentation pertaining to new note development including 

policies and procedures used in program management over new 

note development, as well as multi-agency governance committee 

 

1

 Annual Plan Fiscal Year 2019 (OIG-CA-19-007; issued October 31, 2018) 2

 Security features are counterfeit-deterring features used to authenticate currency. Security features 

can be both noticeable on the note, without special equipment, as well as covert. Tactile features and 

high-contrast numerals assist users with the capability to distinguish between note denominations. A 

tactile feature provides users the means to identify a note’s denomination through touch and highcontrast numerals refer to larger and colored numbers that assist in identifying the note’s 

denomination.
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minutes to determine stakeholder involvement and decision making 

in new note design. In addition, as part of this audit and in response 

to Congressional concerns, we reviewed the circumstances 

surrounding Treasury’s timeline for unveiling of a new design 

concept for the $20 note. We conducted fieldwork from June 2019 

through February 2020. Appendix 1 provides a more detailed 

description of our objective, scope, and methodology. 

Results in Brief 

We found that BEP is implementing security features and 

incorporating meaningful access for the blind and visually impaired 

into currency through its newly structured note development 

governance and processes. These efforts and activities are under 

the multi-agency effort referred to as the United States Currency 

Program (USCP).

3

 

The current Catalyst series note redesign is the first in which BEP 

has followed these new structured processes for note redesign.4

These processes included a Technology Development Process (TDP)

implemented during 2013, which is a tailorable process used to 

develop technologies for inclusion in BEP products; and the 

Banknote Development Process (BDP) implemented during 2012, 

which is a multi-step process with phases that, among other things, 

integrates new security features into the currency design as well as 

develops design concepts. Although BEP is following these newly 

 

3

 As discussed further below and in appendix 2, USCP consists of and is governed by the following 

committees comprised of representatives from Treasury, BEP, the Board and its Currency Technology 

Office (CTO), and Secret Service: (1) Advanced Counterfeit Deterrence Steering Committee (ACD), 

responsible for making recommendations to the Secretary of the Treasury for the design, 

development, production, and issuance of currency, which includes coordinating redesign efforts of its 

member agencies; (2) Interagency Currency Committee (ICC), responsible for supporting the ACD and 

overseeing the note development Core teams; (3) Program Approval Committee (PAC), responsible for 

overseeing note development projects that have significant changes in note designs and overseeing 

Bank Development Process (BDP) Core teams; and (4) Technical Approval Committee (TAC), 

responsible for overseeing technology development projects by following the Technology Development 

Process (TDP) Handbook. 4

 The Catalyst series is the third major redesign of U.S. currency in the last 90 years. See the 

background section for additional information.
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developed processes, further refinement to the processes’ guidance 

to reflect lessons learned would improve effectiveness in note 

redesign and development. BEP is also utilizing an Integrated Master 

Schedule (IMS) to track the progress of BEP’s redesign efforts; 

however, additional detail would be beneficial in identifying issues 

that may impact the schedule of planned activities of the multiple 

agencies involved in the note redesign.

5

We also found that certain members of the Advanced Counterfeit 

Deterrence Steering Committee (ACD) are not attending committee 

meetings as was intended by the ACD charter, which in turn, could 

impact the effectiveness of the ACD. Full collaboration from all

multi-agency members is imperative to ensure that stakeholder 

leadership is kept sufficiently informed on note design. The ACD 

charter should be updated to ensure members’ roles, 

responsibilities, and current practices are clearly defined and 

communicated. Additionally, BEP should continue its progress in 

updating its memorandum of understanding (MOU) with the Board. 

These updates will ensure that documentation of governance and 

oversight over note development and production reflects existing 

practices.

6

Additionally, based on Congressional interest, we reviewed the 

circumstances surrounding Treasury’s timeline for unveiling of a 

new design concept for the $20 note. We found that the former 

Secretary of the Treasury made an announcement in April 2016 

proposing release of new $5, $10 and $20 note design concepts

during 2020.

7 This announcement was made outside the formal 

note development governance structure, and without the 

recommendation of the ACD. We also found that, in May 2016, the 

 

5

 An IMS is a program schedule which includes the entire scope of effort from start to finish. It 

connects the sequence of activities or tasks needed to complete the effort and displays how one 

activity relates or depends on another activity. This schedule has been continually updated for the 

$10 and $50 Catalyst note redesign. 6

 OIG-20-023 BILL AND COIN MANUFACTURING: BEP Improved Governance and Oversight over Note 

Development and Production But Challenges Remain; issued December 31, 2019. The audit report 

contained the recommendation that BEP update its MOU with the Board. 7

 In June of 2015, the former Secretary of the Treasury had announced a woman would be featured on 

the $10 redesigned note and unveiled in 2020. The April 2016 announcement identified that Lucretia 

Mott, Sojourner Truth, Susan B. Anthony, Elizabeth Cady Stanton, and Alice Paul would be honored 

on the $10 note and that Harriet Tubman’s portrait would be on the $20 note.
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former Secretary of the Treasury reported to the U.S. District Court 

for the District of Columbia that the first note ($10 note) in the 

currency redesign effort would be delayed from 2020 until 2026 in 

order to develop the necessary security features. Furthermore, the 

sequence schedule for note redesign has remained the same since 

2016 and the ACD never intended the release of the Catalyst series 

design in 2020. Historically, only after security features were 

developed, was the design with the note’s image finalized because

placement of security features can radically affect the note design. 

Therefore, the unveiling of the design typically occurs 6 months 

prior to issuance as part of the public information campaign. 

We recommend that the Director of BEP in collaboration, as 

necessary, with members of the USCP: 

1. Continue to improve the BDP and TDP guidance, including 

refining procedures to reflect lessons learned during its Catalyst 

note series redesign. 

2. Review and implement actions within the IMS program to 

improve the decision making process and help identify issues 

that may impact the schedule of planned note redesign activities. 

This includes ensuring that technical and key milestones are 

incorporated into the IMS at a detailed level. 

3. Ensure the ACD charter is updated in a timely manner, and as 

needed, to ensure roles, responsibilities, and current practices 

such as the attendance of ACD monthly meetings by appropriate 

personnel are clearly defined and communicated to its members. 

In a written response, BEP management agreed with our 

recommendations and outlined planned and taken corrective 

actions. Specifically, in response to our first recommendation, BEP

has developed lessons learned for the early phases of currency 

redesign. Management believes the pilot of BDP will provide 

comprehensive lessons learned material for both BDP and the 

integration of security features, as well as identify modifications to 

consider for BDP and TDP. During the execution of currency 

redesign, BEP will also identify improvement opportunities to 

incorporate into guidance and documentation. In response to 

recommendation number 2, BEP will revisit the requirements for the 
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level of detail, frequency, and milestones to be included in the IMS 

to improve the decision making process. Lastly, for recommendation 

number 3, BEP will update the ACD charter, including clarifying the 

roles and responsibilities of the ACD. Management’s response, in its 

entirety, is included as appendix 3.

Management’s response, and corrective actions taken and planned, 

meet the intent of our recommendations. Management will need to 

record the estimated date for completing its planned corrective

actions as well as the actual date of completed corrective actions in

the Joint Audit Management Enterprise System (JAMES), 

Treasury’s audit recommendation tracking system.

Background 

Currency Redesign is a Multi-Agency Task Driven by

Security 

Currency is redesigned primarily to address current and potential 

security threats. In addition, currency has been redesigned to 

address functional needs such as providing improved identification

for those visually impaired. Redesign requires seeking out and 

developing technology for new security features. As the complexity 

of counterfeiting threats has increased due to technology 

advancements, so has the complexity in and length of time 

necessary for development of security features.

8

The ACD is a federal multi-agency group responsible for 

coordinating counterfeit deterrence activities of its member 

agencies, including the design, development, production, and 

issuance of currency. ACD members consist of senior executives 

from Treasury Departmental Offices, BEP, the Board, and Secret 

Service. As discussed in further detail below, the ACD’s efforts in 

collaboration with its member agencies through the Interagency 

Currency Committee (ICC), Program Approval Committee (PAC), 

 

8

 In addition to deterring counterfeiting, security features facilitate the public’s use and authentication

of currency, provides accessibility and usability, and maintains public confidence. 
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and Technology Approval Committee (TAC) are referred to as the 

USCP. 

Based on the counterfeiting threat posed to each denomination, the 

ACD provides currency design recommendations to the Secretary of 

the Treasury.

9 Included among its recommendations is the sequence 

in which note denominations should be redesigned as well as design 

concepts that include security features to safeguard against 

counterfeiters. Each note denomination design, development, and 

issuance schedule is undertaken individually and completed over the 

course of several years. 

Tentative New Schedule for Next Redesign 

In the last 90 years, currency has been significantly redesigned 

twice. The ACD’s policy has been to redesign the note 

denominations collectively, as part of a family series, in which each 

note denomination has very similar architecture, but may have 

different security features incorporated in its design based on the 

counterfeiting threat posed to each denomination.10 Historically, the 

unveiling for each redesigned note occurs 6 months prior to note 

issuance to allow for public education of new security features.

Figure 1 below displays the last two families of note redesign 

releases, including those of the New Currency Design series and the 

NexGen series. Additionally, displayed is the tentative schedule for 

the next redesign of notes referred to as the Catalyst family.11 

 

9

 The Secretary of the Treasury has sole statutory authority to issue currency and determine currency 

design under the Legal Tender Acts, Act February 25, 1862, 12 Stat. 345; Act July 11, 1862, 12 

Stat. 532; Act March 23, 1863, 12 Stat. 709 and; 12 U.S.C. 418, Printing of notes; denomination 

and form. 10 A family series of notes includes the $5, $10, $20, $50, and $100 notes. The $1 and $2 notes have 

not been redesigned since the ACD’s establishment in 1982 as both notes have not historically been a 

frequent target of counterfeiters. Additionally, the redesign of the $1 note has been prohibited by the 

annual Financial Services and General Government Appropriations Act, with the most recent being the 

Consolidated Appropriations Act of 2020 (Public Law 116-93) signed by the President on 

December 20, 2019. 11 The schedule for the Catalyst family of notes represents when the notes are estimated to be ready for 

production printing rather than the release dates to the public. The Board maintains authority over the 

issuance and release dates of notes.
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Figure 1- Past Note Redesign and Tentative Redesign Release

•Year 1996 1997 1998 2000

•Note $100 $50 $20 $10, $5

New Currency 

Design

• Year 2003 2004 2006 2008 2013 

•Note $20 $50 $10 $5 $100 NexGen

•Year 2026 2028 2030 2032-35 2034-2038 

•Note $10 $50 $20 $5 $100 Catalyst 

Source: OIG analysis of BEP documentation 

The last note redesigned was the NexGen $100 note. Problems 

associated with the note’s design complexity, a security feature, 

and printability led to the note being released in 2013, though it 

was originally scheduled to be released during March 2008. The 

issues experienced with the NexGen $100 also resulted in a 10-year 

initiative including BEP and other ACD members to improve 

governance and oversight over note development and production.

12

Governance Over Design and Development 

Since the problems experienced with the NexGen $100 note, the 

governance and oversight over note design, development, and 

production has been strengthened. Figure 2 below displays the 

multi-agency governance over the USCP. Additional detail on these 

committees is provided in appendix 2. 

 

12 OIG previously reported out on these issues and oversight with BILL MANUFACTURING: Improved 

Planning and Production Oversight Over NexGen $100 Note Is Critical (OIG-12-038; issued 

January 24, 2012) and BILL AND COIN MANUFACTURING: BEP Improved Governance and Oversight 

over Note Development and Production But Challenges Remain (OIG-20-023; issued December 31,

2019). 
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Figure 2 – USCP Governance Structure Multi-Agency Groups 

 Source: OIG analysis of BEP documentation

Additionally, as part of the improvement in governance, 

comprehensive and documented processes over note development 

were implemented, including the BDP and the TDP. The BDP 

provides a unified, structured approach that is followed in the 

planning, developing, and testing to ensure new notes are 

production ready.13 Similarly, the TDP provides a structured process 

in which the research and development of technology projects, such 

as the development of security features, advance until the projects 

are thoroughly vetted and can be integrated into the BDP. The 

governance structure and processes developed for new notes focus 

on ensuring successful security feature development and integration 

after a lengthy technical development process. However, not all 

security features are expected or will be successful and integrated 

into the BDP. Appendix 2 provides additional detail on the BDP and 

TDP processes.

 

13 In addition to new note development, the BDP is also followed to address any changes which impact 

fit, form, and/or function of notes.
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Figure 1 above displays the schedule for the Catalyst $10 note, the 

first note to be redesigned, with a tentative production ready 

schedule for 2026. This schedule was developed in 2015. Also in 

2015, counterfeiting trends for the $50 NexGen note began steadily 

increasing. At the recommendation of the ACD, BEP began parallel 

development of the Catalyst $10 and $50 in August 2017 and the 

redesign sequence was subsequently revised and approved by the 

Secretary of the Treasury in 2018. In our 2019 audit report, we 

identified that BEP had begun the first note redesign using the BDP, 

that of the Catalyst $10 note.

14 During this audit, we learned that 

the security features for the $10 note had not been finalized. 

Audit Results 

Finding 1 BEP is Implementing Security Features and Meaningful 

Access for the Blind and Visually Impaired into New Note 

Designs, but Refinement of Guidance and Additional 

Schedule Detail Would Prove Beneficial

We found that BEP is implementing security features and 

incorporating meaningful access for the blind and visually impaired 

into the redesign of currency by following new structured processes

and governance.

15 However, opportunities exist to improve note 

development processes and provide stakeholders greater detail for 

planning. Specifically, BEP needs to (1) refine the procedures to be 

performed and to reflect lessons learned from the Catalyst family of 

notes design and; (2) improve its IMS by including additional details 

 

14 OIG-20-023 15 Following an August 2019 court injunction, the U.S. District Court for the District of Columbia agreed 

with BEP that a tactile feature for the blind and visually impaired and security features cannot be 

implemented independently of each other and must be developed in tandem. The court also found that 

BEP had been working in good faith on its currency redesign efforts in compliance with its legal 

requirements. Public Law 93-112, also known as the Rehabilitation Act of 1973, requires BEP to 

provide meaningful access for the blind and visually impaired. 12 U.S.C 418, Printing of notes; 

denomination and form, requires BEP to design currency to guard against counterfeiting. 
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to help identify issues that may impact the schedule of planned note 

redesign activities. 

Procedures for Processes in Feature and Note Design 

Development Should be Refined

In a recent audit of BEP, we reported that BEP had improved its 

processes over note development which included implementing TDP

and BDP.16 In past redesigns, BEP did not have a formal or 

documented process for developing technology features, designing 

new notes, or documenting stakeholder requirements. 

During our current audit, we found BEP is following the TDP and

BDP structured processes for note development which supports 

BEP’s ability to implement new security and raised tactile features in 

the next redesign of currency. We also found that there is a formal 

process that documented stakeholder requirements which included 

documenting security and meaningful access feature requirements. 

The documentation is to ensure stakeholders’ needs are 

communicated and addressed during the note development. Our 

review of the requirements document for the current note redesign 

found that BEP had identified over 300 requirements for the next 

note redesign of the Catalyst family of notes, of which 

approximately 30 percent were related to security and meaningful 

access features. 

Overall, BEP officials and other agency stakeholders we spoke with 

expressed no concerns with processes over security features and 

meaningful access development and felt the processes followed in 

the redesign were adequately working. However, as this is the first 

note redesign using these processes, updating the guidance over 

the processes will be needed to incorporate areas of improvement 

or clarification identified through BEP’s lessons learned process 

relating to the Catalyst family. Several BEP officials told us the BDP 

manual needs to be refined.

 

16 OIG-20-023 
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According to a Government Accountability Office (GAO) study on 

lessons-learned practices, a critical step in any lessons-learned 

process is the sharing and disseminating of the knowledge gained.17

This includes the revision of work processes or procedures, and 

training. We believe that updating TDP and BDP guidance by 

incorporating lessons learned will improve the effectiveness over 

and ensure the consistent use of BEP’s guidance over its future note 

redesign and development processes. 

BEP’s IMS Can be Improved to Better Inform DecisionMakers

In our 2019 audit, we also reported that BEP had developed an IMS. 

During this audit, we found that redesign activities related to the 

$10 and $50 note were displayed on the IMS. The BEP official 

responsible for the IMS told us that the IMS combines major project

milestones for security features development, note development, 

equipment scheduling, new facility construction, and engineering. 

However, we found that the IMS is still lacking detailed schedules

which identify risks and a more defined critical path.18 We noted 

that product managers have been using BDP as a detailed plan and 

activities schedule, but that these schedules have not been built 

into IMS. The lack of detailed milestones increases the risks of not 

timely identifying events that impact the schedule and key activities 

in the redesign effort. 

Also, the IMS should incorporate detail for technical and key 

activities and milestones for each redesign effort. Specifically, as of 

the time of our audit, the practice is that BEP’s IMS manager 

coordinates and updates the schedules for the various projects 

throughout the bureau and then subsequently presents these 

schedules at the ICC and ACD meetings. To create a more complete 

IMS, BEP program managers in charge of product development, 

security features, and production equipment should regularly provide 

 

17 GAO, Federal Real Property Security: Interagency Security Committee Should Implement a LessonsLearned Process (GAO-12-901; issued September 10, 2012) 18 GAO defines a program’s critical path as the longest duration through the sequence of activities in 

order to determine the program’s earliest completion date that will lead to the project’s success. The 

schedule’s risk analysis would be based on the critical path to predict the level of confidence in 

meeting a program’s completion date.
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the BEP IMS manager with more detailed schedules and milestones 

for incorporation into the IMS. 

Furthermore, we were told by some ACD members that they have 

not seen the critical path clearly presented and the IMS was not 

useful for informed decision making because it lacked details on 

critical dependencies and resources relating to testing and 

production of the new notes. One example given was that the 

Board’s Currency Technology Office (CTO) could run into a situation 

where it is unable to test notes on a specific machine because that 

machine was down for scheduled maintenance.

19 We were told that 

such detail, as equipment maintenance, would identify resource 

constraints and could be used to identify issues that may impact the 

schedule of planned note redesign activities. 

According to GAO’s Schedule Assessment Guide, an IMS should be 

a reliable schedule that reflects all activities and is defined in detail 

including the program’s critical path.20 GAO’s guide cautions that if 

the schedule is not planned in sufficient detail or collaboratively by 

team members and stakeholders, then opportunities for process 

improvement, such as identifying redundant activities, what-if 

analysis, and risk mitigation will be missed.

Recommendations

We recommend that the Director of BEP in collaboration, as 

necessary, with members of the USCP: 

1. Continue to improve the BDP and TDP guidance, including

refining procedures to reflect lessons learned during its 

Catalyst note series redesign. 

 

19 CTO supports the cash processing operations of the Federal Reserve Banks focusing on the 

automation of physical currency handling and processing equipment systems for high-speed 

automated authentication, fitness assessment, and the destruction of unfit notes. 20 GAO, GAO Schedule Assessment Guide: Best Practices for Project Schedules (GAO-16-89G; issued 

December 22, 2015) 
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Management Response 

Management agrees with our recommendation. Management 

stated that it has developed lessons learned in detail for the 

early phases of currency design, some of which are pre-BDP. 

Management also stated that it is constantly thinking about 

how to evolve BDP based on what it is finding. Management 

believes that the pilot will provide the most comprehensive 

lessons learned material for both the BDP and integration of 

security features; and that the pilot will identify modifications 

to consider for both the BDP and TDP. Also, during the 

execution of redesigns, improvement opportunities will be 

identified, which will be incorporated into the guidance and 

documentation.

OIG Comment

Management’s response and planned and taken actions meet 

the intent of our recommendation. Management will need to 

incorporate the estimated date for completing its planned 

corrective actions as well as the actual date of completed 

corrective actions in JAMES, Treasury’s audit 

recommendation tracking system.

2. Review and implement actions within the IMS program to 

improve the decision making process and help identify issues 

that may impact the schedule of planned note redesign 

activities. This includes ensuring that technical and key 

milestones are incorporated into the IMS at a detailed level. 

Management Response 

Management agrees with our recommendation. Management 

stated that it will revisit the requirements for the level of 

detail, frequency, and milestones to include in the IMS to 

improve the decision making process.
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OIG Comment

Management’s response and planned action meet the intent 

of our recommendation. Management will need to incorporate 

the estimated date for completing its planned corrective 

actions as well as the actual date of completed corrective 

action in JAMES, Treasury’s audit recommendation tracking 

system. 

Finding 2 ACD Governance Not Operating As Intended

We found that certain ACD members are not attending committee 

meetings as was intended by the ACD charter, which, in turn, could 

impact the effectiveness of the ACD. Full collaboration from all

multi-agency members is imperative to ensure that stakeholder 

leadership is kept sufficiently informed on note design. 

ACD Effectiveness Impacted 

The ACD charter requires its members to collaborate on 

developments related to new design and currency. This includes 

developing strategies and making recommendations to policy level 

decision makers at Treasury, Secret Service, and the Board, as well 

as reporting its combined findings and recommendations to the 

Secretary of the Treasury. To accomplish this, the ACD was 

designed to include members comprised of senior executives from 

Treasury’s Departmental Offices, BEP, Secret Service, and the 

Board. 

Additionally, while ACD meetings can be attended by other 

personnel from these agencies, the charter specifically identifies six 

voting members, which include the following positions:

• Treasury Under Secretary for Domestic Finance, 

• U.S. Treasurer, 

• BEP Director, 

• Board Deputy Director, 

• Board Product Director, and

• Secret Service Deputy Assistant Director.
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The charter also specifies that the Under Secretary for Domestic 

Finance is to chair the ACD. However, the charter allows for the 

members, with the exception of the U.S. Treasurer and BEP 

Director, to designate their roles.

From our discussion with ACD meeting participants as well as a

review of ACD meeting minutes, we found that there has been a 

lack of senior executive participation. One ACD member told us that 

this has resulted in ACD meetings evolving into status update 

meetings versus meetings in which decisions can be made. As we 

identified above, the ACD was designed to include executive 

members from multiple agencies which we believe was to ensure 

the committee had sufficient authority to make policy decisions for 

their respective agency and to keep their respective leadership 

informed on note design. In particular, we found the Treasury 

Departmental Offices’ senior executive participation in the ACD to 

be lacking over the past several years. 

We noted that the position of Under Secretary for Domestic Finance 

has been vacant since 2014; we also noted that the role of ACD 

chair had been filled by the Treasurer for several years prior. 

However, we found that the Treasurer had not been attending ACD 

meetings over the last several years. We were told by the Treasurer, 

who was appointed to this position in 2017, that her duties did not 

include overseeing BEP or serving on the ACD. The ACD charter has 

not been updated to include this information. The Treasurer 

departed from Treasury in January 2020. In the absence of the 

Under Secretary for Domestic Finance and the Treasurer, the BEP 

Director assumed the ACD chair role and briefs the Secretary of the 

Treasury on behalf of the ACD. 

Governance Charter and MOU Need to Be Updated

As discussed above, BEP and other ACD members went through a 

10-year initiative to improve governance and oversight over note 

development and production. This included both the restructuring of 

existing multi-agency governance and the creation of new multiagency committees. 
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Currently each committee operates under a charter that identifies 

the committees’ purpose as well as its members’ roles, 

responsibilities and the procedures that are to be followed in order 

to accomplish the committees’ purpose.

Our review found the charters for the ICC, PAC and TAC were 

updated during our audit to ensure alignment and relevance against 

current strategy and objectives. Although the ACD charter does not 

specify a timeline for updates or amendments, it has not been 

updated for 15 years.

21 As discussed above, the role of the 

Treasurer has changed. In addition, other roles of members initially 

assigned may have changed or positions may no longer exist, which 

necessitates a review and updating of the charter. Additionally, the 

MOU, which formalizes responsibilities and authorities between BEP 

and the Board, which is supposed to be reviewed every 5 years to 

ensure consistency with current practices has not been updated 

since 2011; however, we found that BEP was in the process of 

updating the MOU. 

We believe that it is a best practice of management to ensure 

governance charters and MOUs are reviewed and updated on a 

timely basis. Without updated charters and MOUs, the roles, 

responsibilities, and current practices may not be clearly defined, 

described, and communicated to members. 

Recommendation 

We recommend that the Director of BEP in collaboration, as 

necessary, with USCP members:

1. Ensure the ACD charter is updated in a timely manner, and as 

needed, to ensure roles, responsibilities, and current practices 

such as the attendance of ACD monthly meetings by 

appropriate personnel are clearly defined and communicated 

to its members.

 

21 The ICC, PAC and TAC charters are supposed to be updated every 3 years and were last updated in 

2019. 
Audit of Bureau of Engraving and Printing’s Implementation of Security 

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New Note Design (OIG-20-040) 

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Management Response 

Management agrees with our recommendation. Management 

stated that it will update the ACD charter, including clarifying 

the roles and responsibilities.

 

OIG Comment

Management’s response and planned action meet the intent 

of our recommendation. Management will need to incorporate 

the estimated date for completing its planned corrective 

action as well as the actual date of completed corrective 

actions in JAMES, Treasury’s audit recommendation tracking 

system.

Other Matter

Proposed 2020 Note Redesign Impacted By Security 

Feature Development 

As part of this audit and in response to Congressional concerns, we 

reviewed the circumstances surrounding Treasury’s timeline for

unveiling of new design concepts for the $20 note. We found that 

the former Secretary of the Treasury made an April 2016 

announcement proposing the release of the $5, $10 and $20 note 

designs in 2020. This announcement was made outside of the note 

development governance structure and without the recommendation 

of the ACD. 

We also found that, shortly thereafter in May 2016, the former 

Secretary of the Treasury reported to the U.S. District Court for the 

District of Columbia that the first note in the redesign effort, the 

$10 note, would be delayed from 2020 to 2026 in order to develop 

the necessary security features and incorporate a tactile feature. 

Additionally, we confirmed that the design concept for the $20 note 

will not be released in 2020, as this note has not yet entered the 

BDP where the design concept is finalized. Rather, the current plan 

is for the $20 note to be production-ready in 2030.

22

 

22 The Board has the overall decision authority to determine a note’s production-ready date and what 

date a note will be issued into circulation.
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To elaborate, as noted above, the primary reason for redesigning 

currency is security against counterfeiting, and multiple agencies are 

involved in the design and approval for new currency. The primary 

mechanism to protect currency is security features, which is the 

greatest factor in the timeline of note development. It takes time to 

develop security features and there is no guarantee the security 

feature will work until testing and design are complete. It can take 6 

to 10 years to bring a security feature to completion as there are 

multiple factors involved, including acquiring and implementing 

equipment needed to test the security features and production 

equipment to implement the new security feature into a note. 

Historically, only after security features were developed, was the 

design with its image finalized as placement of security features can 

radically affect the note design. The unveiling of the design typically 

occurs 6 months prior to issuance as part of the public information 

campaign. 

In June 2015, the former Secretary of the Treasury announced that 

the redesigned $10 note would feature a woman and was expected 

to be unveiled in 2020.

23 Additionally, while historically the 

Secretary of the Treasury had relied on BEP’s advice, input from the 

public would be relied upon to help guide the design for the next 

redesign of currency. 

In the months following the Secretary’s announcement, discussions 

about the next redesign with the Secretary and during ACD 

committee meetings focused on making it clear that the concepts 

under development were only concepts and would not be designs 

until the final stages of the BDP. The recommendation was made to 

not mention issuance dates or give any definitive timelines. BEP also 

communicated to the former Secretary of the Treasury that any 

images released to the public would not be viable options for future 

design consideration due to the security risk this would present.

 

23 The 2020 date was based on when BEP had previously anticipated releasing the first redesigned 

denomination containing a tactile feature stemming from the U.S. District Court ruling that the 

Secretary of the Treasury take such steps as may be required to provide meaningful access to 

currency for blind and other visually impaired persons. 
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In April 2016, following public input for new note design concepts, 

the former Secretary of the Treasury announced that BEP had been 

directed to accelerate plans for the redesign of the $5, $10 and $20 

notes and anticipated that the final concept designs would be 

unveiled in 2020. Additionally, the former Secretary of the Treasury

publicized, based on input from the public, the notes would be 

redesigned to include:

• historic events at the Lincoln Memorial on the $5 note; 

• Lucretia Mott, Sojourner Truth, Susan B. Anthony, Elizabeth 

Cady Stanton, and Alice Paul on the $10 note and; 

• Harriet Tubman’s portrait on the $20 note. 

However, ACD members told us that accelerating the redesign 

process and unveiling design concepts in 2020 was problematic and 

opposed by the ACD as it put a huge risk on the USCP. Specifically, 

the design concepts and unveiling schedule developed under the 

direction of the former Secretary of the Treasury were completely 

outside the note development governance structure and currency 

design expertise and without the recommendation of the ACD. In 

fact, the $20 note was not even being considered for redesign at 

that time by the ACD.24 With that said, it was questionable whether

the concepts proposed could even be manufactured since a 

significant amount of work was needed to complete the security 

features. 

Shortly after, in May 2016, the former Secretary of the Treasury 

submitted a supplemental status report to the U.S. District Court for

the District of Columbia in which the Secretary identified, among 

other things, that a significant amount of time was required to 

conduct research and development in order to develop the 

necessary security features for the next redesign of the currency, 

which would result in delaying the development and production of 

the next redesign beyond the anticipated 2020 date.

25 The first note

 

24 In March 2016, the planned sequence for redesign by denomination was the $10, $5, $20, $50 and 

$100. 25 A 2008 U.S. District Court Order of the District of Columbia and Judgement mandated that the 

Treasury provides status reports every six months on its meaningful access implementation into 

currency. 
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incorporating the security features, which was the $10 note, were 

expected to be production ready no later than 2026; however, this 

was subject to revision based mostly on security and technological 

advancement. 

As discussed above, BEP follows a structured process in developing 

security features where features are vetted by the TDP, and if 

successful, are advanced into the BDP and integrated into the 

note’s design. It is during the BDP process that a note’s concept 

design is finalized. During our audit, we found that only two

denominations are in the BDP process.

Our review found that since 2013, the $10 note is the first note in 

the redesign sequence. Since that time, the sequence of note 

redesign was changed once. In 2018, based upon a security threat 

assessment, the sequence was changed and the $5 note and the 

$50 note sequence were switched. Figure 1 above displays the

current sequence and schedule for the next redesign of notes. The 

$10 and the $50 notes were the only notes in the BDP during our 

audit and neither of the notes had its concept design finalized.

In response to Congressional concerns relating to the timeline for

unveiling the design concept of the $20 note in 2020, we found the 

sequence of the redesign of the $20 has remained the same since

2016 and the announcement of a 2020 release was not endorsed 

by the ACD. The $20 note has not yet entered the BDP where 

following the current note development process its design concept 

will be finalized. 
Audit of Bureau of Engraving and Printing’s Implementation of Security 

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* * * * * *

We appreciate the cooperation and courtesies extended to our staff 

during the audit. If you wish to discuss this report, you may contact 

me at (617) 223-8638 or Ken O’Loughlin, Audit Manager, at 

(617) 223-8624. Major contributors to this report are listed in 

appendix 4. A distribution list for this report is provided as 

appendix 5. 

/s/

Sharon Torosian

Director, Manufacturing and Revenue
Appendix 1: Objectives, Scope, and Methodology 

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The objective of our audit was to determine whether the Bureau of 

Engraving and Printing (BEP) is properly implementing security 

features into the currency as part of its counterfeit deterrence 

program and incorporating tactile features and high-contrast 

numerals in future currency designs to improve meaningful access 

for blind and visually impaired individuals in accordance with 

requirements approved by the Secretary of the Department of the 

Treasury (Treasury). The scope of our audit covered the time period 

from 2012 during which time the Banknote Development Process 

(BDP) was implemented through February 2020. 

To accomplish our objective, we performed the following activities 

during audit fieldwork from June 2019 through February 2020: 

• Conducted interviews with BEP personnel to gain an 

understanding of the processes over security features and 

meaningful access development and involvement in multiagency governance that includes the Advance Counterfeit 

Deterrence Steering Committee (ACD). This included BEP’s 

Director, and officials from its Product Design and 

Development Directorate, Office of Strategy and Project 

Management, Office of External Relations, and Office of 

Counsel. 

• External to BEP, we conducted interviews with stakeholders to

gain an understanding of their involvement with new note 

governance and development. This included officials from the 

Board of Governors of the Federal Reserve System (Board) 

Division of Reserve Bank Operations and Payment Systems as 

well as its Currency Technology Office. We also interviewed 

representatives from the United States Secret Service. 

• Reviewed applicable laws and regulations pertaining to future 

currency designs.

• Reviewed applicable documentation from BEP that included:

o Memorandum of Understanding between BEP and the 

Board; 

o Multi-agency governance committee charters; 
Appendix 1: Objectives, Scope, and Methodology 

Audit of Bureau of Engraving and Printing’s Implementation of Security 

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o Standard operating procedures pertaining to the Banknote 

Development Process (BDP) and Technology Development 

Process (TDP); 

o Meeting minutes and presentations of the ACD and 

Interagency Currency Committee for calendar years 2012 

through 2019; 

o Integrated Master Schedules for February 2018, March 

2019, July 2019, and November 2019; and 

o Other security feature development reports in 2018 and 

2019 and meaningful access development reports

submitted on behalf of the Secretary of the Treasury to 

the U.S. District Court for the District of Columbia from

2015 through 2019. 

• Reviewed various Secretary of the Treasury announcements 

and press releases.

We conducted this performance audit in accordance with 

generally accepted government auditing standards. Those 

standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for 

our findings and conclusions based on our audit objectives. 
Appendix 2: Additional Background

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United States Currency Program 

The United States Currency Program (USCP) is comprised of the 

senior executives from Treasury Departmental Offices, Bureau of 

Engraving and Printing (BEP), Board of Governors of the Federal 

Reserve System (Board), United States Secret Service (Secret 

Service), and Board Currency Technology Office (CTO) and is 

responsible for overseeing currency redesign and production. The 

programs used for redesign include the Technology Development 

Process (TDP) to develop security features and the Banknote 

Development Process (BDP) to integrate security features in a note 

design that is fully-developed and tested before issued to the 

public.

Figure 1: USCP Governance Groups

Entity Roles and Responsibilities Members

Advanced 

Counterfeit 

Deterrence 

Steering 

Committee 

(ACD)

• Federal multi-agency group established in 1982 by 

the U.S. Department of the Treasury (Treasury) to

coordinate the counterfeit deterrence activities. 

• Develops and monitors plans for the redesign of 

Federal Reserve notes (notes) and makes redesign 

recommendations to the Secretary of the Treasury 

to safeguard the notes against counterfeiters. 

• All lower committees and working groups report up 

to the ACD for approval and recommendations.

Treasury 

Departmental 

Offices, 

BEP, Board, 

Secret Service,

and CTO

Interagency 

Currency 

Committee 

(ICC)

• Operates under the authority and in support of the 

ACD by providing executive oversight of the lower 

committees that oversee new note development and 

new technological feature projects. 

• Monitors counterfeit threats and recommends design 

changes to the ACD. 

• Decisions of the group are made by consensus. In 

the event that no consensus is reached, viewpoints 

are presented to the ACD for final decision.

BEP, 

Board, 

Secret Service,

and CTO 

Program 

Approval 

Committee 

(PAC)

• Oversees note development projects and ensures 

they follow the prescribed BDP manual. 

• Monitors and reviews project status and ensures 

that business objectives and requirements are met

by serving as the gatekeeper between BDP phases. 

BEP, Board, 

Secret 

Service, 

and CTO 
Appendix 2: Additional Background

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• Under the direction of the ICC, provides guidance 

and decisions to product and project managers on 

BDP Core Teams for new note development 

Projects. 

Technology 

Approval 

Committee 

(TAC)

• Oversees and guides the execution of activities 

implemented by the ICC to develop new and 

innovative technological features. 

• Monitors and reviews project status and ensures 

that business objectives and requirements are met

by serving as gatekeeper throughout the TDP.

• Provides guidance to the Technology Review Group 

(TRG) and other working groups to ensure ICC

directives are met. 

BEP, Board, 

Secret Service, 

and CTO 

BDP Core

Team

• In support of the PAC, cross-functional teams that 

execute note development projects through the BDP 

phases. 

• Prepares for phase-end reviews, oversees extended 

teams, and communicates issues to the PAC on a 

monthly basis. 

BEP, Board, 

Secret Service, 

and CTO 

Technology 

Review Group 

(TRG)

• In support of the TAC, provides technical review 

and recommendations for projects and technology 

development efforts.

• Not a decision-making group, but informs the TAC 

that advancement to the next phase of the TDP is 

warranted.

BEP, Board, 

Secret Service, 

and CTO 

Source: OIG analysis of BEP documentation. 

Technology Development Process (TDP) 

Implemented in 2013, TDP is a research and development process 

used to develop innovative note features for new currency 

technology and security needs. It is a multi-phased process that 

subjects each feature to testing and approval. Features that meet 

the demands of this process are integrated into the new note’s 

design and into the BDP phases that subject it to final production 

testing. The process is governed by TAC that manages projects to 

develop technologies for input to the BPD. 
Appendix 2: Additional Background

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Banknote Development Process (BDP)

BEP implemented the BDP in 2012 to be used as a multi-step 

process with phases to integrate new security features, build 

design concepts, receive input from stakeholders, obtain 

interagency approval, and test the product in a production setting. 

The manual provides guidance and criterion to move projects to the 

next step, and allows for a unified, standard approach to plan and 

execute banknote development change initiatives which impact fit, 

form, and/or function of US banknotes. The process is governed by 

the cross-organizational PAC that manages projects to produce a 

fully developed and production-ready banknote.

Meaningful Access 

BEP is involved in an ongoing effort to comply with a 2008 U.S. 

District Court for the District of Columbia ruling that U.S. banknote 

design violates Section 504 of the Rehabilitation Act because 

individuals with visual impairments lack a means to denominate 

currency.26 The court order requires that Treasury provide 

meaningful access for the blind and visually impaired in its next 

banknote family redesign, but does not specify steps or methods 

required to provide such access to U.S. currency. 

Following the ruling, in 2009, BEP’s consultant performed a study 

of meaningful access options, and found that no one method could 

fill the need for the entire blind and visually impaired community. 

Hence in 2011, the Secretary of the Treasury approved a threepronged approach to allow for individuals with visual impairments 

to denominate currency, as follows:

1. Raised, tactile feature 

• Expected to provide users with a means of identifying each 

banknote denomination via touch. The tactile feature that 

has been chosen will be a raised hollow rectangle. 

 

26 Public Law 93-112, also known as the Rehabilitation Act of 1973, requires BEP to provide meaningful 

access for the blind and visually impaired.
Appendix 2: Additional Background

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2. High contrast numerals 

• Provides users large high contrast numerals and different 

colors to each denomination that it is permitted by law to 

alter. This method was previously implemented in the

redesign beginning in 1997, and will continue to be 

incorporated into future redesigns. 

3. Currency Reader Program

• Provides a banknote-reading device (“iBill”) to all eligible U.S. 

citizens and national residents. The device is free-of-charge 

and was launched in 2014.

• BEP developed banknote reader applications for iPhone 

(EyeNote) and Android users (IDEAL Currency Identifier) 

which use text-to-speech technology to denominate U.S. 

currency. 
Appendix 3: Management Response 

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Appendix 3: Management Response 

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Appendix 4: Major Contributors to This Report

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Kenneth O’Loughlin, Audit Manager

Kiira Jones, Auditor-In-Charge

James Shepard, Auditor

Timothy Cargill, Auditor

Hillary Hopper, Referencer

John Tomasetti, Referencer
Appendix 5: Report Distribution 

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Department of the Treasury 

Secretary

Deputy Secretary 

Office of Strategic Planning and Performance Improvement

Office of the Deputy Chief Financial Officer, Risk and Control 

Group

Bureau of Engraving and Printing

Director

Office of Inspector General Audit Liaison 

Office of Management and Budget

OIG Budget Examiner

Board of Governors of the Federal Reserve System

Inspector General

Director, Division of Reserve Bank Operations and Payment 

Systems

Department of Homeland Security

Inspector General

Director, United States Secret Service

U.S. Senate

Chairman and Ranking Member

Committee on Banking, Housing, and Urban Affairs

U.S. House of Representatives

Chairman and Ranking Member

Committee on Financial Services

Chairman and Ranking Member

Subcommittee on Monetary Policy and Trade
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