Department of Homeland Security 

Office of Inspector General 

Management and Oversight of 


Immigration and Customs Enforcement 


Office of International Affairs Internal Controls for 


Acquisitions and Employee Integrity Processes
 

OIG-10-38 January 2010 
 

Office of Inspector General 

U.S. Department of Homeland Security

Washington, DC 20528 

 January 25, 2010 

Preface 

The Department of Homeland Security (DHS) Office of Inspector General (OIG) was 

established by the Homeland Security Act of 2002 (Public Law 107-296) by amendment 

to the Inspector General Act of 1978. This is one of a series of audit, inspection, and 

special reports prepared as part of our oversight responsibilities to promote economy, 

efficiency, and effectiveness within the department. 

This report addresses the strengths and weaknesses of Immigration and Customs 

Enforcement Office of International Affairs internal controls for acquisitions and 

employee integrity processes. It is based on interviews with employees and officials of 

relevant agencies and institutions, direct observations, and a review of applicable 

documents. 

The recommendations herein have been developed to the best knowledge available to our 

office, and have been discussed in draft with those responsible for implementation. We 

trust this report will result in more effective, efficient, and economical operations. We 

express our appreciation to all of those who contributed to the preparation of this report. 

Richard L. Skinner 


Inspector General 

Table of Contents/Abbreviations 

Executive Summary.............................................................................................................1
 

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

Results of Review ................................................................................................................8
 

Improvements Have Been Made; Vulnerabilities Remain in Overseas Procurement ...8 


Recommendations........................................................................................................11 


Management Comments and OIG Analysis ................................................................12 


ICE OIA Needs to Improve Oversight of Field Offices ..............................................12 


Recommendations........................................................................................................17 


Management Comments and OIG Analysis ................................................................17 


ICE OIA Needs to Ensure Compliance With Foreign Tour of Duty Policy................18 


Recommendations........................................................................................................20 


Management Comments and OIG Analysis ................................................................20 


Appendices 

Appendix A: Purpose, Scope, and Methodology.......................................................21 


Appendix B: Management Comments to the Draft Report.......................................22 


Appendix C: ICE Assistant Secretary Memorandum to DHS Deputy Secretary......25 


Appendix D: Major Contributors to This Report ......................................................31 


Appendix E: Report Distribution ..............................................................................32 


Abbreviations 

DHS Department of Homeland Security 

DOS Department of State 

DOSAR Department of State Acquisition Regulation 

FAR Federal Acquisition Regulation 

FMC Financial Management Center 

FY Fiscal Year 

GAO Government Accountability Office 

GSO General Services Office 

ICE Immigration and Customs Enforcement 

ICECAPS Immigration and Customs Enforcement Contract and Acquisition Procedures 

IT Information Technology 

OAQ Office of Acquisition Management, Immigration and Customs Enforcement 

OIA Office of International Affairs, Immigration and Customs Enforcement 

OIG Office of Inspector General 

OPR Office of Professional Responsibility, Immigration and Customs Enforcement 

SIP Self Inspection Program 
OIG
 

Department of Homeland Security 

Office of Inspector General 

Executive Summary 

The criminal investigation of a senior U.S. Immigration and 

Customs Enforcement Office of International Affairs official 

identified potential vulnerabilities in a number of internal controls. 

Internal controls are vital in managing an organization and helping 

prevent fraud, waste, and abuse. We reviewed what management 

review and oversight is performed to ensure that employees 

understand and are following applicable procurement policies and 

procedures. We assessed the effectiveness of internal controls to 

prevent or detect the unauthorized acquisition, use, or disposition of 

assets. We also reviewed whether policies and procedures are tested 

periodically to ensure that internal controls are working as intended. 

Immigration and Customs Enforcement has made improvements to 

its policies, procedures, and internal controls. Specifically, 

acquisition procedures for both armored and non-armored vehicles 

for overseas offices have been improved. In addition, a policy 

change regarding the use of liaison expenditure funds requires 

additional documentation and prior headquarters approval for the 

use of specific levels of funds. 

However, Immigration and Customs Enforcement needs additional 

controls to address remaining vulnerabilities. We are 

recommending that Immigration and Customs Enforcement develop 

and implement control measures over acquisitions abroad, as well as 

a plan to oversee acquisition activities. In addition, we are 

recommending that Immigration and Customs Enforcement provide 

additional guidance to staff overseas to ensure that they understand 

their roles and responsibilities in managing property. Finally, we 

are recommending that Immigration and Customs Enforcement 

establish procedures to track compliance with the foreign tour of 

duty policy. 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

Page 1 
Background 

The criminal investigation of a senior U.S. Immigration and 

Customs Enforcement (ICE) Office of International Affairs (OIA) 

supervisory official identified potential vulnerabilities in a number 

of ICE OIA internal controls. Specifically, the investigation 

identified potential vulnerabilities in acquisitions processes and 

human resources policies. These vulnerabilities enabled the senior 

ICE OIA official to be involved in, and achieve personal gain 

from, several fraudulent activities. The senior official 

subsequently pled guilty and was convicted of the charges against 

him. When ICE learned of the senior official’s activities, they 

conducted a review of policies, procedures, and existing internal 

controls and implemented changes to prevent other ICE employees 

from taking advantage of the vulnerabilities. 

ICE Office of International Affairs 

ICE OIA has 54 offices in U.S. embassies and consulates in 42 

countries. ICE personnel overseas coordinate investigations with 

foreign law enforcement counterparts and acquire and develop 

intelligence related to cross-border criminal activities involving 

people, goods, and technology. In addition, ICE personnel provide 

investigative case support to domestic and international ICE 

offices, refer requests from host country agencies to ICE domestic 

investigative offices, and assist in removal operations by 

coordinating ICE efforts to transport removed aliens to their 

countries of origin. An ICE attaché or assistant attaché directs 

each overseas office. 

ICE OIA headquarters is organized into three divisions. 

International Operations works to identify, disrupt, and dismantle 

transnational criminal organizations; provides oversight for ICE 

investigations conducted abroad; and coordinates and supports 

domestic investigations within ICE and with DHS and foreign 

counterparts. 

ICE OIA Mission Support provides administrative guidance and 

financial support to ICE OIA operations and investigations. The 

division’s responsibilities include hiring and recruiting; time and 

attendance; personnel management; relocations and rotations; 

managing budget formulations and accounts, financial resources, 

and analysis; contracting and procurement; property and inventory; 

fleet management; travel administration; and developing document 

retention and records management practices. 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

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The International Programs division manages ICE OIA’s 

international programs and policy, including ICE involvement in 

multilateral organizations; coordination of international training 

and assistance; liaison with external agencies, such as Interpol or 

the Department of State (DOS); and the Visa Security Program. 

ICE Office of International Affairs Internal Controls 

In a September 2007 memorandum, after learning of the senior 

official’s criminal activities, the ICE Assistant Secretary informed 

the DHS Deputy Secretary of ICE OIA’s current and planned 

actions to ensure that all ICE OIA employees understand and 

follow the procedures related to acquisitions, human resources, 

ethics, and integrity awareness, and ensure that ICE OIA 

management monitors those activities.1

 According to the 

memorandum, ICE OIA constantly evaluates its policies, 

procedures, and guidance to provide oversight of ICE OIA 

employees. Until new policies and procedures are developed, ICE 

OIA continues to use preexisting policies from legacy agencies and 

interim guidance. 

Overseas offices receive acquisition support from DOS personnel 

who are responsible for executing procurement contracts in 

accordance with federal and DOS regulations, policies, and 

procedures. ICE OIA receives a report from DOS of all 

contractual actions executed on behalf of ICE. According to the 

September 2007 memorandum, the ICE Office of Acquisition 

Management (OAQ) will review the reports and randomly sample 

transactions to ensure that ICE OIA offices maintain proper 

supporting documentation, including justification for the use of 

noncompetitive procedures. As an additional internal control, 

attaché offices must submit written requests through their 

headquarters operations manager to fund items not included in 

their current budget. After reviewing the request for completeness, 

accuracy, and justification, the desk officer forwards the request to 

the appropriate management level for approval based on the 

amount of the request. All requests exceeding $25,000 require the 

ICE OIA director’s approval. 

ICE Office of Professional Responsibility (OPR) and Employee 

Labor Relations vets individuals selected for ICE OIA overseas 

positions. Individuals must pass a background investigation to 

determine their suitability for employment and before being 

granted a security clearance. Prior to deployment, individuals 

1

 See appendix C for a copy of the memorandum. 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

Page 3 
attend orientation training at ICE OIA headquarters, which 

addresses mission-oriented programs and processes. 

According to the memorandum, ICE OIA ensures compliance with 

integrity expectations through formal policies, training, oversight, 

and an office self-inspection process. In addition to predeployment 

training, employees receive additional training when they arrive at 

their overseas assignment. All ICE OIA employees also 

participate in annual mandatory training through ICE’s Virtual 

University. That training includes integrity, computer security, 

and prevention of sexual harassment. In addition, general ethics 

training has been incorporated into the curriculum at regional 

attaché conferences. 

Self Inspection Program 

The Self Inspection Program (SIP) is designed to build 

management accountability and foster professional integrity by 

evaluating offices on core areas that are susceptible to corruption, 

vulnerability, or are critical to mission performance. The overall 

ICE-wide management of the SIP is the responsibility of the OPR 

Management Inspection Unit. Because ICE OIA was part of the 

ICE Office of Investigations until February 2007, all ICE OIA 

offices completed the ICE Office of Investigations SIP annually 

prior to 2007. In February 2007, ICE OIA began working with 

OPR to create an OIA-specific self-inspection program to address 

the unique characteristics of the international environment. 

During self-inspections, each ICE office reviews its practices in 

specific areas using worksheets designed by ICE OPR. The 

worksheets cover universal core areas that apply to all ICE 

components plus areas unique to one or more, but not all, ICE 

components, such as ICE OIA. For example, both ICE OIA and 

the Office of Investigations would inspect their case management 

practices, but this area would not be applicable for Detention and 

Removal Operations. ICE OPR notifies component offices that 

they must complete a self-inspection of their office within a 

specified period. During the designated period, each office in that 

component retrieves the worksheets from OPR and completes a 

self-inspection. The principal officer for each office—the attaché 

for ICE OIA offices abroad—then certifies the self-inspection 

results and submits a certification memorandum and audit trail 

documentation to ICE OPR. Offices are required to maintain the 

records of the self-inspection for three fiscal years following 

completion. 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

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ICE OPR oversees the content of the SIP and adds or removes 

areas and activities as appropriate for future years. For the initial 

OIA-specific SIP conducted in April 2009, the universal areas 

were management responsibilities, travel administration, purchase 

card, asset management, and information technology (IT) security. 

Examples of specific activities reviewed in these areas included 

whether travel authorizations and vouchers were filed timely and 

whether employees have completed mandatory training classes. 

The additional areas included specifically for ICE OIA included 

case management, confidential informants, financial 

responsibilities, and firearms program. Examples of specific 

activities reviewed in these areas included whether investigative 

cases were opened and initial case reports were filed timely and 

whether liaison expenditures were appropriately documented. 

In addition to the SIP, both OPR and ICE OIA management 

conduct field inspections of a sample of attaché offices. OPR’s 

Management Inspection Unit tries to conduct full field inspections 

of each ICE office, including overseas offices, every four years. 

During its field inspections, OPR performs an in-depth review of 

the office’s operations and records, including a review of the 

office’s SIP results and verification of their accuracy. Upon 

completion of the field inspection, OPR issues a report identifying 

any deficiencies and makes recommendations as appropriate. The 

office then has 45 days to create a corrective action plan to address 

any deficiencies. OPR tracks deficiencies in a database for both 

self-inspections and field inspections. 

ICE OIA management bases its field inspections of attaché offices 

on the SIP. However, according to a senior ICE OIA official, ICE 

OIA concentrates more on management responsibilities while OPR 

concentrates more on the other SIP areas. The OIA inspection 

team reviews and verifies the office’s SIP worksheets and 

documentation during its field inspection. ICE OIA committed to 

conducting field inspections of a selection of attaché offices each 

year. In fiscal year (FY) 2008, ICE OIA conducted inspections at 

11 overseas offices. ICE OIA management is still determining 

how and when offices will be selected for field inspections, but 

plans to inspect each attaché office every four years. 

Internal Control Requirements 

Implementing appropriate internal controls is vital to achieving an 

agency’s mission and goals and helping prevent fraud, waste, and 

abuse. Internal controls include the organization, plans, policies, 

and procedures established to meet an agency’s mission, goals, and 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

Page 5 
objectives. The Federal Managers Financial Integrity Act of 1982 

requires each executive agency head to establish internal controls 

that reasonably ensure effective and efficient government 

operations, reliable financial reporting, and compliance with 

applicable laws and regulations.2 Office of Management and 

Budget Circular A-123 provides internal control standards and 

guidance for executive agency managers regarding developing, 

assessing, correcting, and reporting on internal control.3 The 

circular also describes management’s responsibility for developing 

and maintaining internal controls that meet the Act’s objectives. 

According to the U.S. Government Accountability Office (GAO), 

internal controls serve as the first line of defense in safeguarding 

assets and preventing and detecting errors and fraud. Internal 

controls provide reasonable, although not absolute, assurance of 

the prevention or prompt detection of the unauthorized acquisition, 

use, or disposition of funds, property, and other assets. Federal 

program managers set the objectives, establish control processes, 

monitor, and evaluate the controls. 

The following five standards for internal controls outline the 

minimum level of quality acceptable for internal controls in the 

federal government: 

� control environment, 

� risk assessment, 

� control activities, 

� information and communications, and 

� monitoring. 

The control environment provides the foundation for all the other 

standards. A positive control environment encompasses many 

factors, including senior management establishing and promoting 

values and guidance for integrity, ethics, and proper behavior, as 

well as appropriately disciplining staff when necessary. Other 

factors affecting a positive control environment include the 

agency’s organizational structure and clear definitions and 

delegation of authorities and responsibilities. 

An agency’s control activities help ensure that risks are addressed. 

They include policies and procedures that cover the following: 

� physical control of vulnerable assets, 

2 31 USC 3512(c)(1) 


3 OMB Circular No. A-123, Revised, December 21, 2004. 


Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

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�	 segregation of duties, 

�	 authorization and implementation of transactions involving 

agency resources by authorized staff, and 

�	 creation and maintenance of records and documentation 

demonstrating proper implementation of these activities. 

ICE OIA Overseas Procurement 

ICE OIA offices located outside the United States must follow the 

same requirements and regulations pertaining to acquisitions that 

ICE domestic offices and other federal executive agencies must 

follow when acquiring goods and services. The Federal 

Acquisition Regulation (FAR) governs federal acquisitions of 

goods and services using appropriated funds. To facilitate 

compliance with the FAR by all ICE offices, ICE OAQ established 

ICE Contracts and Acquisition Procedures (ICECAPS), which 

specify required steps to be followed throughout the acquisitions 

process. Because DOS provides on-site acquisition support for 

foreign ICE offices, ICE overseas procurements also must adhere 

to DOS acquisitions regulations and requirements. 

DOS supports ICE OIA overseas procurements through the 

General Services Office (GSO) and Financial Management Center 

(FMC) at U.S. embassies and consulates. GSO contracting officers 

are the federal government’s authorized agents for soliciting offers 

and for negotiating, awarding, modifying, and terminating 

contracts at U.S. posts abroad. GSO’s procurement and 

shipping/receiving staff also support the acquisition process. FMC 

personnel obtain funding and account information from the ICE 

attaché office and execute payment to vendors. 

ICE OIA begins the acquisitions process by submitting an attachéapproved procurement request to GSO. GSO searches for vendors, 

obtains price information, gets quotes as required by federal 

regulations, and collaborates with ICE OIA to ensure the 

requirements are met. Once a vendor is selected, GSO creates a 

purchase order and sends it to ICE OIA for approval. ICE OIA 

reviews the purchase order, which the attaché signs if approved, 

and ensures funds availability. GSO then works with the vendor to 

complete the purchase. Once received, either ICE OIA or the GSO 

Receiving Office confirms receipt of the good or service, and then 

GSO sends the invoice to FMC for payment. Typically, FMC staff 

review the contract, purchase order, and vendor invoice to verify 

that the information is correct and execute payment. Although the 

procurement process varies at each overseas post, figure 1 below 

illustrates the general acquisitions process for ICE attaché offices. 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

Page 7 
Determines that 

goods or services 

are required 

Submits signed 

Purchase Request 

Ensures adequate 

funding available 

for purchase 

Attaché signs 

purchase order to 

approve payment 

Receives good 

or service 

Solicits offers to find 

vendors and obtain 

price quotes 

Selects vendor and 

creates purchase order 

Procurement agent 

contacts vendor, 

completes order, 

and makes purchase 

Vendor sends purchase 

to GSO Receiving Office 

or directly to ICE OIA 

Executes payment 

after receipt of item 

and invoice 

Overseas Acquisitions Process 

ICE OIA DOS GSO DOS FMC 

Figure 1. ICE OIA Overseas Acquisitions Process 

Results of Review 

Improvements Have Been Made; Vulnerabilities Remain in 

Overseas Procurement 

ICE OIA implemented several policy, procedural, and organizational 

changes to improve its internal controls and reduce the chance that an 

employee could improperly acquire, use, or dispose of assets. However, 

vulnerabilities remain in the overseas procurement process. 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

Page 8 
ICE OIA Changes Reduced Some Internal Controls 

Vulnerabilities 

In November 2007, ICE OIA reorganized the structure of its field 

office divisions. Prior to November 2007, ICE OIA attaché offices 

were divided into three geographic areas—Americas; Europe, 

Africa, and the Middle East; and Asia and the Pacific. In 

November 2007, ICE OIA split the Americas division into two 

areas—North America and Central/South America—creating four 

overall operational areas. An operations chief directs each area. 

By splitting the Americas area into two separate areas, the 

respective operations chiefs can provide better oversight over 

attaché activities. 

Vehicle Acquisitions for Field Offices 

Prior to FY 2008, individual attaché offices completed the 

procurement process for all vehicles overseas. After learning that 

a senior ICE OIA official at one post was able to steer $2.8 million 

in sole source U.S. government contracts to a foreign company for 

purchasing and armoring vehicles, ICE OIA implemented changes 

to its vehicle acquisition process. Specifically, ICE OIA 

headquarters now conducts the acquisition of armored vehicles for 

all overseas offices and sole source purchases are not allowed. All 

armored vehicles must now be purchased and armored in the 

United States and then shipped to the foreign post. 

Individual attaché offices continue to execute nonarmored vehicle 

purchases; however, those purchases must be made through the 

DOS acquisition process at the embassy. All vehicle purchases 

must be competitively bid. In addition, ICE OIA headquarters 

must send a procurement cable and a funding cable directly to the 

post approving the purchase and certifying funds availability. 

Liaison Expenditures 

In September 2008, ICE OIA issued interim guidance to attaché 

offices regarding funding for liaison expenditures. ICE 

representatives use liaison funds to host meals or other social 

functions for building relationships with law enforcement 

counterparts in the foreign government. The guidance requires 

prior ICE OIA headquarters approval of liaison expenditures above 

$500, and requires ICE representatives to deduct the cost of his or 

her meal and beverage—up to $15 each—from the requested 

reimbursement. The guidance also requires the ICE representative 

to draft an internal memorandum documenting the meeting, 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

Page 9 
including the purpose, related case, list of attendees, expenditure 

amount, and the deduction for ICE representatives in attendance. 

The September 2008 guidance ensures that the appropriate level of 

ICE OIA management knows about significant activities with 

foreign liaisons. 

Additional Controls Needed to Address Remaining 

Vulnerabilities 

While ICE OIA did improve its overseas control environment, 

vulnerabilities remain in ICE OIA’s acquisitions process. Because 

ICE OIA relies on DOS to complete most of the acquisitions 

process overseas, ICE OIA must ensure that proper controls exist 

for the areas under its control. 

Overseas, the ICE attaché is the senior approving official and is 

responsible for purchase activities at posts. All procurement 

requests and resulting purchase orders require a signature 

authorizing the purchase. While DOS should process only signed 

purchase requests, DOS is not responsible for verifying whether 

attachés have properly authorized ICE purchase requests. ICE is 

solely responsible for ensuring that attachés, or staff to whom they 

have delegated their authority, are properly approving purchases. 

The ICE attaché’s review and approval provides a control for 

authorizing ICE funds at posts overseas. If the attaché is not 

reviewing and signing all procurement requests and purchase 

orders, ICE acquisitions are vulnerable to fraud, waste, or abuse. 

Conditions in some overseas offices showed vulnerabilities in ICE 

OIA acquisitions practices. At one post, when the attaché was out 

of the office, staff used a stamp of the attaché’s signature to sign 

procurement requests and purchase orders. While this practice 

occurs infrequently under the current attaché, all office staff know 

the location of and have access to the unsecured signature stamp. 

A senior ICE OIA headquarters official said that the use of 

signature stamps is not allowed; however, there is no written 

policy to support that prohibition. Without this guidance, there is 

no control over the use of signature stamps at ICE OIA offices 

overseas, thus creating an opportunity for forged approval 

signatures on procurement documents. 

In addition, our review of procurement documents at one post 

showed that on several occasions a former attaché and a former 

mission support specialist had been able to sign approvals for selfreimbursements through electronic fund transfers. Opportunities 

for misuse and abuse increase when one person controls all 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

Page 10 
significant phases of the acquisition process. This breaks down the 

separation of duties that is necessary to maintain effective controls 

over ICE purchases. Having different people approve, make, 

receive, and certify payment for a purchase limits opportunity for 

abuse. 

Because it is not DOS’ responsibility, ICE must ensure that 

purchases are authorized and signed properly prior to submission 

to DOS. At three posts we visited, several procurement requests or 

purchase orders were submitted to and processed by DOS without 

the attaché signature. At other posts, DOS was more stringent in 

verifying the signature of the attaché and recognizing the proper 

authorities’ signatures. At two posts we visited, DOS officials said 

that documentation outlining proper ICE signatory authorities 

would be beneficial. However, ICE is not required to provide 

DOS verification of proper ICE attaché or designee signatures. 

Absence of this documentation impedes ICE OIA headquarters 

from conducting effective oversight. 

Vulnerabilities in the acquisitions process exist because control 

measures have not been established for ICE OIA overseas offices. 

According to GAO, a sound control environment requires that an 

agency clearly define key areas of authority and responsibility. 

The control environment also is affected by the manner in which 

these key areas are delegated throughout the environment. 

Delegation covers authority and responsibility for operating 

activities, as well as authorization practices. 

Developing control measures for ICE OIA acquisitions operating 

activities at its foreign posts and providing guidance on 

authorization practices, signatory authority, and appropriate 

documentation of procurement transactions promote a positive 

control environment overseas. These measures also promote 

accountability over the purchase of supplies and services overseas 

and ensure vulnerabilities are minimized. 

Recommendations 

We recommend that the Assistant Secretary for U.S. Immigration 

and Customs Enforcement: 

Recommendation #1: Develop and implement control measures 

to ensure acquisitions by overseas ICE offices are appropriately 

approved and documented. 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

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Management Comments and OIG Analysis 

ICE provided written comments on our draft report. We evaluated 

these comments and have made changes to the report where we 

deemed appropriate. Below is a summary of the ICE response to 

the report’s first recommendation and our analysis. A copy of the 

ICE response, in its entirety, is included as Appendix B. 

Management Comments to Recommendation #1 

ICE concurred with the recommendation. In its response, ICE 

indicated that ICE OIA has taken steps to increase internal controls 

over its acquisitions. New controls include a system of automated 

funds control, a mandate that overseas purchases above the micropurchase authority be approved by ICE OIA headquarters, a 

coordination mechanism for international training, and more robust 

review and approval requirements for liaison expenditures. ICE 

OIA will also prohibit the use of signature stamps and selfreimbursements, and will work with DOS to validate attaché 

signatures. 

OIG Analysis 

This recommendation is resolved and open pending receipt and 

review of documentation of the new controls. 

ICE OIA Needs to Improve Oversight of Field Offices 

Headquarters Can Improve Acquisitions Oversight 

The Assistant Secretary’s September 2007 memorandum described 

a process to oversee whether ICE OIA acquisitions follow federal 

regulations. ICE OAQ reviews a sample of acquisitions that 

exceed the threshold amount of $2,500 to ensure compliance with 

federal regulations on competition. After receiving a list of 

qualifying acquisitions from ICE OIA, OAQ randomly audits two 

purchases per quarter to verify that proper acquisitions processes 

prescribed in the FAR, Department of State Acquisition Regulation 

(DOSAR), and ICECAPS were followed. OAQ obtains all 

supporting documentation for post purchases through headquarters; 

it does not communicate directly with the foreign posts. Should 

any problems arise, OAQ works with ICE OIA headquarters to 

obtain additional supporting documentation. Figure 2 illustrates 

this process. In response to OAQ’s first audit of ICE OIA 

acquisitions overseas, ICE OIA is beginning to liaise with the DOS 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

Page 12 
Procurement Office. This is a positive step in aiding OAQ audits 

of future ICE OIA purchases. 

Headquarters Oversight over ICE OIA Overseas Acquisitions ICE OIA Overseas Offices 

Retains 

procurement 

documentation; 

Reports purchases 

exceeding $2500 

Collects 

supporting 

documentation 

for requested 

purchase 

Submits list 

of purchases 

exceeding $2500 

for review 

Requests 

purchase 

documentation 

from ICE OIA 

overseas offices 

Randomly selects 

2 ICE OIA overseas 

office purchases 

exceeding $2500 

for review each 

quarter 

Submits request 

for supporting 

documentation 

for selected 

purchases 

Receives 

documentation; 

forwards 

for review 

Reviews 

documentation 

for compliance 

with regulations 

Forwards 

Documentation 

ICE OIA

Headquarters 

ICE Office of Acquisition

Management 

Figure 2. ICE Review Process for Overseas Acquisitions 

According to an OAQ procurement analyst, OAQ does not receive 

a report from DOS and does not have independent knowledge of 

the total volume of ICE OIA acquisitions that exceed $2,500 for 

the year. The analyst does not have independent access to identify 

ICE OIA purchases greater than this amount and reviews only 

qualifying procurements sent to OAQ by ICE OIA. Steps to 

ensure the authenticity of the lists are not performed. This limits 

OAQ’s ability to perform independent oversight because it only 

reviews files submitted by foreign posts and ICE OIA 

headquarters. Additionally, OAQ review of ICE OIA procurement 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

Page 13 
documentation does not include confirmation of purchase 

approvals by the appropriate approving authority at foreign posts, 

whether ICE attachés or their designees. 

ICE OIA headquarters has made efforts to improve oversight over 

ICE OIA acquisitions overseas but more is needed. To ensure 

effective oversight over its purchases, ICE should develop a plan 

that, at minimum, ensures independent analysis of foreign posts’ 

acquisitions and review of procurement files to confirm 

appropriate signatory authorities and acquisition approvals exist. 

Without this plan, it will be difficult to ensure that ICE is 

conducting the oversight necessary to prevent wasteful or 

fraudulent overseas acquisitions. 

Accountable Property Tracking System Information Is Not 

Always Accurate 

Several federal and departmental policies regulate the management 

and accountability of government property. Government property 

is accountable and subject to controls to track its physical location 

from acquisition through use and disposition. Some government 

property that meets specific criteria, however, must be tracked in 

an asset management system. The Sunflower Asset Management 

System is DHS’ property tracking tool. 

ICE guidance specifies that all property with an original 

acquisition value of $5,000 or greater, as well as sensitive 

property, are accountable and must be tracked in Sunflower. 

Table 1 provides examples of categories of accountable property. 

Category Examples 

All property with an original 

acquisition value 

of $5,000 or greater 

Vehicles, office equipment, 

software, personal property, 

leased property 

Sensitive property includes 

anything requiring a high degree 

of protection and controls and 

holds memory 

BlackBerrys, thumb drives, 

laptops, portable digital assistants, 

desktop computers, 

global positioning systems 

Table 1. Examples of Accountable Property in Sunflower 

The ICE Office of Asset Management, which is ultimately 

responsible for accountable property, requires that all ICE offices, 

including ICE OIA, conduct a physical inventory annually to ensure 

that all new and existing accountable property is in Sunflower. The 

ICE Office of Asset Management provides instructions for 

conducting the annual inventory to ICE OIA two to four weeks prior 

to commencing the inventory. ICE OIA’s Headquarters Personal 

Property Manager then forwards the inventory information to ICE 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

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OIA offices overseas, where the post’s Accountable Property 

Officer and designated staff are responsible for conducting a 

physical inventory of all accountable property at post. Once posts 

complete their inventories, they provide ICE OIA headquarters with 

the results and updated Sunflower information. ICE OIA 

headquarters enters property information into Sunflower for 

overseas posts that cannot access the system. ICE OIA overseas 

offices with access to Sunflower are responsible for entering their 

property information into the system. 

We visited seven ICE OIA overseas offices and conducted a 

physical inventory of a random sample of ICE accountable 

property at each post. We were able to match actual property for 

most items inventoried in Sunflower; however, there were 

discrepancies. At a few posts, the barcode number, owner, and 

physical location did not correspond to the post’s Sunflower report. 

There were also inconsistencies in entering and tracking 

information in Sunflower across the ICE OIA overseas offices. 

Some accountable property, such as BlackBerrys, laptops, and 

global positioning systems, were not entered into Sunflower. Staff 

at two posts said they were unclear regarding what items should be 

entered into Sunflower. Staff at other posts said that some of the 

property was sent from headquarters, and they were uncertain why 

the items were not already entered into the system. Staff at another 

office said that items were acquired at posts, but were not updated 

in Sunflower when the items were obtained because of issues 

pertaining to accessing the system. Consequently, the information 

was sent to ICE OIA headquarters for entry into Sunflower. Staff 

also said that accountable property was added during the annual 

inventory. 

The accuracy of information entered into Sunflower is important 

for property management purposes. Without accurate information 

maintained in Sunflower, the probability for accountable property 

to be lost, stolen, or misused increases. All Sunflower users should 

understand the importance of entering and maintaining accurate 

property information in ICE’s property tracking system. The better 

staff understands what should be entered into Sunflower and their 

roles and responsibilities regarding entering and tracking 

government property in the system, the more accountability there 

will be in managing government property. 

Self Inspection Program Identifies Deficiencies 

All 54 ICE attaché offices completed their first ICE OIA-specific 

self-inspections in April 2009. The self-inspections provide the 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

Page 15 
respective attaché with an indication of whether the office is in 

compliance with policies and procedures covered by the SIP and 

what areas need improvement. Each office submitted to ICE OPR 

the results of its self-inspection, including audit trail documentation 

and certification memorandum. The self-inspections identified 

deficiencies across SIP areas and attaché offices, and the attaché 

included a corrective action plan for each deficiency in the 

certification memorandum. 

We reviewed the SIP documentation submitted online to ICE OPR 

by 27 attaché offices. Some of these offices completed draft selfinspection worksheets which included areas or activities that ICE 

OPR ultimately removed from the final ICE OIA-specific SIP 

worksheets, such as classified material or pay administration. 

Other offices did not complete one or more of the nine ICE OIAspecific SIP areas, such as case management, asset management, or 

travel administration. In addition, offices responded differently to 

areas that applied to some offices but not to others. For example, 

not all offices use purchase cards. However, some offices did not 

complete the SIP for this area while others completed the SIP but 

indicated that the office does not have a purchase card. Still other 

offices without purchase cards indicated that there had been no 

activity in the purchase card area during the past year. Guidance to 

ensure that all offices complete the SIP in the same manner during 

future self-inspections likely would be helpful as ICE OPR reviews 

and adjusts the ICE OIA-specific and other ICE component SIPs. 

All posts identified deficiencies in at least one area during their 

respective self-inspections. If one sample inspected for an activity 

was not in compliance, then that activity was identified as a 

deficiency. Of the offices that responded to the respective SIP 

areas, 100% identified deficiencies in the case management area, 

68% in asset management area, 65% in the travel administration 

area, and 56% in the IT security area. 

Within the case management area, three activities were commonly 

identified as deficiencies: opening cases, completing the initial 

case report of investigation, and completing initial responses to 

collateral investigations in a timely manner. Of the documentation 

we reviewed, 26 of 27 offices completed the case management 

SIP. Of those 26 offices, 19 identified deficiencies in opening 

cases in a timely manner, and 24 offices identified deficiencies in 

completing initial reports of investigation and responses to 

collateral investigations. Certification memoranda submitted by 

the attaché offices documented corrective actions taken regarding 

case management, including reminding agents of the requirements 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

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and referring them to the case management handbook. Given the 

unique environment in which overseas offices operate, these 

deficiencies also could indicate a possible need for policy or 

procedural changes in the international environment. 

Recommendations 

We recommend that the Assistant Secretary for U.S. Immigration 

and Customs Enforcement: 

Recommendation #2: Develop a plan to monitor and objectively 

analyze ICE acquisition activities at overseas locations that, at 

minimum, outlines steps to require verification of acquisitions 

approvals at foreign posts and obtain procurement documentation 

independent of the Office of International Affairs. 

Recommendation #3: Provide additional guidance to ICE Office 

of International Affairs overseas offices that specifies the 

government property to be entered into the Sunflower Asset 

Management System and clarifies ICE inventory policies, roles, 

responsibilities, and processes to ensure that accountable property 

is entered and tracked accurately on a timely basis. 

Management Comments and OIG Analysis 

Management Comments to Recommendation #2 

ICE concurred with the recommendation. ICE OIA implemented 

an automated funds control system and implemented additional 

accounting controls to ensure that individual attaché offices do not 

deviate from their approved spend plans without prior approval by 

ICE OIA headquarters. ICE OIA also instructed attaché offices to 

run monthly reports through DOS to enable ICE OIA headquarters 

to track attaché expenditures and ensure oversight of spend plans. 

In addition, overseas purchases above the micro-purchase authority 

are procured by DOS in accordance with DOS acquisition policies 

and regulations, and attaché offices must report these purchases to 

ICE OIA headquarters. The information is provided to ICE OAQ 

for random sampling of purchases for compliance with applicable 

policies and regulations. 

OIG Analysis 

This recommendation is resolved and open pending receipt and 

review of additional information regarding the automated funds 

control system and accounting controls. ICE should also provide 

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information on how ICE OAQ will include verification of 

acquisitions approvals during its review process and ensure that 

they can independently obtain information regarding ICE OIA 

purchases that exceed $2,500.00. 

Management Comments to Recommendation #3 

ICE concurred with the recommendation. The ICE Office of Asset 

Management, within the Office of the Chief Financial Officer, is 

responsible for establishing personal property management policies 

and controls, providing personal property management training, 

and conducting quality assurance on data stored in Sunflower. The 

office also coordinates ICE’s annual inventory process. In early 

2009, the Office of Asset Management published guidance on ICE 

inventory policies, roles, responsibilities and processes to ensure 

appropriate accounting of all ICE property. ICE OIA will adhere 

to these policies now that they have been established. 

OIG Analysis 

Following a review of additional documentation submitted by ICE 

OIA, this recommendation is resolved and closed. 

ICE OIA Needs to Ensure Compliance With Foreign Tour of 

Duty Policy 

Although ICE has a policy regarding the length of time employees can be 

assigned to foreign offices, ICE human resources personnel do not verify 

whether individuals have previously been assigned overseas or for how 

long. In addition, some non-mission support personnel continue to remain 

in their overseas assignments beyond the allowed time limit. 

According to ICE policy, ICE personnel, except mission support 

specialists, can be assigned overseas for no more than five years at a time 

with no more than a total of ten years in foreign assignments during their 

entire career with ICE. Non-mission support personnel could be special 

agents, intelligence research specialists, or other personnel who are not 

mission support specialists. The time limitation includes time served 

overseas with legacy agencies, such as U.S. Customs or U.S. Immigration 

and Naturalization Service. Mission support specialists can be assigned 

overseas for 15 years over their entire career at ICE. The ICE OIA 

director may approve exceptions to these requirements. 

Human resources personnel in the Human Resources Division in Dallas, 

Texas, which provides personnel selection and payroll benefit support 

services for ICE OIA, said that they do not check for prior foreign 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

Page 18 
assignments when verifying a job candidate’s qualifications for overseas 

deployment. When human resources personnel receive responses to an 

ICE OIA vacancy announcement, they review the applications to 

determine whether applicants meet the qualifications for a posted job, but 

this review does not include verifying the length of time an applicant may 

have already served in an overseas position. In addition, the office does 

not clarify prior time overseas once ICE OIA selects an applicant for a 

specific position from the list of qualified candidates. By not verifying 

whether a candidate for a foreign assignment has previously served 

overseas, ICE OIA could select an individual who may not be qualified 

based on the foreign tour of duty policy. 

In addition, ICE OIA continues to have non-mission support personnel 

assigned overseas longer than five years. As of April 2, 2009, ICE OIA 

had 183 personnel overseas—170 non-mission support and 13 mission 

support personnel. Of the 170 non-mission support personnel, 63 were in 

the first year of their assignment, 52 were in their second year, 37 were in 

their third year, 6 were in their fourth year, and 3 were in their fifth year. 

Nine special agents were beyond five years in their current assignment, 

with two of these agents beyond six years. 

According to the April 2, 2009, rotation report maintained by ICE OIA 

headquarters, only four of the nine special agents who were already 

beyond five years overseas had received extensions. There was no 

indication in the rotation report of whether tour extensions had been 

granted for the other five agents. For one of the four agents who received 

an extension, the tour extension date expired in February 2009. There was 

no indication in the report of whether this agent had received an additional 

tour extension. 

As of April 2, 2009, all 13 overseas mission support personnel were within 

the allowed time limits according to the ICE OIA rotation report. 

However, the records kept by ICE OIA headquarters track only the 

employee’s current foreign assignment. The rotation report kept by ICE 

OIA human resources personnel could not identify that one mission 

support specialist had previously completed 10 years of foreign 

assignments. The mission support specialist recently received a tour 

extension, which will bring time served in the current assignment to five 

years and total time served overseas to 15 years. Because prior foreign 

assignments are not included in the rotation report or otherwise tracked, 

this mission support specialist possibly could receive another tour 

extension even though the employee will reach the 15-year limit upon 

completion of the current assignment. 

ICE OIA uses its rotation report to track current foreign assignments for 

both mission support and non-mission support personnel. When personnel 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

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rotate from a foreign assignment to a domestic assignment, ICE OIA has 

begun to copy the information from the current foreign assignment to 

another page in the rotation report. However, the rotation date for most 

employees is not updated to note the actual departure date from post, 

leaving the original planned departure date based on the employee’s entry 

on duty date at the post in the report. If an employee who rotated out of a 

foreign assignment, and whose foreign assignment information was 

transferred to the rotated-out section of the report, decided to apply for 

another foreign assignment, ICE OIA would be unable to use the report to 

determine with certainty the amount of time previously spent in a foreign 

assignment. According to an ICE OIA official, the only way to track prior 

foreign assignments, aside from the rotation report, would be to review 

each employee’s official personnel file. To ensure compliance with the 

policy, ICE must establish procedures to determine whether personnel 

selected for foreign assignments qualify for the assignment, and must 

track foreign assignments and tour extensions of overseas personnel. 

Recommendations 

We recommend that the Assistant Secretary for U.S. Immigration 

and Customs Enforcement: 

Recommendation #4: Establish and implement procedures to 

ensure compliance with the ICE foreign tour of duty policy and 

track ICE OIA foreign assignments and extensions. 

Management Comments and OIG Analysis 

Management Comments to Recommendation #4 

ICE concurred with the recommendation. Since February 2007, 

ICE OIA has had direct authority over its international placements. 

To ensure compliance with the foreign tour of duty policy, ICE 

OIA added language to overseas vacancy announcements 

regarding the maximum length of overseas assignments. In 

addition, ICE OIA is establishing a database to track the overseas 

assignments and extensions of all ICE employees. 

OIG Analysis 

This recommendation is resolved and open pending receipt and 

review of additional information regarding the database for 

tracking overseas assignments and extensions. 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

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Appendix A 

Purpose, Scope, and Methodology 

We reviewed the management and oversight of ICE OIA internal 

controls for acquisitions and employee integrity processes to 

evaluate weaknesses identified by prior OIG Investigations work. 

Specifically, the objectives of our review were to determine: 

(1) what management review and oversight is performed to ensure 

that ICE OIA employees understand and are following applicable 

procurement policies and procedures; (2) whether internal controls 

are effective at preventing or detecting the unauthorized 

acquisition, use, or disposition of assets; (3) the appropriateness of 

corrective actions when internal controls identify potential 

unauthorized activities; and (4) whether ICE OIA tests its policies 

and procedures periodically to ensure that internal controls are 

working as intended. 

We reviewed applicable laws, regulations, and directives regarding 

internal controls and the federal acquisitions process. We also 

reviewed policies, procedures, and training materials used by ICE 

OIA. In addition, we reviewed budget, acquisition, personnel, 

training, travel, property, and other records and documentation at 

both ICE headquarters and attaché offices. Finally, we reviewed 

oversight records, including self-inspection documentation, 

reports, and corrective action plans. 

We conducted 81 interviews with officials within ICE and DOS at 

headquarters and overseas. We conducted site visits to ICE OIA 

attaché offices in Bogotá, Colombia; Brasilia, Brazil; London, 

United Kingdom; Mexico City and Monterrey, Mexico; Madrid, 

Spain; and Rome, Italy. In addition to interviews at the posts, we 

reviewed ICE OIA attaché office files and documentation in 

several self-inspection areas including budget and procurement 

documentation for FYs 2006 to 2009. 

We began fieldwork in October 2008 and ended in July 2009. This 

review was conducted under the authority of the Inspector General 

Act of 1978, as amended, and according to the Quality Standards 

for Inspections issued by the President’s Council on Integrity and 

Efficiency. 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

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Appendix B 

Management Comments to the Draft Report 

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FOR OFFICIAL USE ONLY 

Appendix B 

Management Comments to the Draft Report 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

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FOR OFFICIAL USE ONLY 

Appendix B 

Management Comments to the Draft Report 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

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Appendix C 

ICE Assistant Secretary Memorandum to DHS Deputy Secretary 

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Appendix C 

ICE Assistant Secretary Memorandum to DHS Deputy Secretary 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

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Appendix C 

ICE Assistant Secretary Memorandum to DHS Deputy Secretary 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

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Appendix C 

ICE Assistant Secretary Memorandum to DHS Deputy Secretary 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

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Appendix C 

ICE Assistant Secretary Memorandum to DHS Deputy Secretary 

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Appendix C 

ICE Assistant Secretary Memorandum to DHS Deputy Secretary 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

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Appendix D 

Major Contributors to This Report 

Douglas Ellice, Chief Inspector, Office of Inspections 

Jennifer A. Lindsey, Lead Inspector, Office of Inspections 

E. Kristine Odiña, Senior Inspector, Office of Inspections 

Matthew R. Noll, Program Analyst, Office of Audits 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

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Appendix E 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff for Operations 

Chief of Staff for Policy 

Deputy Chiefs of Staff 

General Counsel 

Executive Secretariat 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

ICE Audit Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

Management and Oversight of ICE OIA Internal Controls for Acquisitions and Employee Integrity Processes 

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ADDITIONAL INFORMATION AND COPIES 

To obtain additional copies of this report, please call the Office of Inspector General (OIG) at (202) 254-4100, 

fax your request to (202) 254-4305, or visit the OIG web site at www.dhs.gov/oig. 

OIG HOTLINE 

To report alleged fraud, waste, abuse or mismanagement, or any other kind of criminal or noncriminal 

misconduct relative to department programs or operations: 

• Call our Hotline at 1-800-323-8603; 

• Fax the complaint directly to us at (202) 254-4292; 

• Email us at DHSOIGHOTLINE@dhs.gov; or 

• Write to us at: 

DHS Office of Inspector General/MAIL STOP 2600, 

Attention: Office of Investigations - Hotline, 

245 Murray Drive, SW, Building 410, 

Washington, DC 20528. 

The OIG seeks to protect the identity of each writer and caller.