DHS Inconsistently 

Implemented 

Administrative Forfeiture 

Authorities under CAFRA 

August 27, 2020 

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DHS OIG HIGHLIGHTS 

DHS Inconsistently Implemented

Administrative Forfeiture Authorities under CAFRA
 

August 27, 2020 

Why We Did 

This Audit 

As a means of enforcing 

compliance, and 

disrupting and dismantling 

criminal enterprises, DHS 

has the authority to seize 

and forfeit property 

associated with violations 

of law. From fiscal years 

2014 through 2018, DHS 

seized and forfeited about 

$4.6 billion for deposit into 

the Treasury Forfeiture 

Fund. We conducted this 

audit to determine whether 

DHS uses seizure and 

administrative forfeiture 

authorities as intended by 

law and policy. 

What We 

Recommend 

We made two 

recommendations to 

improve DHS’ oversight of 

administrative forfeitures 

to ensure compliance with 

applicable laws and 

regulations. 

For Further Information: 

Contact our Office of Public Affairs at 

(202) 981-6000, or email us at 

DHS-OIG.OfficePublicAffairs@oig.dhs.gov 

What We Found 

The Department of Homeland Security inconsistently 

implemented seizure and administrative forfeiture 

authorities under the Civil Asset Forfeiture Reform Act 

of 2000 (CAFRA) in FYs 2014 through 2018. Congress 

enacted CAFRA to provide uniform procedures for civil 

forfeitures and increase safeguards for individuals 

whose property has been seized by the Federal 

Government. However, DHS components used 

inconsistent processes for administrative forfeitures 

under CAFRA. Specifically, we found inconsistencies 

in the forms used to notify property owners and the 

process for responding to claims. Additionally, U.S. 

Customs and Border Protection (CBP) inappropriately 

used waivers to extend deadlines for responding to 

claims. 

These inconsistencies occurred, in part, because 

components interpreted CAFRA differently, but also 

because DHS did not designate an office responsible 

for overseeing administrative forfeitures across the 

Department. Additionally, DHS did not establish 

department-wide policy and instead allowed 

components to use different policies and processes to 

guide administrative forfeiture activities. Without 

proper oversight, DHS may be unaware of 

noncompliance and possible abuse of seizure and 

forfeiture authorities. Further, DHS may risk losing 

the public’s trust and exposing the Department to 

costly litigation. 

DHS Response 

DHS did not concur with recommendation 1 but 

concurred with recommendation 2. We consider 

recommendation 1 unresolved and open and 

recommendation 2 resolved and open. Appendix A 

contains DHS management comments in their entirety. 

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Department of Homeland Security 

Background
 

As a means of disrupting and dismantling criminal enterprises, the Department 

of Homeland Security has the authority to seize and forfeit property associated 

with violations of law. A seizure occurs when the government takes possession 

of an individual’s property, while a forfeiture is the legal process of transferring 

title of the property to the government. DHS components may seize property 

for violations such as immigration law, misreporting currency upon entering or 

exiting the United States, importation of counterfeit goods, drug smuggling, or 

money laundering. Asset forfeiture is a critical law enforcement tool used to 

deprive criminal organizations of illicitly obtained assets and enforce 

compliance with Federal law. From fiscal years 2014 through 2018, DHS 

components forfeited an estimated $1.8 billion in assets such as cash, 

electronics, and vehicles for deposit into the Treasury Forfeiture Fund,1 with an 

additional $2.8 billion still subject to forfeiture proceedings. 

DHS has three components with seizure and forfeiture authority: U.S. Customs 

and Border Protection, U.S. Immigration and Customs Enforcement (ICE), and 

the United States Secret Service (Secret Service). A fourth component, the 

United States Coast Guard, only has seizure authority and uses other DHS 

components or Federal law 

enforcement to process 

forfeitures. Although ICE has 

forfeiture authority, ICE does not 

have the infrastructure to process 

forfeitures. Since DHS’ inception, 

CBP’s Fines, Penalties and 

Forfeitures Division has handled ICE 

seizures. For the most part, once 

ICE seizes property, it transfers the 

asset to CBP for processing, 

including sending notices, managing 

petitions and claims, storing assets, 

and final disposition. As shown in 

figure 1, CBP processed the most 

forfeiture cases, comprising 

approximately 91.1 percent of the 

Department’s total for FYs 2014 

through 2018. 

Figure 1: FY 2014–2018 Percent of

Forfeiture Cases by Seizing Component 

Source: DHS Office of Inspector General (OIG) 

analysis of component-generated data. We did not 

test the reliability of this data and are presenting 

the information as provided. 

1 Forfeitures are deposited into a special fund called the Treasury Forfeiture Fund managed by 

the Treasury Executive Office for Asset Forfeiture. 

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Once an asset has been seized, DHS components use three types of forfeiture 

to take ownership of the property: criminal, civil judicial, or administrative. 

Criminal and civil judicial forfeitures require court proceedings to decide 

whether to forfeit the asset. Administrative forfeitures are handled primarily by 

the seizing agency, generally without judicial involvement and without having 

to charge the property owner with a crime. An example of a basis for 

administrative forfeiture is misreporting currency upon entering or exiting the 

United States. Travelers are required to declare to CBP if they are transporting 

$10,000 or more in 

currency. If a traveler 

fails to declare, it could 

result in seizure and 

possible forfeiture of all 

currency on the 

individual. Components 

are authorized to 

administratively forfeit 

currency of any amount, 

as well as other property 

valued at less than 

$500,000, excluding real 

estate. From FYs 2014 

through 2018, DHS 

processed approximately 

98.6 percent of cases as 

administrative forfeitures 

(See figure 2). 

Figure 2: FYs 2014–2018 DHS Cases by 

Forfeiture Type 

Source: DHS OIG analysis of component-generated data. We 

did not test the reliability of this data and are presenting the 

information as provided. 

CBP and ICE follow CBP’s Seized Asset Management and Enforcement 

Procedures Handbook and Secret Service uses its Asset Forfeiture Manual for 

guidance on enforcement actions regarding seizures, fines, penalties, and 

liquidated damages. According to law and these components’ policies, once an 

asset is seized, components must send the property owner and any other 

parties that may have an interest in the property a written notice of the seizure 

and intent to forfeit. The purpose of this notice is to inform property owners of 

their options, for example: file a petition, file a claim, or do nothing. Property 

owners file petitions if they agree their property is subject to forfeiture, but are 

seeking its partial or full return. A claim is filed in instances such as when 

property owners believe their property was not part of an illegal activity and 

wish to contest the seizure in court. Figure 3 outlines DHS’ administrative 

forfeiture process. 

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Figure 3: Overview of Administrative Forfeiture Process 

Source: OIG analysis of component manuals and processes 

In April 2000, Congress enacted the Civil Asset Forfeiture Reform Act of 2000 

(CAFRA) to increase safeguards for property owners whose property has been 

seized by the Federal Government and provide more just and uniform 

procedures for Federal civil forfeitures. CAFRA significantly revised civil 

forfeiture law by establishing deadlines, formalizing an innocent owner 

defense,2 and waiving property owner costs associated with filing a claim. 

These revisions were meant to ensure due process by requiring timely Federal 

Government action when property owners contest a seizure or forfeiture. 

Even after passage of CAFRA, Congress expressed concerns about Federal 

agencies forfeiting property without judicial oversight and without charging 

property owners with crimes. Our audit is the first time OIG has reviewed 

DHS’ use of administrative forfeiture authorities. We conducted this audit to 

determine whether DHS uses seizure and administrative forfeiture authorities 

as intended by law and policy. Our audit focused on the Department’s 

processes for administrative forfeitures under CAFRA in FYs 2014 through 

2018. 

Results of Audit 

DHS Components Used Inconsistent Forfeiture Processes 

Congress enacted CAFRA to prevent delays in property owners challenging 

forfeitures or receiving due process. As such, CAFRA requires the seizing 

agency to send a written notice to the 

property owner within 60 days of the 

seizure. CAFRA’s protections also 

include a requirement for Federal 

agencies to use easily understandable 

Due process requires that 

laws and regulations do not 

contain provisions that 

result in unfair or arbitrary 

treatment of an individual. 

2 According to 18 United States Code (U.S.C.) 983(d), if a person shows that he or she did not 

know his or her property was being used for an illegal purpose, or that upon learning of the 

illegal use took reasonable steps to terminate such use, then the property will not be forfeited. 

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notices. However, we found inconsistencies in CBP’s and Secret Service’s 

CAFRA notices of seizure and forfeiture. Specifically, we identified differences 

in the language regarding property owners’ rights and options. CBP’s notice 

did not clearly explain the circumstances under which a property owner may 

choose to file a petition or a claim. In comparison, Secret Service’s notice 

clearly explained each option and specific timeframes. Appendixes B and C 

contain examples of CBP’s and Secret Service’s CAFRA notices of seizure and 

forfeiture, respectively. 

CBP’s notice also included confusing deadlines. As illustrated in figure 4, the 

language describing the deadlines for filing a claim after a petition is 

ambiguous and unclear. 

Figure 4: CBP CAFRA CBP CAFRANotice Language for Filing a Petition Notice Language for Filing a Petition 

Source: Excerpt from CBP’s CAFRA Notice to Property Owners 

CBP’s CAFRA notice language may cause confusion about the correct filing 

deadline for a claim. If a property owner misunderstands the timeframes for 

filing, the individual could miss the deadline and the property could be 

forfeited. In fact, one property owner filed a motion in District Court, arguing 

that CBP’s ambiguous and misleading notice violated the owner’s right to due 

process.3 During an interview, an Assistant United States Attorney also 

described CBP’s notice as confusing and agreed that without extensive 

knowledge of forfeiture law it would be difficult to understand each option. 

To further our analysis, we compared CBP’s and Secret Service’s notices to 

those of other Federal agencies. Both the Internal Revenue Service (IRS) and 

the Department of Justice (DOJ) issue notices similar to Secret Service, with 

explanations for each filing option and specific timeframes. We learned that, to 

ensure uniformity under CAFRA, DOJ developed uniform notices that are used 

by other Federal agencies. 

3 Restrepo v. United States, Civ. A. No. 17-mc-19 (N.D. Fla.). An official of the Department of 

Justice identified this case as an example of the confusion created by CBP’s notice language. 

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Additionally, we found DHS components did not consistently respond to claims 

filed by property owners. According to CAFRA, a property owner must file a 

claim by the deadline stated in the notice. This deadline must be at least 35 

days after a notice is sent. The Federal Government must file a court action 

within 90 days or return the property. However, we found that CBP and Secret 

Service handle claims differently. Both CBP and Secret Service policies state 

that upon receiving a claim, the package should be sent to the U.S. Attorney’s 

Office (USAO) to decide whether to file a court action or return the property. 

Yet, CBP and Secret Service’s procedures differ regarding what should happen 

if the USAO declines the case. According to Secret Service’s manual, the 

property must be released to the property owner, while CBP’s handbook allows 

CBP to negotiate a settlement with the property owner for partial return of 

property. 

The USAO can decline a case for a variety of reasons, such as the value of the 

property seized does not meet the threshold to pursue court action, or there is 

not enough evidence to support that the property is subject to forfeiture. By 

negotiating settlements in cases where a USAO declines the case referral or in 

cases that are not referred to a USAO, CBP may be taking a portion of property 

from innocent property owners. In one claim we reviewed, CBP seized $20,000 

in cash from a property owner. Based on the evidence, CBP later determined 

that the funds seized did not appear to come from illegal activity, yet CBP 

negotiated a settlement with the property owner to forfeit $1,000 to the Federal 

Government, returning only $19,000. We reviewed another case in which CBP 

negotiated a settlement to forfeit $15,000 from $59,950 in seized cash. In both 

examples, CBP made this decision without referring the claim to the USAO for 

a decision. In fact, for 7 of 11 sampled cases in which a claim was filed, CBP 

settled with a property owner without sending the claim to a USAO for a 

decision, as required by policy. 

Lastly, CBP inappropriately used waivers to extend CAFRA’s 90-day deadline to 

file a court action or release the property, although it lacked such authority. 

According to CAFRA, deadlines are established to ensure property owners 

receive due process. However, in one case, CBP worked with the claimant’s 

attorney to have the claimant (property owner) forego CAFRA’s 90-day deadline 

to allow more time for CBP to negotiate a settlement. Under CAFRA, only 

district courts have the authority to extend this deadline. The extension 

allowed CBP an additional 15 days to continue to work toward an agreement 

with the property owner, instead of promptly returning the property, as 

required by law. We compared CBP’s practices to those of Secret Service and 

determined Secret Service does not negotiate settlements for claims or issue 

waivers to extend CAFRA’s claim deadline. We also compared CBP’s practices 

to the policies of DOJ and the IRS, both of which interpreted the claim process 

under CAFRA differently from CBP. For example, Secret Service policy and 

practice is similar to both DOJ and IRS policies, which state that claims are to 

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be referred to the USAO and if a judicial forfeiture is not filed within 90 days, 

the property must be returned. 

DHS Does Not Effectively Oversee Components’ Use of 

Administrative Forfeitures 

The inconsistencies described previously occurred in part because DHS did not 

designate an office or departmental official responsible for overseeing 

components’ administrative forfeitures. Since its inception in 2002, DHS has 

allowed components to operate asset forfeiture programs independently. DHS 

has not established an office to collect program data to monitor components’ 

use of administrative forfeitures for compliance with applicable laws. The 

Department also did not have an office to implement performance metrics to 

measure or track program effectiveness — critical elements of quality oversight. 

In the absence of department-wide performance measures, we requested 

performance measure data from each component. However, at the time of our 

review in August 2019, none of the components had implemented metrics to 

track the effectiveness of their administrative forfeiture practices. 

In addition, DHS had not established any department-wide policies to ensure 

components complied with the requirements of CAFRA. Instead, DHS allowed 

components to use different policies and processes to guide forfeiture activities. 

DHS’ Financial Management and Accounting Manual includes a section on 

seized and forfeited property, but the manual delegates the responsibility to the 

components. It does not provide comprehensive guidance for the components, 

such as how to properly seize property, forfeit property, or dispose of forfeited 

property. 

DHS, as part of its oversight role, did not review components’ policies to 

determine compliance with returning property for declined CAFRA claim 

referrals by the USAO. We found that CBP and Secret Service policies both 

required a property owner to sign a Hold Harmless Agreement as a condition 

for returning property. This agreement requires that the property owner waive 

the right to file suit against the government and absolve the government of any 

wrongdoing. However, CAFRA does not mention this type of agreement as part 

of its provisions for releasing property. Although CBP and Secret Service use 

this practice, without proper oversight, DHS cannot ensure it aligns with 

CAFRA's requirement that the government promptly release the property back 

to the owner. Having department-wide policy would ensure components use 

seizure and forfeiture authorities consistently, in compliance with CAFRA. 

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Conclusion 

When used appropriately, asset forfeiture is an effective tool to deter criminal 

activity by depriving criminals of illegal proceeds and enforcing compliance 

with Federal law. Without proper Departmental oversight, DHS may be 

unaware of noncompliance and possible abuse of seizure and forfeiture 

authorities, exposing the Department to potential litigation and unnecessary 

costs. In recent litigation, Dunn v. United States,4 the United States 

acknowledged that CBP misinterpreted Adrian Dunn’s claim filing as a petition 

instead of a claim.5 The court overturned CBP’s administrative forfeiture, 

potentially returning illicit cash, and subsequently ordered the government to 

pay $20,160 in Mr. Dunn’s attorney fees.6 In another example, Kazazi v. CBP,7 

the court agreed that CBP did not promptly return the Kazazis’ property as 

required by CAFRA, and that they were entitled to receive $43,280 in attorney 

fees and costs. The court’s decision stated that the Kazazis “are exactly the 

type of people CAFRA was designed to protect and make whole — innocent 

property owners merely seeking the return of their held property.” Such 

lawsuits expose the Department to further criticism and invite perceptions of 

due process violations, which might cause Congress to consider limiting the 

use of administrative forfeiture on a government-wide scale. 

Recommendations 

Recommendation 1: We recommend the Under Secretary for Management 

develop and implement a department-wide structure and designate an office to 

manage and oversee forfeiture activities across DHS, including: 

x reviewing component policies and procedures to ensure alignment with 

CAFRA; 

x developing performance objectives, measures, and plans; and 

x periodically requesting and reviewing component administrative 

forfeiture data for alignment with departmental and component goals. 

Recommendation 2: We recommend the Under Secretary for Management 

develop department-wide policies and procedures, including: 

x consistent CAFRA notices and forms that meet Federal plain language 

writing requirements; and 

x consistent interpretation on managing CAFRA claims and use of a Hold 

Harmless Agreement. 

4 Civ. A. No. 16-cv-493 (W.D. Mo.).
 5 As the United States further acknowledged, under CAFRA, once CBP received the claim, it
 

should have referred it to the U.S. Attorney’s Office for the Western District of Missouri.
 6 United States v. Approximately $41,000 in United States Currency, et al., Civ. A. No. 18-cv-43
 

(W.D. Mo.).
 7 Civ. A. No. 18-mc-51 (N.D. Ohio).
 

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Management Comments and OIG Analysis 

The Department provided formal written comments in response to our draft 

report. We also received technical comments and incorporated them in the 

report where appropriate. We have included a copy of the Department’s 

response in its entirety in appendix A. In its response, the Department raised 

concerns that the draft report contains inaccurate and misleading 

representations about the Department’s implementation of administrative 

forfeiture authorities. The Department did not concur with recommendation 1 

but concurred with recommendation 2. 

We disagree with the Department’s assessment that this report contains 

inaccuracies and misleading representations. We recognize that DHS enforces 

broad authorities that permit it to forfeit property. However, our audit was 

meant to provide constructive recommendations to ensure the integrity of the 

Department’s administrative forfeiture programs. If the public loses trust in 

the controls over DHS administrative forfeitures, it opens the Department up to 

litigation and may risk the loss of DHS administrative forfeiture authority as a 

law enforcement tool. 

We consider recommendation 1 unresolved and open, and recommendation 2 

resolved and open. A summary of the Department’s responses and our 

analysis follows. 

DHS Response to Recommendation 1: Non-Concur. The Deputy Under 

Secretary for Management does not believe the OIG’s draft report provides 

adequate justification for creating a structure with a designated office to 

manage and oversee forfeiture activities department-wide. 

OIG Analysis of DHS Response: We disagree with DHS’ response to 

recommendation 1. DHS believes that the Department of Treasury’s Executive 

Office of Asset Forfeiture provides adequate oversight of DHS components’ 

forfeiture activities through its financial statement audit. However, the 

financial statement audit reviews the Treasury Forfeiture Fund and does not 

involve reviewing programmatic use or implementation of DHS’ forfeiture 

activities. Additionally, during fieldwork, the DOJ Criminal Division’s Money 

Laundering and Asset Recovery Section raised concerns about CBP’s CAFRA 

form and claim referrals. Neither Treasury nor DOJ provides oversight since 

they do not have a direct line of authority over DHS components and how they 

process seizures for forfeiture under CAFRA. Without adequate oversight, DHS 

cannot ensure that components are appropriately following relevant policies 

and procedures for forfeiture of seized assets subject to CAFRA. Until DHS 

takes appropriate action, we consider this recommendation unresolved and 

open. 

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DHS Response to Recommendation 2: Concur. DHS recognizes the value of 

creating department-level policy to ensure DHS components implement CAFRA 

appropriately. DHS agreed to develop a department-wide directive to: 1) ensure 

compliant CAFRA implementation; 2) provide notices and forms that conform 

to Federal best practices; and 3) ensure consistent practices for managing 

responses to property owners, while taking into account the different forfeiture 

authorities of each component. Estimated Completion Date: August 31, 2021. 

OIG Analysis of DHS Response: We consider these actions responsive to the 

recommendation. The recommendation will remain resolved and open until 

DHS provides the department-wide directive and instructions and we verify the 

policy guidance satisfies the intent of the recommendation. 

Objective, Scope, and Methodology 

The Department of Homeland Security Office of Inspector General was 

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

amendment to the Inspector General Act of 1978. 

We conducted this audit to determine whether DHS uses seizure and 

administrative forfeiture authorities as intended by law and policy. The scope 

of our audit included administrative forfeitures under CAFRA from FYs 2014 

through 2018. To achieve our objective, we reviewed Federal, departmental, 

and component guidance related to seizures and forfeitures for CBP, ICE, 

United States Coast Guard (Coast Guard), and Secret Service. We also 

reviewed congressional testimony, along with prior OIG, Government 

Accountability Office, and other Federal agency OIG audit reports for findings 

and recommendations related to our audit. 

To gain an understanding of seizures and forfeitures at the Department, we 

interviewed DHS and component headquarters officials from: 

x Office of the Chief Financial Officer (OCFO); 

x OCFO Budget; 

x OCFO Financial Management; 

x OCFO Program Analysis and Evaluation; 

x Office of the Chief Readiness Support Officer; 

x CBP’s Fines, Penalties and Forfeitures Division; 

x ICE’s Homeland Security Investigations Asset Forfeiture Unit; 

x Secret Service’s Asset Forfeiture Branch; 

x U.S. Border Patrol; 

x Coast Guard; and 

x components’ counsel offices 

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We also interviewed officials from the Department of Justice and Treasury’s 

Executive Office for Asset Forfeiture. 

We excluded Coast Guard from the scope of the audit after meeting with Coast 

Guard officials and reviewing the component’s policy manuals. We excluded 

Coast Guard because it does not have forfeiture authority or an established 

forfeiture program; Coast Guard generally conducts seizures in coordination 

with or on the behalf of other Federal law enforcement agencies; and it 

predominantly seizes contraband and does not have the capacity or facilities to 

store seizures. 

We requested information from CBP and ICE’s SEACATS8 database and Secret 

Service’s FASTRAK9 database to determine the total number and dollar value of 

assets seized and forfeited. We did not place any significant reliance on or test 

data from SEACATS and FASTRAK because it was not needed to meet our 

audit objective. We used SEACATS and FASTRAK only to select cases for 

review and not to reach conclusions in support of our audit findings. We 

identified a universe of 506,785 seizures in SEACATS and 2,864 seizures in 

FASTRAK in consultation with our data analytics group. Due to the large 

number of seizures, we narrowed our universe to cases classified as 

administrative forfeitures because they are not handled in court and have 

higher risk due to a lack of oversight. This reduced the number of seizures to 

303,494 SEACATS cases and 1,581 FASTRAK cases. We further excluded data 

fields, such as: 

x

x

administratively forfeited cases that also resulted in criminal or civil 

judicial forfeitures; 

cases that cited non-CAFRA violations or “Customs Carve-Out” laws;10 

and 

x cases with additional enforcement actions such as an indictment, plea 

agreement, or search, seizure and arrest warrant. 

As a result of data limitations, the audit team still found some non-CAFRA 

assets among its reviewed seizures. Due to limited audit resources, we 

judgmentally selected and reviewed 207 case files. We judgmentally selected 

cases from locations based on the total number of administrative forfeiture 

cases, total dollar value of seizures, claims filed, and OIG hotline complaints. 

8 Seized Asset and Case Management System (SEACATS) is the official CBP system of record for 

tracking seized property and processing seizure cases. 

9 FASTRAK is a system application that manages the entire asset forfeiture process from 

beginning through final disposition of an asset. This application is a part of Secret Service’s 

Field Investigative Reporting System, which consists of seven applications for reporting law 

enforcement activities. 

10 The SAMEPH and 18 U.S.C. 983 list “Customs Carve-Out” laws, which are excluded from 

CAFRA requirements. These laws are: Title 19, U.S.C.; Title 22, U.S.C. 401; Title 26, U.S.C.; 

Title 21, U.S.C. 301, et seq.; Title 50, U.S.C. App. 1, et seq.; and, Title 50, U.S.C. 1701, et seq. 

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We reviewed case files at the following locations: Washington, DC; Detroit, MI; 

Laredo, TX; Miami, FL; Newark, NJ; and New York, NY. 

To test the documentation obtained in these case files, we developed a data 

collection instrument. We reviewed probable cause documented for each 

seizure and documentation of subsequent steps taken to prove substantial 

connection between the property and the illegal activity supporting forfeiture. 

We also attempted to determine when property was returned to the owner and 

how the application of Hold Harmless Agreements affected release of the 

property. Additionally, during site visits, we interviewed Federal law 

enforcement, staff at ports of entry, and paralegal specialists to understand 

oversight controls and identify performance measures the field used to evaluate 

the effectiveness of seizure and forfeiture activities for deterring criminal 

activity. Lastly, we reviewed seven excerpts of CBP administrative case files 

that DOJ provided. Due to the limited sample size, we did not use this 

information as the sole basis to support our findings. 

We conducted this performance audit between September 2018 and March 

2020 pursuant to the Inspector General Act of 1978, as amended, and 

according to 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 upon our audit objective. We believe that the evidence 

obtained provides a reasonable basis for our findings and conclusions based 

upon our audit objective. 

The Office of Audits major contributors to this report are Shelley Howes, 

Director; David Lu, Audit Manager; Elizabeth Finn, Auditor in Charge; Michael 

Brunelle, Program Analyst; Amber Carlson-Jones, Program Analyst; Gaven 

Ehrlich, Senior Program Analyst; Kate Fishler, Auditor; Richard Joyce, Program 

Analyst; Stephen Wheeler, Program Analyst; Christopher Zubowicz, Assistant 

Counsel to the Inspector General; Lindsey Koch, Communications Analyst; and 

Michael Nasuti, Independent Referencer. 

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Appendix A 

DHS Comments to the Draft Report 

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Appendix B 

CBP Notice of Seizure and Information to Claimants CAFRA 

Form 

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Appendix C 

Secret Service Seizure of Property Notice 

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Appendix D 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chiefs of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Under Secretary, Office of Strategy, Policy, and Plans 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Commandant, United States Coast Guard 

Commissioner, U.S. Customs and Border Protection 

Director, U.S. Immigration and Customs Enforcement 

Director, United States Secret Service 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees 

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Additional Information and Copies 

To view this and any of our other reports, please visit our website at: 

www.oig.dhs.gov. 

For further information or questions, please contact Office of Inspector General 

Public Affairs at: DHS-OIG.OfficePublicAffairs@oig.dhs.gov. 

Follow us on Twitter at: @dhsoig. 

OIG Hotline 

To report fraud, waste, or abuse, visit our website at www.oig.dhs.gov and click 

on the red "Hotline" tab. If you cannot access our website, call our hotline at 

(800) 323-8603, fax our hotline at (202) 254-4297, or write to us at: 

Department of Homeland Security 

Office of Inspector General, Mail Stop 0305 

Attention: Hotline 

245 Murray Drive, SW 

Washington, DC 20528-0305