Audit Report

OIG-16-001

Libyan Sanctions Case Study

October 26, 2015

Office of

Inspector General

Department of the Treasury
This Page Intentionally Left Blank.
Contents

Libyan Sanctions Case Study (OIG-16-001) Page i

Audit Report

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

Background.................................................................................................... 6

OFAC Mission ..............................................................................................6

Libyan Sanctions Program..............................................................................7

Financial Institutions Identified, Blocked, and Maintained Libyan 

Assets .......................................................................................7

OFAC Eased Sanctions on Libya and Released the Majority of Blocked 

Assets .....................................................................................10

Findings........................................................................................................10

Weaknesses Identified in OFAC’s Internal Controls .........................................10

OFAC Would Benefit from a Formal Lessons-learned Process ...........................17

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

Appendices

Appendix 1: Objectives, Scope, and Methodology .............................................24

Appendix 2: Chronology of Significant Events ...................................................26

Appendix 3: Management Comments ...............................................................29

Appendix 4: Major Contributors to this Report...................................................31

Appendix 5: Report Distribution.......................................................................32

Abbreviations

ABaRRS Automated Blocking and Reject Report System

EO Executive Order
Libyan Sanctions Case Study (OIG-16-001) Page ii

GAO Government Accountability Office

IEEPA International Emergency Economic Powers Act

JAMES Joint Audit Management Enterprise System

NEA National Emergencies Act

OASIS OFAC Administrative System for Investigations and Sanctions

OFAC Office of Foreign Assets Control

OIG Office of Inspector General
OIG Audit

Report

The Department of the Treasury

Office of Inspector General

 

Libyan Sanctions Case Study (OIG-16-001) Page 1

Audit Report

October 26, 2015

John E. Smith, Acting Director

Office of Foreign Assets Control

This report presents the results of our audit of the Office of Foreign 

Assets Control’s (OFAC) implementation and administration of 

sanctions against Libya. Our report also discusses the implications 

that OFAC’s processes and practices identified in the Libyan 

program have on other OFAC sanctions programs. 

OFAC administers and enforces economic and trade sanctions 

based on U.S. national security and foreign policy goals against 

targeted foreign countries and regimes, terrorists, international 

narcotics traffickers, those engaged in activities related to the 

proliferation of weapons of mass destruction, and other threats to 

the national security, foreign policy, or the economy of the United 

States. 

Our objectives for this audit were to (1) determine the legal 

authorities for the Libyan sanctions program; (2) determine how 

blocked assets were identified, maintained, and accounted for; and 

(3) assess OFAC's subsequent and gradual release of blocked

Libyan assets, including how OFAC planned to identify and release 

all remaining blocked assets to their rightful owners upon 

termination of the sanctions program. 

To accomplish these objectives, we interviewed OFAC officials 

responsible for the implementation and administration of the Libyan 

sanctions program. We also reviewed program documentation 

provided to us by OFAC. We performed our fieldwork from March 

2012 to January 2013. We updated the status of the Libyan 

sanctions program and other information included in this report in 

December 2014. Appendix 1 provides a more detailed description 

of our audit objectives, scope, and methodology.
Libyan Sanctions Case Study (OIG-16-001) Page 2

Results in Brief

On February 25, 2011, the President issued Executive Order (EO) 

13566 blocking the property and interests in property of Colonel 

Muammar Qadhafi, his close associates, and the government of 

Libya. The EO was issued based on authority granted to the

President under the National Emergencies Act (NEA) and the 

International Emergency Economic Powers Act (IEEPA).1

The United States imposed sanctions because the continued 

violence in Libya posed an unusual and extraordinary threat to U.S. 

national security and foreign policy interests. Three (3) days after 

EO 13566 was issued and OFAC’s sanction program was 

established, Treasury announced that at least $30 billion in Libyan 

assets within U.S. jurisdiction were blocked as a result of the EO. 

In total, approximately $38 billion in assets were blocked under this

program. 

By December 2011, most of the sanctions against Libya had been 

lifted with approximately $3 billion in assets remaining blocked at 

that time. The President extended EO 13566 for 1 year in 2012, 

2013, 2014, and again in 2015. In extending the EO, the President 

cited conditions in Libya that continued to pose unusual and 

extraordinary threats. According to OFAC, in December 2014

approximately $3 billion in assets remained blocked under the 

Libyan program.

OFAC implemented and administered the Libyan sanctions program 

as it has with other sanctions programs by requiring U.S. persons, 

including financial institutions, to identify, and block the assets of 

 

1 Enacted on September 14, 1976, NEA (50 U.S.C.1601 et seq., National Emergencies Act) 

established regulations for presidential declarations of national emergencies and wars, and for the 

termination of such declarations. The President is required to formally declare the existence of a 

national emergency and to specify the provisions of law under which the President or other officers 

propose to act. The President’s actions must be pronounced either through the declaration of a 

national emergency or issuance of an EO. National emergencies declared under NEA terminate on the 

anniversary of the declaration. The President may, within the 90-day period prior to each anniversary 

date, notify the Congress of intent to continue the state of emergency and must publish such intent 

in the Federal Register. Enacted by Congress in 1977, IEEPA (50 U.S.C. 1701–1706, International 

Emergency Economic Powers Act) authorizes the President to declare national emergencies in the 

event of foreign threats to the United States. IEEPA provides the President with the authority to deal 

with unusual and extraordinary threats to the national security, foreign policy, or the economy of the 

United States, where the source of the threat in whole or substantial part is outside of the country.
 Libyan Sanctions Case Study (OIG-16-001) Page 3

targeted parties that come within their possession or control. 

Financial institutions were required to report these actions to OFAC 

within 10 business days. As with most sanctions programs, OFAC 

did not take possession of blocked assets under the Libyan 

sanctions program. While OFAC authorized the release of blocked 

assets through its licensing program, the financial institutions were 

responsible for returning funds to their rightful owners once 

authorized for release by OFAC.

Our audit identified the following control weaknesses impacting 

OFAC operations, some of which were similar to issues reported in 

prior Office of Inspector General (OIG) audits of OFAC:

 OFAC continued to rely on its collection of prior executive 

orders, regulations, memoranda, and the knowledge and 

experience of OFAC staff as policy and procedural guidance 

when implementing and administering new and ongoing

sanctions programs. Written standard operating procedures for 

many day-to-day functions of OFAC’s sanctions programs have 

not been developed, contrary to government-wide internal 

control standards.

 OFAC did not actively assess financial institutions’ compliance 

with the 10-day reporting requirement for submitting reports of 

blocked transactions and rejected transactions.

2

In addition, our 

review of a sample of these reports found that, in many 

instances, OFAC’s system and supporting documentation did 

not contain the information necessary to determine the date the 

reports were received or the timeliness of the filings. We believe 

the quality of reports of blocked and rejected transactions data 

could be improved by completing the development of OFAC’s 

planned electronic filing system for high-volume filers and 

promoting the use of OFAC’s electronic filing applications by all 

financial institutions.

 

2 Blocking or freezing of assets imposes immediate, comprehensive prohibition against transfers or 

dealings of any kind with regard to the property. Financial institutions must retain the assets and 

block them from further use. Rejected transactions are activities prohibited under a sanctions 

program that may not involve a blockable interest. Rejected transactions do not involve funds 

blocked and retained by financial institutions.
Libyan Sanctions Case Study (OIG-16-001) Page 4

 OFAC can only estimate the total amount of assets that remain 

blocked under its sanctions program at any point in time. To 

determine the total assets blocked, OFAC adjusted the amounts

provided in annual financial institution reports with blocking and 

licensing data posted to internal OFAC systems after the annual 

report cut-off dates. OFAC, however, did not fully assess its 

blocked asset and licensing data to ensure that all financial 

institutions submitted annual reports of blocked assets or that 

the reports it received were accurate.

Our review also found that OFAC has not implemented a formal 

lessons-learned process to communicate knowledge gained from 

past sanctions for the benefit of future sanctions programs. OFAC 

instead relies on staff experience and the range of Executive 

Orders, regulations, and guidance documents issued for all of its 

current or former sanctions programs as guidance for implementing 

new programs. We believe OFAC would benefit from a formal 

lessons-learned process to identify best practices for use in future 

programs and to aid in the development and maintenance of 

documented standard operating policies and procedures for 

administering sanctions programs.

We are recommending in this report that OFAC (1) identify the 

actions required to implement and administer its sanctions 

programs and document those actions in written standard 

operating procedures; (2) implement procedures and any necessary 

system modifications to allow for tracking and periodic analysis of

financial institutions’ compliance with the 10-day reporting 

requirement and to take appropriate action against late-filers; 

(3) implement a methodology to identify blocked assets that have 

been released by type of license (general or directive) and update

information in OFAC’s system; (4) continue to pursue development 

and implementation of electronic filing for high-volume filers; and 

(5) develop a lessons-learned process, to capture and communicate 

acquired knowledge from past sanctions programs at a time 

appropriate for each sanctions program.

In its management response, OFAC did not address our 

recommendation to document actions required to implement and 

administer its sanctions programs in written standard operating 

procedures. OFAC stated that it already has a wealth of documents 

available for staff to implement and administer sanctions programs, 
 Libyan Sanctions Case Study (OIG-16-001) Page 5

along with a body of case work developed through its licensing 

decisions and letters of interpretive guidance to assist staff. We 

believe the documents and information cited by OFAC, while 

valuable resource materials, do not represent what we would 

consider standard operating procedures to be used by OFAC staff 

for implementation and the day-to-day administration of its 

sanctions programs. Many of the resources cited by OFAC are 

materials developed for use by filing institutions and the public in 

complying with sanctions programs and do not constitute a set of 

operational policies and procedures. Accordingly, we consider the 

management response insufficient and the recommendation to be 

unresolved. Pursuant to Treasury Directive 40-03, we plan to refer 

this recommendation to the Treasury Assistant Secretary for 

Management for further action.

3

With respect to the recommendation that a lessons-learned process 

be developed, OFAC agreed this could further assist its mission but 

disagreed that the creation and implementation of such processes 

were the best use of its limited assets at this time. It also stated 

that the recent successes of several of OFAC’s sanctions programs 

underscored the fact that OFAC’s existing feedback and lessonslearned mechanisms are working well. We continue to believe a 

formalized lessons-learned process would benefit OFAC and are 

disappointed that it does not plan to implement a formalized 

process at this time. That said, we consider the recommendation to 

have a management decision and encourage OFAC to adopt a 

formalized lessons-learned process in the future.

Other than the issues discussed above, OFAC’s provided planned 

corrective actions are responsive to the other recommendations in 

this report. OFAC will, however, still need to develop and record in 

the Joint Audit Management Enterprise System (JAMES), the 

 

3 Treasury Directive 40-03, “Treasury Audit Resolution, Follow-Up, and Closure” (February 2, 2001). In 

accordance with this directive, the Treasury Deputy Secretary is responsible for making a final 

management decision on an Office of Inspector General audit recommendation when disagreement 

exists and resolution could not be reach between the Department and our office. Before the actual 

referral of a disagreed recommendation to the Deputy Secretary, the directive calls for the Assistant 

Secretary for Management to assist in resolving the disagreement.
Libyan Sanctions Case Study (OIG-16-001) Page 6

Department’s audit recommendation tracking system, anticipated 

completion dates for those corrective actions.

OFAC’s management response is provided in Appendix 3.

Background

OFAC Mission

Part of Treasury’s Office of Terrorism and Financial Intelligence, 

OFAC’s mission is to administer and enforce economic and trade 

sanctions established under presidential directives or legislative 

actions. OFAC promulgates regulations to implement sanctions 

programs that target foreign countries, regimes, terrorists, 

international narcotics traffickers, those engaged in activities 

related to the proliferation of weapons of mass destruction, and 

other threats to the national security, foreign policy, or the U.S. 

economy. OFAC acts under legislative authority and presidential 

wartime and national emergency powers to impose controls on 

transactions and to block assets under U.S. jurisdiction from use by 

designated parities. Assets blocked under OFAC sanctions 

programs remain unavailable for use until OFAC authorizes the 

release under those programs or when a state of emergency is 

terminated by the President. 

All U.S. persons, as defined by OFAC’s regulations, must comply 

with OFAC regulations requiring the blocking of assets and other 

property and prohibiting financial transactions with or for specified 

countries, entities, and individuals targeted by sanctions programs. 

The success of OFAC’s sanctions programs requires the 

participation and support of financial institutions, which, more than 

any other sector of the economy, are affected by OFAC 

regulations. OFAC is supported by examinations conducted by the 

Federal banking agencies and other cognizant Federal and State 

agencies to help ensure compliance with OFAC regulations.4

 

4 The Federal banking agencies are the Office of the Comptroller of the Currency, Federal Deposit 

Insurance Corporation, Board of Governors of the Federal Reserve System, and the National Credit 

Union Administration. Other Federal financial regulators include the Securities and Exchange 

Commission, the Commodity Futures Trading Commission, and the Internal Revenue Service.
 Libyan Sanctions Case Study (OIG-16-001) Page 7

Libyan Sanctions Program

The President signed EO 13566 on February 25, 2011, declaring a 

national emergency to deal with the unusual and extraordinary 

threat to national security and foreign policy posed by Colonel 

Muammar Qadhafi, his government, and his close associates. The 

EO was issued based on authority granted to the President under 

NEA and IEEPA. Using this authority, property and interests in 

property of the Government of Libya, its agencies, 

instrumentalities, and controlled entities were required to be 

blocked, including the Libyan Investment Authority, and the Central 

Bank of Libya. Also blocked were properties in which Qadhafi, 

members of his family, senior members of his regime, and others 

responsible for the political repression in Libya had an interest. 

Three (3) days after EO 13566 was signed, Treasury announced 

that at least $30 billion in Libyan assets under U.S. jurisdiction had 

been blocked. By November 25, 2011, approximately $38 billion in

Libyan assets were blocked under the program. 

Financial Institutions Identified, Blocked, and Maintained

Libyan Assets

Financial institutions were responsible for identifying, blocking, and 

maintaining assets targeted under the Libyan sanctions program 

and reporting these actions to OFAC through reports of blocked

transactions. OFAC used these reports to account for blocked 

assets when preparing semiannual reports to Congress on the 

status of the Libyan program. The semiannual reports on the Libyan 

sanctions program included information on licenses issued to 

release blocked assets, Specially Designated Nationals designations 

and removals,5 new assets blocked during the reporting period, as 

well as actions taken by the President or those granted authority by 

 

5 OFAC publishes a list of individuals and companies owned or controlled by, or acting for or on behalf 

of, targeted countries; as well as individuals, groups, and entities, such as terrorists and narcotics 

traffickers designated under programs that are not country-specific. Collectively, these individuals 

and entities are called “Specially Designated Nationals.”
Libyan Sanctions Case Study (OIG-16-001) Page 8

the President to carry out the provisions of EO 13566.6Financial 

institutions maintained control over blocked Libyan assets and 

placed them in interest-bearing accounts until authorized for 

release.7

OFAC has the authority to release blocked assets and authorize

transactions that would otherwise be prohibited. OFAC used 

general, specific, and directive licenses to release blocked assets or 

to allow prohibited transactions under the Libyan program. 

 General licenses are regulatory provisions authorizing certain

types of transactions or to release classes of blocked assets.8

Although general licenses are not usually associated with 

specific license applications, general licenses can be issued 

when a high volume of license applications received by OFAC 

relate to similar types of transactions. 

 Specific licenses are used by OFAC to release assets blocked by 

financial institutions identified in reports of blocked transactions

submitted to OFAC. Specific licenses are also used by OFAC to 

authorize transactions usually involving goods or services that 

would otherwise be prohibited. These specific licenses 

frequently would not involve blocked assets and therefore 

would not be linked to reports of blocked transactions. OFAC’s 

Licensing Division reviews applications, often in consultation 

with the State Department, and issues specific licenses 

determined to be consistent with U.S. foreign policy. 

 Directive licenses are used by OFAC to instruct, direct, or 

compel financial institutions to release certain assets in-line with 

U.S. foreign policy decisions. Directive licenses are generally not 

associated with license applications submitted to OFAC.

 

6 The Secretary of the Treasury, in consultation with the Secretary of State, was authorized to take all 

necessary actions and employ all powers granted to the President by IEEPA to carry out the purposes 

of EO 13566. The Secretary of the Treasury re-delegated authority pursuant to EO 13566 to the 

Director of OFAC.

7

 31 C.F.R. § 501.601, Records and Record Keeping Requirements, and 31 C.F.R. § 501.603, Reports 

on Blocked Property, provide instructions for maintaining blocked assets as well as reporting, 

recordkeeping, and records retention.

8 One general license issued under the Libyan program allowed transactions involving banks-owned or 

controlled by the Government of Libya that were organized under the laws of a country other than 

Libya. Another general license allowed for goods or services for diplomatic missions of the 

Government of Libya to the United States and United Nations under certain conditions.
 Libyan Sanctions Case Study (OIG-16-001) Page 9

According to OFAC, directive licenses are used in rare 

circumstances.

Through January 30, 2015, OFAC issued 251 specific licenses that

released Libyan assets identified in license applications or

authorized transactions otherwise prohibited under the Libyan 

Sanctions program. Information on specific licenses issued by 

OFAC was recorded in the OFAC Administrative System for 

Investigations and Sanctions (OASIS). The specific licenses issued 

to release blocked assets were linked in OASIS to reports of 

blocked assets in OFAC’s Automated Blocking and Reject Report 

System (ABaRRS).

9 OFAC also issued 11 general licenses under the 

Libyan program to allow certain types of transactions to be 

completed and categories of blocked assets to be released. The 

general licenses expanded the ability of U.S. entities and individuals

to engage in transactions and dealings with Libyan entities deemed 

to be unaffiliated with the Qadhafi regime. OFAC issued four

directive licenses under the Libyan program requiring that financial 

institutions release funds authorized by the United Nations for 

humanitarian purposes in Libya.

Once OFAC authorizes the release of assets, OFAC’s interest in 

those assets is concluded.

10 Financial institutions engaging in 

transactions pursuant to any OFAC licenses are required to ensure 

that all conditions of the licenses are strictly observed and that 

assets not associated with the licenses are not released. As a 

general rule, OFAC does not follow up with the financial 

institutions to confirm that the assets have been released, the 

conditions of the licenses observed, or to whom the assets were 

released. As it deems necessary, OFAC will follow up on cases 

where it has information that assets may not have been released. 

OFAC officials were unaware of any such issues involving the 

Libyan program. 

 

9

In September 2013, OFAC replaced ABaRRS with a new compliance module housed within the 

OASIS system. Like ABaRRS, the new compliance module was designed to record information 

included in blocked and rejected transaction reports filed by financial institutions under OFAC’s 

sanctions programs.

10 OFAC can include reporting requirements in certain licenses but does not use these reports to track 

the release of blocked assets.
Libyan Sanctions Case Study (OIG-16-001) Page 10

OFAC Eased Sanctions on Libya and Released the 

Majority of Blocked Assets

In July 2011, the United States officially recognized the 

Transitional National Council as the new, legitimate governing 

authority for Libya. In September 2011, the United Nations 

authorized the release of $1.5 billion in assets by the United States

to support humanitarian needs in Libya. In response, OFAC began 

easing sanctions on Libya by authorizing the release of certain 

assets through directive licenses. By December 2011, in 

conjunction with the actions taken by the United Nations, OFAC

had lifted most of the remaining sanctions against Libya, by 

authorizing the release of more than $30 billion in blocked assets, 

including assets of the Libyan government and the Central Bank of 

Libya.11 Approximately $3 billion in assets primarily owned or 

controlled by the Libyan Investment Authority remained blocked. 

See Appendix 2 for a chronology of significant events in the Libyan 

sanctions program.

In February 2012, the President extended EO 13566 for 1 year,

citing conditions in Libya that continued to pose an unusual and 

extraordinary threat to U.S. national security and foreign policy.

The President again extended EO 13566 for 1 year in February 

2013, February 2014, and February 2015.

Findings

Finding 1 Weaknesses Identified in OFAC’s Internal Controls

Our review of OFAC’s Libyan sanctions program identified several 

internal control weaknesses in OFAC’s administration of sanctions 

programs, which were similar to those that we had previously 

reported. OIG audit reports dating back to 1993 found that OFAC 

lacked written standard operating policies and procedures for 

implementing sanctions programs and that OFAC’s record-keeping, 

data-management, and processing procedures could be 

strengthened.

 

11 OFAC’s General License 11, issued December 16, 2011, exempted from release the assets of the 

Libyan Investment Authority and entities owned or controlled by this organization blocked as of 

September 19, 2011.
 Libyan Sanctions Case Study (OIG-16-001) Page 11

OFAC Relies on Prior EOs and Regulations as Policies and 

Procedures

OFAC continued to rely on its collection of prior EOs, regulations, 

published memoranda, and the knowledge and experience of 

existing OFAC staff to serve as policy and procedural guidance 

when implementing and administering new and ongoing sanctions 

programs. OFAC has not reduced to writing standard operating 

procedures for the day-to-day administration of sanctions 

programs. The lack of written standard operating procedures does 

not meet required government-wide internal control standards and

does not serve the agency well.

The Government Accountability Office’s (GAO) “Standards for 

Internal Controls in the Federal Government” call for managers to 

clearly document internal controls and all transactions and other 

significant events in a manner that allows for ready examination. 

The documentation may appear in management directives, 

administrative policies, or operating manuals and may be in paper 

or electronic form. Documentation and records should be properly 

managed and maintained.12 Treasury Directive 80-05 also requires 

all Treasury bureaus and offices establish adequate and proper 

documentation of their functions, policy decisions, procedures, and 

essential transactions in a manner that promotes accountability and 

establishes a historical record.13 Documented procedures would 

provide OFAC staff with the necessary fundamental steps to 

ensure effective implementation of sanctions, minimize differences 

in staff experience and knowledge, and contribute to staff 

development.

OFAC officials stated that it was impractical and unnecessary to 

create standardized policies and procedures because each 

sanctions program is based on a unique set of foreign policy 

imperatives, with no two programs being exactly alike. According 

to the officials, developing rudimentary policies and procedures 

would not be helpful to the office’s efforts. Additionally, changes 

in the administration’s foreign policy pose additional challenges to 

implementation. Furthermore, the EOs signed by the President lay 

 

12 GAO, “Standards for Internal Control in the Federal Government” (November 1999). GAO’s 

September 2014 revision, which becomes effective in 2016, includes similar requirements.

13 Treasury Directive 80-05, “Records and Information Management Program” (June 26, 2002).
Libyan Sanctions Case Study (OIG-16-001) Page 12

out the actions that can and cannot be taken under each sanctions 

program. OFAC did provide us with a PowerPoint document that 

had been prepared for staff and titled ”An Introduction to OFAC,”

that outlined the history of OFAC, the office’s sanctions programs, 

and many of OFAC’s functional areas of responsibility. The OFAC 

officials maintained that this document supplemented the EOs, 

promulgated regulations, and other guidance issued to provide 

sufficient information to OFAC staff to implement and administer 

sanctions programs. 

We recognize the value of past EOs, regulations, and other 

memoranda as resources to use in administering new and ongoing 

sanctions programs. However, we believe that common steps and 

practices in implementing and administering sanctions programs

should be documented. Without such standard operating 

procedures, it is difficult to assess OFACs effectiveness in 

administering its sanctions programs. 

OFAC’s resistance to documenting a set of standard operating 

procedures is contrary to government-wide internal control 

standards and Treasury policy. It is also hard to understand OFAC’s 

position given the importance of its mission to U.S. foreign policy.

OFAC Did Not Actively Assess Financial Institution Compliance 

with the 10-Day Reporting Requirement

OFAC regulations require financial institutions to file a report no 

later than 10 business days from the date the property is blocked 

or the transaction(s) rejected. Reports of blocked and rejected

transactions submitted by financial institutions were processed by 

OFAC compliance officials and loaded into ABaRRS. OFAC, 

however, did not record the date each report was received. We 

found that OFAC did not, as a standard practice, assess the 

timeliness of institution filings to determine compliance with the 

10-day reporting requirement. OFAC officials stated that late filing 

of reports of blocked and rejected transactions had not been a 

concern, and tracking of report receipt dates in ABaRRS was

unnecessary. OFAC relied on a culture of compliance by financial 

institutions and its ability to assess civil money penalties for late 

filings of these reports that come to its attention. 

To assess financial institutions’ compliance with the 10-day 

reporting requirement, we reviewed a sample of 284 reports of 
 Libyan Sanctions Case Study (OIG-16-001) Page 13

blocked and rejected transactions for the Libyan program posted to 

ABaRRS as of July 16, 2012. We found that OFAC did not record 

the report receipt date in ABaRRS, which limited our ability to 

assess the timeliness of the filings.14 We attempted to determine 

the report receipt date using other ABaRRS information. For 175 of 

284 reports reviewed (62 percent), we still could not determine 

through this alternative procedure, the date of receipt. Of the 109 

reports for which we were able to determine the receipt date using 

ABaRRS information, our analysis revealed that 25 reports, or 23 

percent, were received 16 or more days after the action was taken 

by the institutions, and in one case, 273 days after the institution 

took action.15

Following our exit conference, OFAC provided additional 

clarifications with respect to information previously provided for

the 25 reports of blocked transactions cited by the OIG as filed 

late. OFAC noted that the 25 entries in ABaRRS were comprised of 

9 reports filed by institutions.

16 OFAC concluded that 13 of the 25

transactions were reported within the timeframes established by 

OFAC regulations as follows:

 For 10 of the 13 transactions, the financial institution 

attempted to file the reports timely but used an incorrect email address. The reports were not received by OFAC until 

the institutions refiled the information, more than 250 days 

after the assets were blocked.

 In one case, the filing institution placed the assets in a 

suspense account and later determined that the assets were 

a blockable interest. The institution incorrectly reported the 

initial suspension date as the date blocked. 

 OFAC requested follow-up information from one of the filers

to determine the correct date filed. The information provided 

 

14 Similarly, OFAC did not record the date blocking reports were received in the OASIS compliance 

module.

15 We defined compliance with the 10-day reporting requirement as receipt by OFAC within 15 days of 

the action taken by financial institutions to allow for non-business days during the reporting period.

16 Filers can include multiple transactions on reports of blocked transactions. Each transaction is 

entered separately into OFAC’s database since they represent independent blocking actions.
Libyan Sanctions Case Study (OIG-16-001) Page 14

by the institution indicated the transaction was reported 

timely.

 For another transaction, OFAC noted that date of the 

blocking recorded in ABaRRS was incorrect and that the 

report was filed timely.

OFAC acknowledged that the remaining 12 transactions cited by 

the OIG were late filings, reducing the overall percentage of late 

filing identified in our sample to 11 percent.

The fact that OFAC had to research this information after our 

audit, demonstrates the need for written procedures that would 

require, among other things, capturing the date each report is 

received at OFAC. The report receipt date would allow OFAC to

timely assess filer compliance with the 10-day reporting 

requirement and to identify reports filed timely but delayed from 

reaching OFAC or being entered into OFAC’s database. It would 

also give OFAC the ability to timely identify late filers and assess 

civil money penalties, when appropriate.

OFAC Data Management and Processing Procedures Could Be 

Strengthened

OFAC could improve its processes to load reports of blocked and 

rejected transactions, as well as the quality of OASIS compliance 

module data, by developing and implementing a planned electronic 

filing system for high-volume filers and emphasizing electronic filing 

of all reports of blocked and rejected transactions. In addition, 

OFAC’s ability to accurately determine the amount of assets that 

remain blocked under sanctions programs, in a timely manner,

could be enhanced by identifying assets released by type of license 

(general or directive) on records of blocked assets posted in the 

OASIS compliance module.

OFAC Could Improve Data Quality by Promoting Electronic Filing of 

All Reports of Blocked and Rejected Transactions

Treasury Directive 40-04 identifies standards for acceptable levels 

of quality for internal controls. At a minimum, controls should be 

established and maintained over information processing to include 

edit checks of data entered; accounting for transactions in 

numerical sequences; comparison of file totals with control 
 Libyan Sanctions Case Study (OIG-16-001) Page 15

accounts; and control of access to data, files, and programs. 

Monitoring activities should be performed to include routine 

management and supervisory activities, transaction comparisons 

and reconciliations, and other actions to assess the quality of 

performance over time. In June 2012, the Office of Management 

and Budget issued guidance stating that the use of electronic 

communication methods can substantially reduce burdens on 

respondents and simultaneously increase efficiency in data 

collection and processing.17

Financial institutions file reports of blocked and rejected 

transactions with OFAC by email; facsimile; U.S. mail; or for small 

volume filers, through OFAC’s “ABaRRS Lite” electronic filing 

system. Although OFAC developed a standardized reporting format 

for hard-copy report submissions, its use by financial institutions is 

voluntary because OFAC has been reluctant to require the use of 

the standardized report format. OFAC compliance staff analyzed

hard-copy report submissions, interpreted the information provided

by the financial institutions, and manually keyed data into 

ABaRRS.18

We reviewed the 284 reports used to assess the timeliness of 

institutions’ filings under the Libyan program to also assess the 

accuracy of data from blocked and rejected transactions recorded 

in ABaRRS. Approximately 10 percent of the records in our sample

contained one or more entries that were not consistent with 

supporting documentation for certain critical data fields, such as 

the date of the blocking or reject action and the amount of assets 

blocked by the financial institutions.

We also tested all 1,160 blocked and rejected transaction records

in ABaRRS for the Libyan program to determine if duplicate records 

had been posted by OFAC. Our analyses identified 27 duplicate 

report postings, including seven (7) that had not been identified by 

OFAC compliance staff. The remaining 20 duplicate postings had

been identified by OFAC and removed from ABaRRS. OFAC 

officials told us that most duplicate report postings were

 

17 Office of Management and Budget Memorandum, “Reducing Reporting and Paperwork Burdens”

(June 22, 2012).

18

 Similar procedures are used by OFAC to load blocking and reject report data into the OASIS 

compliance module.
Libyan Sanctions Case Study (OIG-16-001) Page 16

attributable to filers submitting reports by both facsimile and U.S.

mail. So, unless the compliance staff person entering a duplicate 

submission was the same individual who entered the original record 

and took note of the issue, the duplicate would be posted. 

OFAC reported that it had initiated work on developing the 

“ABaRRS High Volume” electronic filing system. This system 

would allow high-volume filers to submit, track, and retrieve 

previously filed reports of blocked and rejected transactions to 

facilitate future institution filings. ABaRRS High Volume would 

provide filers with standardized forms for data entry, as well as 

OFAC Compliance staff with the ability to review report data 

entered by financial institutions. However, due to technical 

problems related to the Treasury’s Public Key Infrastructure 

authentication system, OFAC has been unable to implement 

ABaRRS High Volume. 

OFAC’s Ability to Report on Assets Blocked Was Limited

OFAC’s accounting for and reporting of assets blocked was limited 

because assets released by general licenses were not recorded in 

OASIS, and could not be linked to reports of blocked transactions

in ABaRRS or the OASIS compliance module that replaced

ABaRRS. Additionally, directive licenses issued by OFAC, while 

recorded in OASIS, were also not linked to the reports of blocked 

transactions they were intended to release. As a result, determining 

the amount of assets blocked under any sanctions program at any 

given time required research and analysis by OFAC staff, and 

limited OFAC’s responsiveness.

OFAC officials stated that to determine the amount of assets 

blocked under any sanctions program, they use information 

provided in financial institution annual reports of blocked assets. 

OFAC then adds assets blocked subsequent to the annual report 

cutoff dates and subtracts assets released by licenses issued 

subsequent to the cutoff.

We believe that this approach is susceptible to error because OFAC 

does not perform full reconciliations of information included in 

annual reports filed by institutions to its blocked asset and licensing 

data from its internal systems, nor does it ensure that all 

institutions file annual reports as required. 
 Libyan Sanctions Case Study (OIG-16-001) Page 17

Finding 2 OFAC Would Benefit from a Formal Lessons-learned 

Process

OFAC did not have a formal lessons-learned process to 

communicate knowledge gained from past sanctions programs for 

the benefit of future programs. OFAC officials told us that the 

uniqueness of each sanctions program would limit the value of any 

lessons learned and that OFAC does not have the resources to 

conduct such reviews. Nevertheless, we believe OFAC would 

benefit from this process.

OFAC Relies on Staff Experience and Prior Program Documentation 

as Guidance for New Sanctions Programs

At the time of the Libyan sanctions program (or any new sanctions 

program for that matter), OFAC draws on staff experiences and 

documentation generated from previous sanctions programs to

work on the new program. Through these resources, OFAC 

determined what practices might be considered for use in 

implementing new sanctions programs. However, OFAC officials 

told us that they did not conduct reviews at or near the conclusion 

of sanctions programs to identify lessons learned and best 

practices. Officials said that OFAC did not have the resources 

available to write the history of every sanctions program and that 

OFAC’s limited resources were better spent on meeting the needs 

of existing and new sanctions programs. Furthermore, the 

uniqueness of each sanctions program limited the value to be 

gained by any such reviews. We believe that a lessons-learned 

process would assist OFAC in preparing for future sanctions 

programs, as demonstrated by what OFAC currently does when 

faced with a new sanctions program.

OFAC officials characterized the Libyan program as an 

extraordinary success story that involved working with numerous 

foreign and domestic government agencies as well as the 

international community. We agree. The rapid deployment of the 

program resulted in an unprecedented $30 billion in assets blocked 

within 3 days. 

In 2012, GAO issued a report regarding the implementation and 

use of lessons-learned processes to benefit an organization’s future 
Libyan Sanctions Case Study (OIG-16-001) Page 18

actions.19 According to the GAO study, the low occurrence of 

instances or activities serves to increase the need to share the 

lessons learned from those instances. For rare events, the 

experiences and lessons learned by others may be the closest 

many new staff comes to direct experience when similar events 

occur. As time passes, implementing best practices from prior 

experiences becomes more difficult because of employee turnover 

and general lapses in memory.

OFAC’s perspective on lessons-learned reviews also differed from 

the conclusions reached by GAO in a 2004 audit report on the U.S. 

government’s efforts to recover foreign regimes’ assets.20 In that

report, GAO concluded that little evidence was available to 

document the government’s efforts to recover blocked Iraqi assets 

that would help to guide future asset recovery efforts. GAO 

commented that OFAC officials were unable to respond in a timely 

manner when asked for documentation regarding regulations 

previously issued on the freezing and transferring of assets and the 

results of these efforts. GAO recommended the Departments of the 

Treasury and State develop and document a compilation of lessons 

learned from more recent efforts to recover Iraq’s assets that could 

assist in institutionalizing and leveraging all mechanisms available 

for future efforts.

A Lessons-learned Process Would Aid OFAC in the Development 

and Maintenance of Policies and Procedures

OFAC’s sanctions program experiences could be used to develop 

and maintain standard operating policies and procedures for the 

administration of sanctions programs. The acquisition of this 

information from OFAC’s programs, however, constitutes only the 

first of eight steps advocated by GAO in its lessons-learned 

process, shown in Figure 2.

 

19 GAO, Federal Real Property Security: Interagency Security Committee Should Implement a LessonsLearned Process (GAO-12-901; issued September 10, 2012).

20 GAO, Foreign Regimes’ Assets: The United States Faces Challenges in Recovering Assets, but Has 

Mechanisms That Could Guide Future Efforts (GAO-04-1006; issued September 14, 2004).
 Libyan Sanctions Case Study (OIG-16-001) Page 19

Figure 2: GAO’s 8-Step Lessons-learned Process

Source: GAO

We believe that the unique nature of the Libyan program, and other 

OFAC sanctions programs, increases the need to evaluate the 

results of each program, document actions that worked well or 

failed to work, and use the results for the benefit of future 

sanctions programs. Unless OFAC makes a specific effort to retain 

the knowledge and experience learned from past sanctions 

programs, we believe that much of the value from those 

experiences could be lost.

As stated above, officials told us that OFAC did not have the 

resources necessary to write the history of what occurred under 

each sanctions program and that the agency’s limited resources 

were better spent on meeting the needs of existing and new 

sanctions programs. OFAC officials stated that, as a small office 

within Office of Terrorism and Financial Intelligence, OFAC had a 

continual backlog of work. The officials also stated that although 

documenting the success stories of sanctions programs would be 

beneficial, such efforts would require significant resources that 

were not available. GAO’s 2012 study, however, concluded that 

resource limitations should not prevent an organization from 

implementing a lessons-learned process. While such a process can 

take years to fully develop, organizations should start small, do 

what is possible with available resources, build gradually, and 

leverage existing structures and practices. GAO also concluded 

that senior leadership of the organizations need to actively engage 

in lessons-learned efforts and prioritize resources to ensure that 

these lessons are disseminated and reflected in policies and 

procedures. Another study conducted by GAO in 2001 concluded 

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Libyan Sanctions Case Study (OIG-16-001) Page 20

that lessons learned from mishaps or operational events could be 

captured in policy and procedure documents and distributed to 

staff through periodic updates.

21

We believe that a lessons-learned process, conducted at an 

appropriate time for each sanctions program, would enable OFAC 

to capture and convert knowledge acquired from sanctions 

programs and aid in the development and maintenance of up-todate standard operating policy and procedures. Without conducting 

lessons-learned reviews, OFAC lacks a viable way of identifying 

strengths and weaknesses in the administration of sanctions 

programs and could miss valuable opportunities to improve its 

effectiveness and efficiency.

Recommendations

We recommend that the Director of OFAC:

1. Identify the actions required to implement and administer its 

sanctions programs and document these in written standard 

operating procedures. The standard operating procedures should 

provide sufficient information to key staff members to enable 

them to complete the fundamental steps necessary in 

implementing and administering sanctions programs.

Management Response

OFAC already has a wealth of existing documents that provide 

the information necessary for staff to implement and administer 

sanctions programs. These documents include executive orders, 

statutes, Federal Register Notices, the Code of Federal 

Regulations, general licenses, published guidance, interpretative 

guidance, advisories, directives, frequently asked questions, 

power point presentations, and division-specific protocols. In 

addition, through the issuance of specific licenses and individual 

letters of interpretive guidance, the Licensing Division has 

created a body of case work that OFAC staff may access 

through the OASIS electronic databased to assist in sanctions 

implementation and administration. 

 

21 GAO, Survey of NASA’s Lessons Learned Process, (GAO-01-1015R; issued September 5, 2001).
 Libyan Sanctions Case Study (OIG-16-001) Page 21

OIG Comment

We believe the documents cited by OFAC do not constitute a

set of standard operating procedures for the implementation and 

day-to-day administration of OFAC’s sanction’s programs. While 

the documents and information cited by OFAC serve as valuable 

reference materials for staff, much of this documentation is 

directed towards filing institutions and the public. 

We consider the management response insufficient and the 

recommendation to be unresolved. In accordance with Treasury 

Directive 40-03, we plan to refer this matter to Treasury’s 

Assistant Secretary for Management for further action.

2. As part of the standard operating procedures developed in 

response to Recommendation 1, implement procedures and any 

necessary system modifications to allow for tracking and 

periodic analysis of financial institutions’ compliance with the 

10-day reporting requirement and to take appropriate action 

against late-filers.

Management Response

In an upcoming maintenance release, OFAC is adding a field in 

the Compliance module in OASIS to include the date on which 

an institution filed an initial report of blocked property. This will 

enable OFAC to run reports and identify filers reporting outside 

the required 10-day timeframe.

OIG Comment

We believe the planned corrective action to add the date field to 

OASIS and thus allowing for reports that identify late-filers 

meets the intent of the recommendation. However, it is 

important that OFAC develop the requisite policies and 

procedures to assign responsibilities, timeframes, and the like 

for running the reports and acting on instances of 

noncompliance with filing requirements. OFAC will also need to 

develop and record in the JAMES the anticipated completion 

date for its corrective action.
Libyan Sanctions Case Study (OIG-16-001) Page 22

3. Implement a methodology to identify blocked assets that have

been released by license type (general or directive). 

Management Response

OFAC is considering requiring an additional report to be filed 

when property is unblocked pursuant to a general license. This 

would supplement the Annual Report of Blocked Property, 

which provides a yearly census of blocked property held at a 

given institution as of June 30 of the reporting year.

OIG Comment

OFAC’s proposed action meets the intent of our

recommendation. OFAC will need to develop and record in the 

JAMES the anticipated completion date for this corrective 

action.

4. Continue to pursue development and implementation of 

electronic filing for high-volume filers.

Management Response

OFAC has continued to explore mechanisms for electronic filing 

of blocking and reject reports, and remains committed to 

providing an electronic filing solution that meets the needs of 

the majority of filers. OFAC intends to continue this 

development work in fiscal year 2016.

OIG Comment

OFAC’s commitment as stated meets the intent of our 

recommendation. OFAC will need to develop and record in the 

JAMES the anticipated completion date for this corrective 

action.

5. Develop a lessons-learned process to capture and communicate

acquired knowledge from past sanctions programs at a time 

appropriate for each sanctions program.
 Libyan Sanctions Case Study (OIG-16-001) Page 23

Management Response

Although OFAC agrees that additional lessons-learned processes 

could further assist its mission, OFAC disagrees that the 

creation and implementation of these additional processes are 

the best uses of its limited resources at this time given the 

significant demands of current national emergencies requiring 

major sanctions-related activity. The recent successes of several

of OFAC’s sanctions programs underscore that OFAC’s existing 

feedback and lessons-learned mechanisms are working well.

OIG Comment

We consider the recommendation to have a management 

decision. However, we continue to believe that OFAC would 

benefit from a formalized lessons-learned process and 

encourage OFAC to adopt such a process in the future as its 

sanctions activity levels off.

* * * * * *

We appreciate the cooperation and courtesies extended to our staff 

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

contact me at (617) 223-8638 or Kenneth Dion, Audit Manager, at 

(617) 223-8641. Major contributors to this report are listed in

Appendix 4.

/s/

Sharon Torosian

Director
Appendix 1: Objectives, Scope, and Methodology

Libyan Sanctions Case Study (OIG-16-001) Page 24

Appendix 1: Objectives, Scope, and Methodology

The objectives of our audit of the Office of Foreign Assets 

Control’s (OFAC) implementation and administration of the Libyan 

sanctions program were to (1) determine the legal authorities for 

the Libyan sanctions program; (2) determine how blocked assets 

were identified, maintained, and accounted for; and (3) assess 

OFAC’s subsequent and gradual release of blocked Libyan assets. 

We also inquired about how OFAC planned to identify and release 

all remaining blocked assets to their rightful owners upon 

termination of the sanctions program.

To accomplish our objectives, we identified the legal authorities 

used by the President to declare a national emergency, issue 

Executive Order 13566 blocking Libyan assets, and provide the

framework for the Libyan sanctions program. We reviewed laws, 

regulations, and guidance associated with the Libyan program as 

well as OFAC information and documentation related to the 

implementation and administration of this program. 

We interviewed OFAC officials responsible for implementing and 

administering the Libyan program, including officials from OFAC’s

Office of Resource Management, Office of Global Targeting, and 

Office of Program Policy and Implementation at its Washington, 

D.C., headquarters. During these interviews, we obtained an 

understanding of OFAC’s processes in implementing and 

administering the Libyan program as well as OFAC’s general 

practices and procedures used for all sanctions programs. 

We obtained data extracts from OFAC’s Automated Blocking and 

Reject Report System (ABaRRS) and the OFAC Administrative 

System for Investigations and Sanctions (OASIS). The extract files 

included 1,160 reports of blocked and rejected transactions posted 

to ABaRRS as of July 16, 2012, and 932 applications for specific 

licenses and license amendments associated with the Libyan

program posted to OASIS as of June 11, 2012. We assessed the 

reliability of the data provided by OFAC by reconciling this 

information to internal reports generated from the OFAC systems 

and other supporting documentation.

We reviewed 284 blocking and reject reports entered into ABaRRS 

more than 30 days from the bank action date to assess financial 
Appendix 1: Objectives, Scope, and Methodology

 Libyan Sanctions Case Study (OIG-16-001) Page 25

institution compliance with the 10-day reporting requirement.22 As 

part of this analysis, we reviewed online ABaRRS information and

financial institution source documents loaded into ABaRRS.

The sample of 284 blocking reports was also used to assess the 

accuracy of critical data fields in ABaRRS and assess OFAC’s 

procedures to process and load data from reports of blocked and 

rejected transactions to ABaRRS. To test for duplicate ABaRRS 

postings, we evaluated data from all 1,160 reports of blocked and 

rejected transactions for the Libyan sanctions program provided by 

OFAC. We defined duplicate ABaRRS postings as records that 

contained the same values in critical data fields, which indicated 

the information was entered more than once by OFAC staff.

We performed our fieldwork from March 2012 to January 2013.

We updated information included in this report in December 2014. 

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.

 

22 The ABaRRS bank action date reflects the date on which a financial institution took action to block 

assets or reject transactions. The institutions report these dates to OFAC on blocking and reject 

reports. 
Appendix 2: Chronology of Significant Events

Libyan Sanctions Case Study (OIG-16-001) Page 26

Appendix 2: Chronology of Significant Events

The following chronology describes significant events in the history 

of Libyan sanctions program administered by the Office of Foreign 

Assets Control (OFAC).

February 25, 2011 The President signs Executive Order (EO) 

13566, imposing sanctions on Colonel Muammar Qadhafi, his close 

associates, and the Libyan government. OFAC establishes the 

Libyan sanctions program and issues General License No. 1,

authorizing transactions involving financial institutions owned or 

controlled by the Government of Libya organized under the laws of 

countries other than Libya.

February 26, 2011 The United Nations imposes sanctions on 

Qadhafi and his inner circle of advisors.

March 1, 2011 OFAC issues General License No. 2, authorizing 

goods or services for Libyan diplomatic missions in the United 

States.

March 2, 2011 EO 13566 is published in the Federal Register.

March 4, 2011: OFAC issues General License No. 1A, superseding 

General License No. 1 and clarifying the scope of the authorized 

transactions to third-country, Libyan-owned or controlled financial 

institutions.

March 9, 2011 OFAC issues General License No. 3, authorizing 

certain legal services on behalf of the Government of Libya or any 

other persons whose property and interests in property are 

blocked. 

April 8, 2011 OFAC issues General License No. 4, providing 

guidance and authorizing investment of assets in which there is a 

blocked, non-controlling, minority interest of the Government of 

Libya.

April 26, 2011 OFAC issues General License No. 5, authorizing 

U.S. persons to engage in transactions with Qatar Petroleum or the 

Vitol group related to oil, gas, or petroleum products exported from 

Libya.

July 1, 2011 OFAC issues interim regulations under 31 C.F.R. 570, 

Libyan Sanctions Regulations, to implement EO 13566 and provide 

general guidance to the public.
Appendix 2: Chronology of Significant Events

 Libyan Sanctions Case Study (OIG-16-001) Page 27

July 15, 2011 The United States formally recognizes the 

Transitional National Council as Libya’s legitimate government.

August 19, 2011 OFAC issues General License No. 6, authorizing

transactions with the Transitional National Council.

September 1, 2011 OFAC directs the release of $1.5 billion in 

assets to help the Transitional National Council restore vital 

services and initiate rebuilding efforts.

September 9, 2011 OFAC issues General License No. 7,

authorizing U.S. persons to engage in transactions involving 

entities owned or controlled by the Libyan National Oil Corporation.

September 19, 2011 OFAC issues General License No. 8,

authorizing U.S. persons to engage in transactions involving the 

Government of Libya and Central Bank of Libya, provided that all 

property and interests of these parties blocked as of September 19, 

2011, remain blocked.

OFAC issues General License No. 7a, superseding General License 

No. 7, to unblock all property and interests in property of the 

Libyan National Oil Corporation.

September 23, 2011 OFAC issues General License No. 8A,

superseding General License No. 8, authorizing transactions 

involving the Government of Libya and Central Bank of Libya. All

assets, including cash, securities, bank accounts, investment 

accounts, and precious metals remain blocked.

November 18, 2011 OFAC issues General License No. 9,

unblocking all assets of the General National Maritime Transport 

Company.

November 25, 2011 Approximately $38 billion in Libyan assets had 

been blocked as of this date.

December 1, 2011 OFAC issues General License No. 10,

unblocking all property and interests in property of the Arab 

Turkish Bank and North African International Bank.

December 16, 2011 OFAC issues General License No. 11,

unblocking all property and interests in property of the Government 

of Libya, its agencies, instrumentalities, and controlled entities, as 

well as and the Central Bank of Libya. Approximately $3 billion in 
Appendix 2: Chronology of Significant Events

Libyan Sanctions Case Study (OIG-16-001) Page 28

funds owned and controlled by the Libyan Investment Authority 

blocked as of September 19, 2011, remain blocked. 

February 23, 2012 The President continues the national emergency 

declared in EO 13566 with respect to Libya for 1 year. 

February 13, 2013 The President continues the national emergency 

declared in EO 13566 with respect to Libya for 1 year.

February 20, 2014 The President continues the national emergency 

declared in EO 13566 with respect to Libya for 1 year.

February 23, 2015 The President continues the national emergency 

declared in EO 13566 with respect to Libya for 1 year.
Appendix 3: Management Comments

 Libyan Sanctions Case Study (OIG-16-001) Page 29

Appendix 3: Management Comments
Appendix 3: Management Comments

Libyan Sanctions Case Study (OIG-16-001) Page 30
Appendix 4: Major Contributors to This Report

 Libyan Sanctions Case Study (OIG-16-001) Page 31

Appendix 4: Major Contributors to This Report

Kenneth Dion, Audit Manager 

Lisa Ginn, Audit Manager

Jeanne DiFruscia, Auditor-in-Charge 

Jason Madden, Auditor 

Patrick Arnold, Auditor 

Fawntrella Thompson, Referencer
Appendix 5: Report Distribution

Libyan Sanctions Case Study (OIG-16-001) Page 32

Appendix 5: Report Distribution

The Department of the Treasury

Deputy Secretary

Under Secretary for Terrorism and Financial Intelligence 

Office of Strategic Planning and Performance Management 

Office of the Deputy Chief Financial Officer, Risk and Control

 Group

Office of Foreign Assets Control

Director

Senior Advisor for Legislative Affairs

Office of Management and Budget

OIG Budget Examiner