Office of Inspector General

U.S. International Development Finance Corporation

Semiannual Report to Congress

April 1, 2023— September 30, 2023
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 2

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Message from the Inspector General

I am pleased to present the U.S. International Development Finance 

Corporation (DFC), Office of Inspector General’s (OIG) Semiannual 

Report to Congress for the reporting period of April 1, 2023, through 

September 30, 2023, in accordance with the Inspector General Act of 

1978, as amended (IG Act). DFC OIG is an independent and objective 

oversight office created within DFC by the Better Utilization of 

Investments Leading to Development Act of 2018 (BUILD Act). In 

accordance with the IG Act, we conduct audits and investigations of DFC 

programs and operations to prevent, detect, and deter fraud, waste, and 

abuse. DFC OIG has grown to 13 full-time staff since I started as 

Inspector General in August 2020.

Currently, our audit planning prioritizes mandatory audits, congressional requests, and risks identified 

in our prior audit work. During this reporting period, our Office of Audits issued two mandatory audit 

reports: DFC’s compliance with the Payment Integrity Information Act of 2019 in FY 2022 and DFC’s 

FY 2022 Charge Card Program Audit. 

During the reporting period, we had an additional three audits in progress. These included an audit of 

DFC’s financial statements, DFC’s compliance with the Federal Information Security Modernization 

Act (FISMA), and a performance audit of DFC-funded renewable energy and microfinancing 

investments in India. The latter two are substantially complete and the draft report of the audits have 

been provided to DFC. We are particularly pleased with the FISMA audit results because we found 

marked improvement in DFC’s information security program from last year. 

Our job at the OIG is to be tough, but fair, in evaluating DFC’s operations and programs. Making 

positive change at DFC starts with agreement on actionable and reasonable recommendations for

practical improvements and solutions. The FISMA audit is a great example where DFC took action on 

audit recommendations that led to significant improvements in its information security program. 

Another great example of positive change through our oversight is the audit of DFC’s investments in 

India. In that audit, we found that DFC waived its environmental and social standards for a project. We 

also found that DFC lacked strategic level objectives, plans, and measurable goals for project site visit 

monitoring to assess if the project met both financial goals and development impact as intended. We 

reached an agreement with DFC on recommendations to address these issues. The U.S. Senate 

Committee on Appropriations has proposed language for DFC in the FY 2024 State, Foreign Operations, 

and Related Programs appropriations bill that would require any waiver of environmental and social 

standards to be reported to Congress and limited to compelling circumstances and that DFC must submit 

a detailed plan for its staffing and expenditures on monitoring and evaluation to the Committee. We 

look forward to publishing both of these audit reports in early FY 2024. 

Our Office of Investigations completed several investigations during this reporting period, including a

joint investigation with USAID OIG that resulted in a cost avoidance of $41 million and a referral to 

DFC for suspension and debarment (our first such referral). The investigation found that a DFC project 

sponsor falsified financial statements submitted to DFC in connection with its loan application.
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 4

We continue to rely on partners such as USAID OIG to assist us with our investigative caseload because 

we still lack much-needed law enforcement authority. Our request for this fundamental OIG authority 

has been pending at the Attorney General’s office since December 2020. At the end of this reporting 

period, we had seven open investigations, including one referral to foreign authorities for prosecution. 

We issued two Reports of Investigation to DFC management: one related to fraud by a DFC project 

sponsor and the other related to misconduct and whistleblower reprisal by a senior official. 

In the past six months we have also conducted extensive outreach to advance our oversight mission, 

including: 

• On June 6, 2023, in collaboration with DFC, issuing a management advisory titled “Key 

Considerations to Inform DFC's Response in Ukraine” to proactively protect DFC’s 

investments as it works to mobilize well over $1 billion in private sector capital to support the 

economy and people of Ukraine.

• On June 14, 2023, providing written testimony1 to the U.S. Senate Committee on 

Appropriations, Subcommittee on State, Foreign Operations and Related Programs hearing, 

“Enhancing American Competitiveness Through the US International Development Finance 

Corporation.” 

• Participating in the Ukraine Oversight Interagency Working Group and coordinating with other 

OIGs to prepare for oversight of DFC-financed investments in Ukraine. As a result of this 

effort, the Council of the Inspectors General on Integrity and Efficiency (CIGIE) will recognize 

the working group with an Award for Excellence. This award recognizes the strong interagency 

collaboration among the many participating federal and military services oversight agencies to 

ensure a comprehensive and cohesive, whole-of-government approach to oversight of the U.S. 

Government’s response to the full-scale Russian invasion of Ukraine.

• Investigating multiple whistleblower complaints, including a whistleblower reprisal complaint 

that we referred to the Office of Special Counsel.

• Successfully passing a Quality Assurance Review by CIGIE that noted no deficiencies in our 

oversight of audits conducted by our Independent Public Accountants.2

• Continuing to establish international anti-fraud and anti-corruption partnerships, including 

executing Memoranda of Agreement with Export-Import Bank OIG and components of the 

World Bank. 

• Engaging our congressional and industry stakeholders, as well as DFC’s Board of Directors, 

on our current and future audit and investigative work. 

Additionally, after only three years as an OIG, we are reporting a positive return on investment. In the 

federal accountability community, the most quantifiable metric of oversight performance is return on 

1 Inspector General Zakel's Written Testimony for the Record, June 14, 2023 2 Federal Trade Commission Office of Inspector General Peer Review Results
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 5

investment, which is calculated as a ratio of funds appropriated for our office against savings generated 

through our audits and investigations, including court-ordered fines, restitutions, recoveries, forfeitures, 

recoveries of improper payments, recommended cost savings, recommendations for funds put to better 

use, and questioned costs. Due to the joint investigation highlighted above (and described in more detail 

in this report), our office helped DFC avoid the disbursement of $41 million to an unscrupulous 

business. As a result, DFC OIG’s return on investment ratio for FY 2023 is more than 7 to 1. 

DFC OIG is providing meaningful oversight of U.S. foreign financial assistance through DFC’s 

investments and programs worldwide. I appreciate the dedication, passion, and subject matter expertise 

of our small, but growing, workforce. As we look forward to FY 2024, we will continue to address new 

vulnerabilities and challenges, and will consult with Congress, our Board of Directors, OMB, and other 

stakeholders to improve our oversight efforts. Our work matters more than ever, and I look forward to 

engaging with DFC, our Board of Directors, and Congress to share insights about DFC’s investments 

and projects through the results of our audits and investigations. 

Sincerely,

Anthony “Tony” Zakel 

Inspector General 

FY 2023

$1 Billion 

Enacted Budget

+600 FTEs 

FY 2023

$5.583 Million 

Enacted Budget

13 FTEs

$7 for every appropriated dollar 

– achieving a return on investment with just a fraction of DFC’s total 

workforce and budget.

Return on Investment

Financial Impact of a DFC OIG Investigation: 

$41 Million Cost Avoidance 

At the end of FY 2023, 

DFC’s Portfolio was almost $40 Billion 
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 6

U.S. International Development Finance Corporation

Office of Inspector General

Our Mission

The U.S. International Development Finance Corporation (DFC), Office of Inspector General’s (OIG) 

mission is to prevent, detect, and deter fraud, waste, and abuse in DFC’s programs and operations around 

the world by conducting audits, investigations, inspections, and evaluations of DFC’s projects, systems, 

employees, and contractors. 

Our Core Values

The OIG commits to carrying out its mission in accordance with the following values: 

Accountability

Is the heart of the OIG’s work. We provide accountability 

through independent and fair audits and investigations that seek to ensure that DFC is accountable for its 

results and the resources 

the public invests into it.

Integrity

Is the OIG’s foundation. The OIG maintains the highest standards of integrity for the American people, 

Congress, the DFC Board of Directors, Chief Executive Officer, and senior officials, and strives to set the 

example for objectivity, accuracy, and transparency. 

Respect

Is central to the OIG’s identity. We have a deep respect for DFC’s mission, and we strive to promote a fair 

and professional work environment to maintain the highest standards of conduct. 
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 7

Contents

Message from the Inspector General ........................................3

About DFC OIG..........................................................................8

DFC OIG Hotline .....................................................................10

Top Management Challenges Facing DFC in FY 2024.............11

Office of Audits.......................................................................14

Office of Investigations...........................................................17

Outreach and Other Activities ................................................23

Appendix A: Required Reporting............................................28

Appendix B: Audit Tables .......................................................30

Appendix C: Metrics for Audit Reporting ...............................32

Appendix D: Metrics for Investigative Reporting ...................33

Appendix E: Acronyms, Definitions, DFC Products ................37
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 8

About DFC OIG

Photo 1: DFC committed a $150 million loan to Yilport Terminal Operations S.A. to finance the expansion and 

modernization of the Puerto Bolivar container port in Ecuador’s El Oro province.

DFC OIG was established by the BUILD Act (Public Law 115-254) and gets its authority from the IG 

Act. The OIG was organized in August 2020 following the appointment of its first Inspector General

and was created to promote the integrity, transparency, and efficiency of DFC programs and operations. 

Through its audits and investigations, the OIG prevents, detects, and deters fraud, waste, and abuse 

affecting DFC’s investments, projects, systems, employees, and contractors. DFC is America’s 

development finance institution and offers debt financing, equity investments, feasibility studies, 

investment funds, political risk insurance, and technical assistance. DFC partners with the private sector 

on projects across sectors including energy, healthcare, critical infrastructure, and technology. In 

addition, DFC currently has an active portfolio in Africa, the Middle East, Latin America and the 

Caribbean, Indo-Pacific, and Europe. The European Energy Security and Diversification Act of 2019 

also authorizes DFC to support certain energy and energy-related investments in eligible European and 

Eurasian countries without regard to host-country income classification. See www.dfc.gov and 

Appendix E to learn more about DFC products. 

DFC’s investments include commitments of over $9.1 billion (above FY 2022’s $7.4 billion) and a 

portfolio of almost $40 billion in FY 2023.3 DFC has active exposure in more than 110 countries4 and 

investments are expected to grow in the coming years. DFC funds are flowing quickly, with urgency to 

mobilize private capital to meet U.S. strategic and foreign policy objectives in economies that may not 

have adequate safeguards to address fraud and corruption. 

3 DFC Press Release, DFC Makes More than $9.1 Billion in Financial Commitments for FY 2023, October 5, 2023 4 DFC FY 2022 Annual Report 
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 9

DFC has an important mission that benefits many people around the world. Accordingly, it is imperative 

that DFC OIG continue to build an effective and efficient oversight agency. DFC OIG is one of the 

smallest of more than 70 federal Offices of Inspector General and is leanly staffed. The DFC Inspector 

General is appointed by and reports to the DFC Board of Directors. Although the OIG is located within 

DFC, it conducts its work within the framework of the IG Act and independently of DFC. The OIG 

consists of the Office of Audits and the Office of Investigations, supported by the General Counsel. 

The Office of Audits conducts a variety of independent statutorily mandated and discretionary audits 

of DFC programs and operations and makes recommendations addressing internal control weaknesses. 

The Office of Investigations conducts inquiries and investigations into allegations of fraud, 

misconduct, corruption, and other illegal activity, which may result in criminal convictions, fines, or 

other sanctions. 

The General Counsel provides legal support for audit and investigative work and oversees matters 

involving legislative and public affairs efforts, ethics, and Freedom of Information Act (FOIA) requests. 

DFC OIG Administrative and Operational Activity

The OIG has made significant strides toward building an organization with the expertise, tools, 

resources, and support needed to accomplish its mission. The OIG’s administrative and operational 

efforts provide critical tools that support our audit and investigative work. During this reporting period, 

OIG administrative and operational activities included increasing the staff to 13 FTEs. 

The OIG publishes all audit reports on its website: www.dfc.gov/oig. There you will find information 

about our mission and vision, as well as how to contact the DFC OIG Hotline. In addition to audit 

reports, the OIG also publishes semiannual reports to Congress, written and oral testimonies to 

Congress, press releases, open audit recommendations, and strategic plans. 

www.dfc.gov/oig 
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 10

DFC OIG Hotline

Report Fraud, Waste, and Abuse

OIG’s confidential hotline receives allegations of fraud, waste, abuse, and other misconduct.

o Federal employees must disclose fraud, waste, abuse, and corruption to appropriate 

authorities, such as the OIG.

o Contractors and recipients of U.S. funds must report allegations of fraud and 

misconduct based on mandatory disclosure requirements in Federal and agencyspecific rules.

o Others, including beneficiaries of investment programs and employees of federal 

contractors and recipients, may report allegations to the OIG directly. 
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 11

Top Management Challenges Facing DFC in FY 2024

As required by the Reports Consolidation Act of 2000 (Public Law 106-531), DFC OIG published, Top 

Management Challenges Facing DFC in FY 2024, which discusses four challenges facing DFC that we expect 

will continue over the next several years.

1. Improve Monitoring and Evaluating Actual Development Impact. Project monitoring and 

measuring actual development impact are continued areas of improvement for DFC. Effectively 

measuring development impact is critical to ensuring DFC meets the intended purpose of its 

investments. The BUILD Act requires DFC to develop standards and methods for ensuring development 

performance, including measurement of the projected and actual development impact of a project. DFC 

must continue to take action to ensure actual development impact is measured. 

2. Balance Heightened Expectations of Congress and Stakeholders. DFC has many stakeholders, in 

the United States and around the world, who are interested in what it does and how it achieves its goals. 

Under the BUILD Act, when evaluating development projects, DFC must consider factors relating to 

environmental and social impact, worker rights, and human rights, among other considerations. DFC 

faces difficult choices in making investments that balance the competing interests of development 

impact, foreign policy, and financial performance. Finding the proper balance between these competing 

priorities presents a significant challenge. DFC OIG believes DFC will face significant challenges in 

the constantly evolving global environment to advance development through its investments while 

meeting the expectations of Congress and other stakeholders. 

3. Improve Performance Management, Traceability, Accuracy, and Availability of Project Data as 

DFC’s Commitments Grow. While Managing Reputational Risks. DFC needs to improve performance 

management, traceability, accuracy, and availability of project data as its commitments grow. The 

BUILD Act requires DFC to assess the development performance of its portfolio. A weakness in this 

area is that DFC does not have formal procedures for the systematic collection and storing of 

documentation from site visits, which inhibits enterprise level tracking against strategic goals. 

4. Maintain Efficient Growth and Development. Maintaining efficient growth and development has 

been a challenge for DFC since its inception. Now that DFC has a Chief Executive Officer (CEO), 

Deputy CEO, Chief Risk Officer (CRO), and Chief Development Officer (CDO), DFC has the 

leadership capability to make major improvements in this area. In many ways, DFC is still a new 

organization and accordingly, DFC OIG has identified efficient growth and development as a top 

management challenge for the past three years. This challenge is a significant element in DFC’s plan to 

ensure it efficiently and effectively accomplishes its goals and objectives. This plan should include 

building a mission-critical workforce, developing an ideal organization structure, growing its support 

staff, and managing potential budgetary constraints. 

The OIG previously published Top Management Challenges Facing DFC in FY 2023, which can be found on 

the DFC OIG website, www.dfc.gov/oig. 
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Audits

Investigations

&

Other Outreach
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Office of Audits 

The Office of Audits (OA) conducts and supervises a 

variety of independent statutorily mandated and 

discretionary performance audits assessing controls of 

DFC programs and operations to detect and deter waste, 

fraud, abuse, and mismanagement. Audits include 

evaluating the efficiency and effectiveness of DFC 

development finance investment programs and operations 

at headquarters and around the world. These audits lead to 

recommendations that may result in policy and 

programmatic changes to help DFC better accomplish its 

mission. 

Audit Activity

During the reporting period, April 1, 2023 – September

30, 2023, OA completed two audits, issued a management 

advisory, and had three audits in progress. The box on the 

right provides a summary of audit statistics followed by a

summary of completed audit report findings and 

recommendations below. Each audit report summary 

includes a link to the report located on the OIG’s external 

website. Appendix B provides additional statistical 

details, and Appendix C provides the definitions for audit 

metrics. For transparency, OIG audit reports (and other 

publications) are posted on our external website: 

https://www.dfc.gov/oig. 

Audit Report Summaries

April 1, 2023 – September 30, 2023

Report Title DFC Implemented an Effective Charge Card Program Fiscal Year 2022 

(Audit Report DFC-23-003-C, Issued April 5, 2023)

What We Reviewed OIG contracted with the independent public accounting firm RMA 

Associates, LLC (RMA) to audit DFC’s charge card program in accordance 

with Government Charge Card Abuse Prevention Act of 2012 (Charge Card 

Act). The Charge Card Act requires the OIG conduct periodic reviews of 

DFC’s charge card program for illegal, improper, or erroneous transactions to 

prevent fraud, delinquency, or misuse.

What We Found RMA determined DFC has effectively developed and implemented policies 

and procedures for its charge card program. RMA concluded that based on 

the review results and sample testing, the next audit of the charge card 

program should be in FY 2025 to audit FY 2024 transactions. There were no 

findings for the FY 2022 audit, all prior year recommendations were closed, 

and no material differences were identified.

Recommendations None

Audits Completed: 2

Recommendations: 1 

Audits In Progress: 3 

Recommendations Closed: 6

Opened / Unresolved 

Recommendations: 12

SUMMARY OF AUDIT 

STATISTICS

APRIL 1, 2023 – SEPTEMBER 30, 2023
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 15

Report Title Management Advisory – Key Considerations to Inform DFC’s Response 

in Ukraine (Report Number DFC-23-001-MA, Issued June 6, 2023)

Why We Reviewed This management advisory highlights key considerations for DFC’s evolving 

response to the war in Ukraine. While current efforts have focused on muchneeded humanitarian and military assistance, DFC will likely have a critical 

role in the U.S. response to the post-war reconstruction. DFC and the United 

States Agency of International Development (USAID) signed a 

Memorandum of Understanding with the Government of Ukraine to support 

attracting investments to Ukraine to address the country’s urgent 

development priorities and economic recovery. Continued due diligence will 

help ensure DFC uses any existing and future influx of funding for Ukraine 

effectively, efficiently, and with appropriate management. The advisory

serves to raise awareness and to urge DFC to incorporate lessons learned 

from project monitoring efforts that protect program integrity.

Key Considerations Enhance due diligence steps to address risks, prevent fraud, and clearly 

define project goals prior to funding commitments. 

1. Coordinate with stakeholders to align projects with U.S. foreign 

policy and national security goals. 

2. Emphasize transparency and social safeguards as well as 

environmental impact in commitments with project sponsors. 

3. Establish strong controls to prevent financial support to prohibited 

entities and individuals. 

4. Identify and assess fraud risks per GAO Leading Practices and 

document how DFC will respond to fraud. Incorporate lessons 

learned in project monitoring and evaluation. 

Incorporate lessons learned in project monitoring and evaluation. 

1. Establish sound monitoring and evaluation policies that result in 

sound monitoring and evaluation practices. 

2. Assess development outcomes and measure development impact 

across DFC’s Ukraine portfolio. 

3. Recognize that third-party monitoring can help address site access 

challenges but has limitations. 

4. Allocate sufficient DFC staff and resources to manage and oversee 

DFC-supported projects. 

Report Title Compliance with Payment Integrity Information Act of 2019 (PIIA) 

Requirement in Fiscal Year 2022 (Report Number DFC-23-004-C, Issued 

July 11, 2023)

What We Reviewed OIG contracted with RMA to review DFC’s compliance with the Payment 

Integrity Information Act of 2019 (PIIA) for fiscal year ending September 30, 

2022, and to review DFC’s risk assessment process and efforts in preventing 

and reducing improper payments (IP) and unknown payments (UP). 

What We Found The audit determined DFC (1) complied with PIIA requirements and

performed risk assessments using required criteria defined by OMB Circular 

A-123, and (2) conformed to OMB guidance for preventing and reducing IPs 
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 16

and UPs. However, DFC did not respond to the Office of Management and 

Budget’s (OMB) Annual Data Call for FY 2022. 

Recommendation One recommendation was made for DFC to respond to OMB’s Annual Data

Call as required and update its procedures to include steps to verify PIIA 

requirements through annual communication with OMB.

Significant Audits in Progress

The Office of Audits has three significant audits in progress. The first is an audit of DFC’s renewable 

energy and microfinancing investments in India.5

 The objectives of the audit are to: 

• Determine if DFC involved the U.S. private sector and supported local country development in 

alignment with its mission;

• Assess the inputs, data, and analyses used to assess and approve the projects; and 

• Assess the process and internal controls DFC used to identify and mitigate certain risks.

The second audit in progress is DFC’s compliance with the Federal Information Security Modernization 

Act of 2014 (FISMA) in FY 2023. FISMA requires OIGs to conduct an annual evaluation of their 

respective agency’s information security program and practices. The results are reported to OMB. The 

scope of this audit is to conduct an independent evaluation of DFC’s information security program using 

the metrics identified by the Department of Homeland Security to determine its practices and their 

effectiveness. The OIG has contracted with an independent accounting firm to complete DFC’s FISMA 

audit. The OIG will coordinate the transmittal of the audit firm’s findings to DFC management, ensure 

the scope of the audit is appropriate, and that deliverables are met with timeliness.

The third audit is of DFC’s Consolidated Financial Statements for FY 2023. Executive branch agencies 

are required to complete annual financial statements and obtain annual audits in accordance with 

generally accepted government auditing standards (GAGAS) and the Financial Audit Manual, both 

issued by the Government Accountability Office; OMB Bulletin No.22-01, Audit Requirements for the 

Federal Financial Statements; and generally accepted auditing standards (GAAS). OIG has contracted 

with an independent accounting firm to audit DFC’s financial statements, internal controls over financial 

reporting, and compliance with laws and regulations relating to the determination of financial statement 

amounts. The OIG will coordinate the transmittal of the audit firm’s opinion to DFC management, 

ensure the scope of the audit is appropriate, and that deliverables are met with timeliness. 

During this reporting period, the OIG’s Office of Audit successfully passed a 

Quality Assurance Review by CIGIE that noted no deficiencies in the

oversight of audits conducted by our Independent Public Accountants.

5 The audit was requested by the U.S. House of Representatives, Committee on Appropriations Subcommittee on State, Foreign 

Operations, And Related Programs (HR Report 116-444). The Committee requested that DFC OIG assess the integration and 

efficiency of DFC policies, procedures, and processes. After consulting with the Committee, the OIG is completing a follow-up audit 

in India similar to the USAID OIG audit of the Overseas Private Investment Corporation’s (PIC’s) Chile Energy Sector Portfolio 

completed in 2019 (9-OPC-19-002-P).
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 17

Office of Investigations

The Office of Investigations (OI) conducts inquiries 

and investigations of suspected fraudulent, illegal, 

or unethical activities, which may result in criminal, 

civil, or administrative sanctions. OIG 

investigations can originate from hotline or 

whistleblower complaints, congressional inquiries, 

or proactive initiatives. OIG investigations protect 

whistleblowers and address critical and sensitive 

issues affecting DFC’s programs and investments, 

as well as U.S. foreign policy objectives and 

national security interests.

During this reporting period, April 1, 2023 – 

September 30, 2023, OI continued to develop its 

capacity to investigate a broad spectrum of 

allegations ranging from internal complaints of 

abuse of authority to external criminal fraud against 

DFC. A summary of investigative statistics is 

provided below, and Appendix D provides 

definitions for investigation metrics.

OI is hampered in its ability to independently 

conduct certain law enforcement activities because 

the OIG does not have much-needed law 

enforcement authority. The OIG’s request for law 

enforcement authority has been pending with the 

Attorney General’s Office since December 2020. 

The OIG continues to work with key stakeholders, 

including Congress and DOJ, to obtain law 

enforcement authority so that OI can effectively and 

efficiently conduct its investigations. Having such 

authority is crucial, as DFC OIG has the same 

oversight responsibilities for DFC that USAID OIG 

had for OPIC but does not have the full law 

enforcement authority USAID had (and has). DFC 

OIG needs law enforcement authority to access 

electronic databases and tools that are reserved for 

law enforcement entities. Without access to this 

data, DFC OIG cannot effectively and efficiently

investigate crimes involving DFC programs and 

operations. Not having this authority also hampers 

OIG’s authority to recruit and hire experienced 

investigators and is a safety issue for our 

investigators.

Complaints Received: 16

Cases Initiated: 10

Cases Open at Beginning of 

Reporting Period: 15

Cases Closed During Reporting 

Period: 18

Cases Open at End of Reporting 

Period: 7 

Investigative Reports Issued: 2 

Persons Referred for Criminal 

Prosecution (DOJ): 1 

Persons Referred for Criminal 

Prosecution (State, Local, and 

Foreign Authorities): 1 

Cases Referred to Agency 

Management for Administrative 

Action: 4 

SUMMARY OF INVESTIGATION

STATISTICS

APRIL 1, 2023 – SEPTEMBER 30, 2023
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Investigative Activity

As it continues to develop its investigative capacity, OI appreciates the partnership of Homeland 

Security Investigations; the U.S. Customs and Border Protection, Office of Field Operations; the 

Diplomatic Security Service, Criminal Investigative Liaison Branch; the DOJ; the FBI; and the OIGs of 

the U.S. Agency for International Development and Department of State. 

During the reporting period, April 1, 2023 – September 30, 2023, DFC OIG engaged in substantial 

investigative activity in multiple cases, including several with interagency partners. We also made one 

referral to DOJ concerning an individual in an ongoing investigation that we are working with foreign 

government authorities; DOJ declined to prosecute, but the matter is ongoing, so there is no summary 

in this report. The following provides a summary of notable investigations that were closed during this 

reporting period. 

Investigation Summaries

April 1, 2023 – September 30, 2023

Alleged Involvement of a Borrower in Illegal Activities

The OIG received information that a DFC borrower was involved in money laundering, terrorist financing, and 

corruption, and that a host country prosecutor was investigating the matter. The OIG briefed DFC regarding the 

concern. The host country prosecutor refused to provide information about the case, however, the borrower 

subsequently provided a letter to DFC from the prosecutor indicating that the case was closed without action.

Alleged Bribery of a Foreign Official

The OIG received information that an American citizen overseas paid a bribe via an intermediary to a senior 

host government official to approve a particular agreement. The investigation disclosed that the agreement was 

not executed, the relevant official who was in place during the alleged bribery has since left the government, 

and the intermediary was not given the funds to make the payment. The U.S. Embassy advised that the host 

government did not have a cooperative relationship with U.S. law enforcement, and the inquiry was closed. 

Alleged Fraud by a DFC Borrower

The OIG initiated a preliminary inquiry upon receipt of a complaint from an anonymous source that DFC was 

financing the expansion of a borrower’s manufacturing capability. The complaint alleged the borrower was in 

financial trouble and closing sites. The OIG took steps to verify the company did in fact have substantial revenue, 

and the inquiry was closed.

Alleged Discrimination Against Veterans

The OIG initiated an inquiry upon receipt of information that a DFC hiring official was refusing to consider 

veterans for employment. The OIG reviewed records which disclosed that several veterans were, in fact, selected 

for interviews and received offers of employment. The inquiry was closed.

Alleged Circumvention of Categorical Prohibitions

The OIG received information that DFC was considering a project with a large footprint that could potentially 

displace almost 10,000 people who would need to be resettled. DFC environmental and social policy and 

procedures categorically prohibit DFC from participating in projects resulting in the resettlement of over 5,000 

persons. The OIG reported the information received to DFC. DFC advised the OIG that the origination team 

was aware of the issue and had decided to recommend terminating DFC’s involvement in the project. 
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 19

Falsification of Financial Statements by a Borrower

DFC OIG and USAID OIG conducted a joint investigation involving a land developer in the Middle 

East that had applied for a loan to finance a development project in an underserved area. The 

investigation revealed that the land developer submitted falsified financial statements to DFC in 

connection with its loan application. The falsified financial statementsimproperly presented shareholder 

loans as equity instead of long-term debt, which dramatically improved the borrower’s debt-to-equity 

ratio. The falsified financial statements also removed a required disclosure about the firm’s status as a

going concern.

OIG investigators informed DFC about the falsified financial statements. Notwithstanding the concerns 

this raised, DFC committed to loan the borrower $41 million for the development project. USAID OIG 

and DFC OIG continued the investigation and attempted to interview the principals of the borrower and 

their project adviser. However, wishing to avoid being interviewed, the prospective borrower cancelled 

the loan commitment. Because the loan was cancelled before funds were dispersed to the disreputable 

borrower, the investigation resulted in a $41 million cost avoidance.6

USAID OIG referred the firm and its principals to foreign authorities for further investigation and 

potential prosecution. DFC OIG referred the parties responsible for the falsified financial statements 

to DFC for suspension and debarment.

6 The monetary impact of this investigation would qualify as either a “cost avoidance” or a “savings” under the applicable reporting 

standards. See Appendix D: Metrics for Investigative Reporting.
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 20

Senior Executive & Whistleblower Reprisal Investigations

DFC OIG investigates allegations of improprieties by DFC

staff and contractors—including DFC senior executives. DFC 

OIG also takes seriously and investigates allegations of 

reprisal against whistleblowers. We review all such 

complaints in a timely and thorough manner, in accordance 

with applicable law. Ensuring individuals’ right to report 

wrongdoing without fear of reprisal is essential to our mission. 

DFC OIG prioritizes assessing and responding to allegations 

of whistleblower reprisal by DFC management or DFC’s 

partners and contractors. During this reporting period, the OIG 

substantiated one allegation of whistleblower reprisal and 

improprieties by a senior executive. Below is a summary of the 

investigation and findings.

The OIG received a complaint from a DFC employee alleging 

various types of misconduct committed by a DFC senior 

executive. The employee also alleged that the senior executive was retaliating against the employee for 

filing a complaint with the OIG. During the investigation, the senior executive gave the whistleblower 

a failing rating, proposed the removal of the whistleblower from federal service, and placed the 

whistleblower on administrative leave.

The OIG investigated the allegations of misconduct and found the following:

• The senior executive improperly waived a preliminary security clearance requirement to hire 

a former business associate and DFC failed to document and properly justify the basis for the 

waiver. 

• DFC violated civil service regulations when it used a third-party contract as a temporary 

staffing mechanism to hire the former business associate as a de facto managerial employee.

• Certain other allegations concerning improper hiring were not substantiated.

• The senior executive created an appearance of impropriety because of the frequency with 

which the executive met a close friend while traveling abroad on government business.

• The senior executive violated State Department regulations and DFC policy by working more 

than 240 hours while on personal foreign travel in 2022 without being in an authorized travel 

status or having Country Clearance from the cognizant U.S. Embassy.

• Regarding a potential conflict of interest involving a proposed investment, the senior executive 

did not take any official action on the deal, and thus did not create an actual conflict of interest.

However, despite being recused from the deal, the senior executive appeared to be facilitating 

the deal behind the scenes, and thus created the appearance of a conflict of interest.

The OIG and the Office of Special Counsel (OSC) separately investigated the allegation of 

whistleblower reprisal. Both investigations obtained evidence supporting the whistleblower’s claim. 

Based on the evidence obtained, the OIG determined that the allegation of whistleblower reprisal is 

substantiated.

The investigation also revealed that the senior executive created a hostile work environment within the 

executive’s department.

During the investigation, the senior executive resigned. Near the end of the investigation, the 

whistleblower was reinstated and returned to the whistleblower’s previous position.
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 21

OIG Mandate to Investigate Whistleblower Complaints

DFC employees, as well as DFC contractors, 

subcontractors, and partners, have the right to 

report what they reasonably believe to be 

evidence of wrongdoing, without reprisal for 

doing so. Retaliation against whistleblowers is a 

prohibited personnel practice under civil service 

laws. Managers who retaliate may be subject to 

disciplinary action up to and including removal.

Protected disclosures include the disclosure of 

information that the employee reasonably 

believes provides evidence of:

• A violation of law, rule, or regulation

• Gross mismanagement

• Gross waste of funds

• An abuse of authority

• A substantial and specific danger to public health or safety.

A disclosure is protected even if the whistleblower is wrong, as long as the whistleblower reasonably 

believed the disclosure was correct. Federal law also protects employees of federal contractors, 

subcontractors, and partners, as well as personal service contractors, from reprisal concerning protected 

disclosures about federal contracts or grants. See 41 U.S.C. § 4712. Protected disclosures include 

information shared with any of the following authorities:

• An Inspector General.

• The Government Accountability Office.

• Members of Congress or representatives of 

congressional committees.

• A federal employee responsible for contract or grant 

oversight or management.

• An authorized official of the Department of Justice or 

other law enforcement agency.

• A court or grand jury.

• A manager or other employee of the contractor, grantee, 

or personal services contractor who has responsibility 

for investigating, discovering, or addressing 

misconduct.

Under the law, employees of Government contractors, subcontractors, and partners, as well as personal 

services contractors, who make a protected disclosure about a federal grant or contract cannot be 

discharged, demoted, or otherwise discriminated against, in retaliation for their good faith protected 

disclosure.
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 22

DFC OIG’s statutorily designated Whistleblower Protection Coordinator educates employees about their 

right to make protected disclosures and the protections available should they choose to come forward. 

The Whistleblower Protection Coordinator:

Educates agency employees on their legal right to disclose fraud, waste, abuse, 

and other misconduct, free from reprisal.

Ensures that information about whistleblower protections is presented at each 

DFC New Employee Orientation, as well as quarterly via an OIG newsletter to 

DFC employees. During the reporting period, this included six sessions and 

one newsletter.

Works with our Office of Investigations to ensure DFC employees and 

employees of DFC partners and contractors receive information on 

whistleblower rights and remedies. The OIG’s General Counsel also works 

with DFC’s Office of General Counsel to effectively address any personnel or 

other actions taken or not taken because of whistleblower activity.

DFC OIG also provides information about whistleblower rights and remedies on its public website at

https://www.dfc.gov/oig and DFC OIG Whistleblower Rights and Protections. 

DFC OIG Whistleblower 

Protection Coordinator 

Responsibilities 
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 23

Outreach and Other Activities

DFC OIG’s outreach and engagement efforts give stakeholders, oversight partners, and the public timely

and relevant information about the OIG’s work. The OIG also seeks stakeholder input to inform its work 

and strengthen partnerships with other oversight offices worldwide. In addition, the OIG engages in 

ongoing discussions with congressional officials, policymakers, researchers, and high-level government 

officials on DFC programs and challenges. The OIG also has conducted numerous outreach activities 

with DFC’s Board of Directors, executives, and other personnel to inform DFC about who we are, what 

we do, and why we perform audits, investigations, and other reviews.

Outreach

As DFC OIG continues to perform its oversight role, we recognize that it is important to inform our 

stakeholders – Congress; DFC’s Board of Directors, CEO, and employees; the international 

development finance industry; domestic and international law enforcement partners; and the American 

public – about our mission and work. During this reporting period, we conducted the following outreach 

efforts, among others.

DFC Board of Directors. Inspector General (IG) Zakel held regular briefings with the 

DFC Board of Directors and attended Risk Committee meetings. The Board was kept 

informed of OIG activity, including investigations, audit announcements, and reports.

DFC Chief Executive Officer. IG Zakel met with CEO Scott Nathan and his

executive staff on a regular basis, generally at least bi-weekly. 

DFC General Counsel. The OIG’s General Counsel and Senior Attorney regularly 

meet with DFC’s Office of General Counsel. During the reporting period, DFC made 

substantial progress toward establishing a suspension and debarment program for 

DFC.

DFC Executives and Employees. In addition to meetings between IG Zakel and DFC

executives, the OIG issued two quarterly newsletters to DFC employees. The 

newsletter is designed to communicate directly to DFC employees to share who we are 

and what we do. In addition, it provides contact information for the Hotline, explains

whistleblower rights and protections, and provides fraud awareness tips. The OIG also 

presented information about OIG’s work to new DFC employees, including how to 

reach us and how we protect whistleblowers. 

Congressional Appropriation and Oversight Committee Briefings. The OIG 

regularly briefed congressional committee staff on our operations progress, audits, and 

investigations. During this reporting period we held briefings with the following:

• Senate Foreign Relations Committee and relevant Subcommittees

• House Foreign Affairs Committee and relevant Subcommittees

• Senate and House Appropriations Committees and Subcommittees on 

State, Foreign Operations, and Related Programs. OIG submitted written 

testimony for the record to the Senate Appropriations, Subcommittee on 

State, Foreign Operations, and Related Programs for June 14, 2023, 
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 24

hearing, Enhancing American Competitiveness Through the U.S. 

International Development Finance Corporation7 

• Senate Homeland Security and Governmental Affairs Committee

Meetings with Other Offices of Inspectors General. The OIG continues to reach out 

to other OIGs seeking advice and guidance on many operational and mission-specific 

topics. During this reporting period, the OIG communicated with the following.

• Export/Import Bank (EXIM Bank) OIG, USAID OIG, AbilityOne OIG, 

and Peace Corps OIG to discuss coordination on matters of mutual 

interest. 

• USAID OIG on the Complex Emergencies Working Group (CEWG). 

CEWG is an international consortium of donor and development 

agencies, non-governmental organizations (NGOs), and oversight bodies 

that share information and resources to make their response to complex 

emergencies more effective and efficient. CEWG is currently focused on 

Ukraine. 

Meetings with Other Oversight and Assurance Offices. The OIG continues to reach 

out to other oversight and assurance organizations seeking advice and guidance on 

many operational and mission-specific topics. During this reporting period, the OIG 

communicated with the following: 

• World Bank Group Internal Audit (GIA) 

• Center for International Private Enterprise (CIPE) – Anti-Corruption and 

Governance Center 

7 Inspector General Zakel's Written Testimony for the Record, June 14, 2023

Tony Zakel, Inspector General DFC OIG (r) and Anke 

D’Angelo, Vice President and Auditor General, World Bank 

Group Internal Audit (l) sign MOU
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 25

Other Activities

Council of the Inspectors General on Integrity and Efficiency. DFC OIG is an active 

participant in the Council of the Inspectors General on Integrity and Efficiency (CIGIE), 

which is a statutorily created, independent entity within the executive branch. Congress 

established CIGIE to address integrity, economy, and effectiveness issues that transcend 

individual Federal Government agencies, and to aid in the establishment of a 

professional, well-trained, and highly skilled workforce in the Offices of Inspectors General. During 

this reporting period, the OIG supported the following activities.

• The IG participates in CIGIE’s Legislative Committee and the Small/Unique OIG Working 

Group, reviewing existing and proposed legislation and regulations to make 

recommendations concerning the impact of such legislation on the IG community.

• The OIG’s attorneys participate in the Council of Counsels to the Inspectors General 

(CCIG). CCIG holds monthly meetings to ensure legal advice is justifiable, consistent, and 

reflects best practices, and organizes training for new and experienced attorneys within the 

OIG community. CCIG has a subgroup for counsels who work on investigations and a 

subgroup for those who work at smaller OIGs. DFC OIG attorneys participate in these 

subgroups.

• The OIG participates in CIGIE’s subgroup for Inspectors General and Deputy Inspectors 

General reporting to Boards, the professional development committee’s mentoring pilot 

group, Investigative Attorneys, and the GAO-CIGIE Coordination Meeting.

• The OIG’s Office of Audits participated in the CIGIE Inspection & Evaluation Expansion 

Working Group.

Interagency Suspension and Debarment Committee. DFC OIG collaborated with DFC’s Office of 

General Counsel to establish a Suspension and Debarment Program for DFC, which will help protect 

DFC and other federal agencies from disreputable contractors. Significant progress towards establishing 

the program was made during the reporting period.

International Engagements. As the OIG’s Office of Investigations continues to develop its capabilities

for international investigations, it is proactively conducting outreach to pertinent law enforcement 

entities. During this reporting period, the OIG met with anticorruption officials from Nigeria and 

Romania.

Overseas Contingency Operations Joint Planning Group (OCO JPG), Ukraine Oversight 

Interagency Working Group. Hosted by Department of Defense IG.

Loans/Loan Guarantee working group. Hosted by Export-Import Bank OIG.
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DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 27

Required Reporting
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 28

Appendix A: Required Reporting

The following pages present summary tables and tables containing statistical and other data, as required by the 

IG Act and other statutes. 

IG Act Section Requirement Results Page Number

Statistical Summary of Audit-Related Accomplishments 

(April 1, 2023 – September 30, 2023) ~ 14

Statistical Summary of Investigative-Related 

Accomplishments (April 1, 2023 – September 30, 2023) ~ 17

5(a)(1) and 5(a)(2) Significant Problems, Abuses, and Deficiencies Related to the 

Administration of Programs and Operations None ~ 

5(a)(3) Significant Recommendations Described in Previous 

Semiannual Reports to Congress on which Corrective Action 

has Not Been Completed

None ~ 

5(a)(4) Matters Referred to Prosecutive Authorities None ~ 

5(a)(5) and 6(c)(2) Summary of Instances Where Information or Assistance Was 

Refused or Not Provided None ~ 

5(a)(8) Questioned Costs-Audits and Other Reports with Questioned 

Cost or Unsupported Cost None ~ 

5(a)(9) Better Use of Funds-Audit and Other Reports with 

Recommendations for Better Use of Funds 1 19

5(a)(10) Unresolved Reports-Unresolved Audit and Other Reports 

Issued Prior to Reporting Period None ~ 

5(a)(10)(B) Reports for which No Agency Comment was Returned to the 

OIG within 60 Days of Issuance None ~ 

5(a)(10)(C) Outstanding Unimplemented Recommendations with 

Aggregate Potential Cost Savings None ~ 

5(a)(11) Significant Revised Management Decisions None ~ 

5(a)(12) Significant Management Decisions with Which the OIG 

Disagreed None ~ 

5(a)(13) Unmet Intermediate Target Dates Established by the Agency 

Under the Federal Financial Management Improvement Act 

of 1996

None ~ 

5(a)(14) Peer Review Results 1 16
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 29

IG Act Section Requirement Results Page Number

5(a)(17) Investigative Reports Issued

• Numbers of Persons Referred to the U.S. Department of 

Justice 1 17

• Number of Persons Referred to State and Local 

Prosecuting Authorities None ~ 

• Indictments and Criminal Information that Resulted from 

Prior Referrals to Prosecuting Authorities None ~ 

5(a)(18) Description of the Metrics Used for Developing the 

Investigative Data for the Statistical Tables under 5(a)(17) ~ 33

5(a)(19) Report on Each Investigation Conducted by the OIG 

Involving a Senior Governmental Employee (GS-15 or above) 

Where the allegations of Misconduct were Substantiated

1 20

5(a)(20) Description of Instances of Whistleblower Retaliation 1 20

5(a)(21) Description of Attempt by Agency to Interfere with OIG 

Independence None ~ 

5(a)(22)(A) Description of Audits or Inspections Closed but Not 

Disclosed to the Public None ~ 

5(a)(22)(B) Description of Investigations Involving Senior Government 

Employees (GS-15 or above) that were Closed but Not 

Disclosed to the Public

None ~ 
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 30

Appendix B: Audit Tables

Table 1: Audit and Other Reports Issued During the Reporting Period

Report Number Report Title Open 

Significant 

Recs

Open 

Other 

Recs

Value of 

Potential Cost 

Savings

DFC-23-003-C DFC Implemented an Effective Charge Card 

Program Fiscal Year 2022 0 0 None

DFC-23-001-MA Management Advisory – Key Considerations to 

Inform DFC’s Response in Ukraine 0 0 None

DFC-23-004-C Compliance with Payment Integrity Information Act 

of 2019 (PIIA) Requirement in Fiscal Year 2022 0 1 None

Table 2: Recommendations Described in Previous Semiannual Reports on Which 

Corrective Action Has Not Been Completed

Report Title Number, and Link

Open Significant Recs Open Other Recs Value of Potential Cost 

Savings

OPIC Implemented Controls in 

Support of FISMA for Fiscal Year 

2017 but Improvements Are Needed 

(A-OPC-17-007-C , 9/28/2017)

None 1 N/A

OPIC Has Generally Implemented 

Controls in Support of FISMA for 

Fiscal Year 2018 (A-OPC-19-006-C, 

1/30/2019)

None 2 N/A

DFC Generally Implemented an 

Effective Information Security 

Program for Fiscal Year 2020 in 

Support of FISMA (A-DFC-21-005-

C, 1/28/2021)

None 1 N/A

DFC Implemented an Effective 

Information Security Program for FY 

2021 in Support of FISMA (A-DFC22-003-C, 12/1/2021) 

None 1 N/A

DFC Made Significant Progress 

Implementing Provisions of the Better 

Utilization of Investments Leading to 

Development Act (DFC-22-005-C, 

9/22/2022

None 3 N/A

FY 2022 DFC Federal Information 

Security Modernization Act of 2014 

Audit (issued November 9, 2023

(DFC-23-001-C)

None 4 N/A
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 31

Table 3: Audit and Other Reports with Questioned or Unsupported Costs

Requirement Number Unsupported Questioned Costs Amount

Inspector 

General Act, 

Section 5(a)(8)

~ None N/A
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 32

Appendix C: Metrics for Audit Reporting

Metric Description

Questioned Cost A cost that is unnecessary, unreasonable, unsupported, or an alleged 

violation of law, regulation, and contract

Unsupported Cost A cost that is not supported by adequate documentation. Unsupported 

costs are included with the amounts shown as Unsupported Questioned 

Costs. 

Funds Put to Better Use Funds that could be used more efficiently by implementing recommended 

actions.

Total Number of Reports 

Issued

The number of audit reports issued during the reporting period.

Recommendations Recommendations highlight actions that will improve entity performance 

when implemented. The appropriate and timely implementation of audit 

recommendations agreed to by management is an important part of 

realizing the full benefit of an audit.

Unresolved 

Recommendations

A recommendation that management has not concurred with and for 

which a resolution has not been reached between the OIG and 

management. These recommendations remain open until resolved.
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 33

Appendix D: Metrics for Investigative Reporting 

Metric Description

Investigation 

Opened

When a complaint or disclosure meets the following conditions: 

• There is identifiable evidence of a potential violation of a law or policy with a 

nexus to DFC. 

• The allegation falls within a stated management priority, or an investigation of 

it can otherwise be justified. 

OIG management is committed to expending the necessary resources to fully 

investigate the matter.

Investigations 

Closed 

When all investigative activity has concluded, all legal and administrative actions 

have been finalized, and all case results have been recorded in OIG’s case 

management system.

Total Number of 

Reports Issued 

Referrals of investigative activity are referred to one or more recipients outside of 

OIG. As part of the referral process, OIG provides referral recipients with a written 

summary of its investigative findings that inform decision-makers considering 

potential administrative action. 

Prosecutive 

Referrals

Referrals: Matters referred by OIG to the appropriate entity responsible for initiating 

criminal prosecution when investigative activity identifies evidence of potential 

violations of criminal law.

Arrests Instances in which an individual has been seized pursuant to legal process and taken 

into custody in connection with an OIG investigation. 

Criminal 

Indictments / 

Information

• Indictment: An accusation in writing found and presented by a grand jury, 

legally convoked and sworn, to the court in which it is impaneled, charging 

that a person therein named has done some act, or been guilty of some 

omission, which by law is a public offense, punishable on indictment. A 

formal written accusation originating with a prosecutor and issued by a grand 

jury against a party charged with a crime. An indictment is referred to as a 

“true bill,” whereas failure to indict is called a “no bill.” 

• Information: An accusation exhibited against a person for some criminal 

offense, without an indictment. An accusation in the nature of an indictment, 

from which it differs only in being presented by a competent public officer on 

his oath of office, instead of a grand jury on their oath. A written accusation 

made by a public prosecutor, without the intervention of a grand jury.

Convictions An adjudication of a criminal defendant’s guilt; specifically, it is the act or judicial 

process of finding a criminal defendant guilty of a charged offense.

Sentencings The formal legal consequences associated with a conviction.

Fines Monetary penalties are imposed on a defendant as part of sentencing.

Special 

Assessments

Monetary penalties are imposed on a defendant as part of sentencing. Special 

assessments are applied on a per-count basis and are collected in the same manner as 

fines for criminal cases.

Restitution Monetary penalties are imposed on a defendant as part of sentencing. Restitution 

serves as recompense to a victim for injury or loss.

Personnel 

Suspensions

The placement of Federal employees in a temporary non-duty status for disciplinary 

reasons.

Resignations Voluntary separation of employees from the Federal agency. Employees who tender 

their resignations as the result of an OIG investigation typically do so in lieu of 

removal.
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 34

Metric Description

Removals The involuntary separation of agency employees from the agency.

Suspensions The temporary disqualification of firms or individuals from receiving U.S. 

government awards. 

Debarments Actions are taken by a debarring official to exclude a contractor or grantee, or 

individual from government contracting and assistance awards for a specified 

period.

Judicial 

Recoveries

Monetary amounts are recovered from firms or individuals as part of a criminal or 

civil sentencing or settlement.

Administrative 

Recoveries

Funds that were already distributed and for which the agency formally issued a bill 

of collection or another recovery mechanism after an OIG investigation revealed that 

the funds were lost, misappropriated, stolen, or misused, and all or a portion of the 

recovery was paid back.

Savings Funds that were obligated, but not yet distributed, to be spent as part of an agency’s 

award that was preserved and made available for better uses after an OIG

investigation revealed evidence that those funds were vulnerable to fraud or waste. 

Savings often accompany contract terminations or the discovery of disallowed, 

questioned, or unsupported costs.

Cost Avoidance Federal funds were obligated and subsequently set aside and made available for 

other uses resulting from an OIG investigation. This includes instances in which the 

awarding agency made substantial changes to the implementation of the project 

based on an OIG referral. The key operating factor in claiming these as cost 

avoidance is that the funds were not de-obligated.

Other Includes a number of investigative results, the most significant of which are the 

following, relating to U.S. employees, Foreign Service Nationals, and/or personal 

services contractors:

• Reprimand: An official written rebuke, censure, or disapproval of a specific 

action or actions by a Federal employee.

• Demotion: A change of a Federal employee’s status to a lower grade or a 

position with a lower rate of pay.

• Audit Scheduled: An instance in which the responsible organization schedules 

an audit of the organization or program that OIG’s investigation deems to be 

vulnerable to fraud, waste, or abuse resulting from.
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Acronyms

Definitions

DFC Products
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 37

Appendix E: Acronyms, Definitions, DFC Products

Acronyms

Term Definition

BUILD Act Better Utilization of Investments Leading to Development Act of 2018; DFC’s 

authorizing statute

CDO Chief Development Officer

CIGIE Council of the Inspectors General on Integrity and Efficiency

CRO Chief Risk Officer

DFI Development Finance Institution

FAA Foreign Assistance Act of 1961, as amended (P.L. 97-195) codified at 22 

U.S.C. §2191 et. seq.

HIC High Income Country

IQ Impact Quotient (Development Impact Assessment Tool)

LIC Low Income Country

LMIC Lower Middle-Income Country

OOA Office of Accountability

ODC Office of Development Credit

OPIC Overseas Private Investment Corporation

SME Small and Medium Enterprise

UMIC Upper-Middle-Income Country

2X DFC’s Women’s Economic Empowerment Initiative

WBG World Bank Group

IFC International Finance Corporation
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 38

Definitions

Term Definition

Additionality The quality of DFC provides support that the private sector cannot provide. Please see 

the full definition in Directive PD-008.

Commitment A binding offer to provide insurance or financing (i.e., loan or guaranty) under explicit 

terms and conditions for a specified period of time. The commitment may precede the 

execution of a loan agreement or insurance contract, but binds the agency to issue the 

loan, guaranty, or issuance coverage provided the terms and conditions of the offer are 

met within the specified time period

Country Status The status of whether DFC can provide support for projects in a given country, which 

may be subject to certain restrictions. 

DFC Policy 

Requirements

Those policy requirements, preferences, and restrictions are imposed by DFC from time 

to time on sponsors, investors, and projects. DFC Policy Requirements are imposed as a 

result of statutory and foreign policy guidance, good corporate governance, and other 

agency considerations.

Eligible 

Investor

(1) United States citizens; (2) corporations, partnerships, or other associations including 

nonprofit associations, created under the laws of the United States, any State or territory 

thereof, or the District of Columbia, and substantially beneficially owned by United 

States citizens; and (3) foreign corporations, partnerships, of other associations: 

Provided, however, that the eligibility of such foreign corporation shall be determined 

without regard to any shares, in aggregate less than 5 per centum of the total of issued 

and subscribed share capital, held by other than the United States owners: Provided 

further, that in the case of any loan investment a final determination of eligibility may 

be made at the time the insurance or guaranty is issued; in all other cases, the investor 

must be eligible at the time a claim arises as well as at the time the insurance or 

guaranty is issued.

Expropriation One of the types of risks that may be covered under DFC’s political risk coverage.

Financing DFC investment guaranty, direct loan, and local currency authorities.

Foreign 

government

“Foreign government” means: (1) Any unit of a foreign government, including any 

national, State, local, and municipal government, and their foreign equivalents; (2) Any 

international or multinational organization whose membership is composed of any unit 

of a foreign government; and (3) Any agent or representative of any such foreign 

government unit or organization while acting as such.

Internationally 

Recognized 

Worker Rights

Defined by section 507(4) of the Trade Act of 1974. Includes: (A) the right of 

association; (B) the right to organize and bargain collectively; (C) a prohibition on the 

use of any form of forced or compulsory labor; (D) a minimum age for the employment 

of children; and acceptable conditions of work with respect to minimum wages, hours of 

work, and occupational safety and health.

ODP Policy 

Requirements

A subset of DFC Policy Requirements. ODP Policy Requirements are those projectrelated restrictions and requirements in the areas of the environment, worker rights, 

human rights, U.S. effects, and developmental benefits. The application of these 

requirements is handled by ODP. ODP Policy Requirements are imposed because of 

statutory and foreign policy guidance, good corporate governance, and other agency 

considerations. 
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 39

DFC Products

DFC products include debt financing, equity investments, feasibility studies, investment funds, political risk 

insurance, and technical assistance. Below is a brief description of DFC products and learn more by visiting its 

website at www.dfc.gov. 

DFC Product Descriptions 

Debt Financing. Direct loans and guarantees of up to $1 billion for tenors as long as 25 

years, with specific programs targeting small and medium U.S. businesses. DFC provides 

financing of more than $50 million to projects in critical infrastructure, energy, and other 

projects requiring large investments.

Equity Investments. DFC direct equity investments can provide critical support to 

companies committed to creating developmental impact. Equity investments can be 

highly developmental because of their ability to support early and growth-stage 

companies that would otherwise not be able to take on debt, especially companies in low 

and lower-middle-income countries.

Feasibility Studies. Support for the analysis of a potential DFC project. In most cases, 

grants for feasibility studies and technical assistance will be designed to increase the 

developmental impact or improve the commercial sustainability of a project that has 

received or may receive, DFC financing or insurance support.

Investment Funds. Support for emerging market private equity funds to help address the 

shortfall of investment capital. DFC can invest debt and equity into emerging market 

private equity funds to help address the shortfall of private equity capital in developing 

countries and help these economies access long-term growth capital, management skills, 

and financial expertise, all of which are key factors in expanding economic development 

and creating new opportunities for people in low-income and developing nations.

Political Risk Insurance. Coverage of up to $1 billion against losses due to currency 

inconvertibility, government interference, and political violence including terrorism. DFC 

also offers reinsurance to increase underwriting capacity. 

Technical Assistance. Support to increase the developmental impact or commercial 

sustainability of existing DFC projects or develop potential DFC projects. 
DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 40

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DFC OIG Semiannual Report to Congress: April 1, 2023 – September 30, 2023 | 41

U.S. International Development Finance Corporation 

Office of Inspector General

1100 New York Avenue, NW 

Suite 270 West 

Washington, DC 20527 

www.dfc.gov/oig 

DFC OIG Hotline

Toll-Free +1 833-OIG-4DFC

Online at DFC OIG Hotline