1 

 DEPARTMENT OF THE TREASURY WASHINGTON, D.C. 20220

Compliance with Section 20(B) of the Executive Order 14074, Advancing 

Policing and Criminal Justice Practices to Enhance Public Trust and Public 

Safety. 

On May 25, 2022, President Biden issued Executive Order (EO) 14074,

Advancing Policing and Criminal Justice Practices to Enhance Public Trust and 

Public Safety1. Section 20(b) of the EO required federal agencies that provide 

financial assistance to law enforcement agencies (LEAs) to conduct a review of 

their practices for enforcing Title VI of the Civil Rights Act (Title VI), and to submit 

to the Assistant Attorney General for the Civil Rights Division of the Department 

of Justice (DOJ) a report of its review. 

The Department of the Treasury (Department or Treasury) conducted a review of 

its implementation and administrative enforcement of Title VI in connection with 

the federal financial assistance provided by the Treasury and is making the 

conclusions of that review publicly available. 

I. Introduction and Overview of Review

Title VI prohibits recipients of Federal financial assistance (FFA) from 

discriminating against any person on the basis of race, color, or national origin in 

the provision of services. Treasury rules under 31 C.F.R. Part 22 implement the 

provisions of Title VI to the Department’s financial assistance programs and 

activities. The statute and rules are critical tools to ensure the financial 

assistance provided by the Department is not used to finance illegal 

discrimination. Title VI and the Treasury’s Title VI regulations are designed to 

provide equal opportunity and access in all programs receiving FFA from 

Treasury, by ensuring nondiscrimination on the basis of race, color, or national 

origin (including limited English proficiency).

The effective implementation and enforcement of Title VI is an important priority 

for Treasury. The Department distributes FFA to thousands of recipients, located 

in all States and territories. The Department’s programs provide FFA for variety 

of purposes. Treasury currently administers 28 FFA programs. The recipients of 

Treasury’s FFA programs are diverse entities, including but not limited to State, 

local, and tribal governments. 

1 Federal Register: Advancing Effective, Accountable Policing and Criminal Justice Practices To Enhance 

Public Trust and Public Safety 
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Treasury surveyed its 28 financial assistance programs to determine what 

programs are providing FFA to LEAs. Within the 28 Treasury programs, there 

are two programs providing FFA to LEAs, the Treasury Executive Office for Asset 

Forfeiture (TEOAF)’s Equitable Sharing Program and the Office of Recovery 

Programs (ORP)’s State and Local Fiscal Recovery Funds (SLFRF) program. 

The governments that received funds from SLFRF are allowed to use the funds 

for a variety of purposes, and in some cases, the funds were used for supporting 

LEAs.

B. Focus Areas of Review

Consistent with Section 20 of the EO, the Department selected the following 

areas as the focus of its Section 20 review.

1. Administrative enforcement – relating to conducting compliance reviews

and complaint investigations. 

2. Data collection and reporting – relating to potential improvements to 

recipients’ data collection and reporting obligations to better identify 

indicators of potentially discriminatory policies and practices and 

considering how to improve data collection procedures without unduly 

burdening recipients. 

3. Intra-department coordination – relating to measures that could be 

adopted to enhance coordination among various agency components. 

4. Legal rules and regulations – relating to an examination of the rules 

governing the compliance and enforcement processes and potential 

regulatory, statutory, and guideline amendments. 

C. Summary of Further Work

The Department is committed to ensuring effective implementation and 

administrative enforcement of Title VI, and its ongoing work and existing 

procedures reflect the importance of that goal. Consistent with its review under 

the EO, moreover, the Department has identified several opportunities to 

enhance its work in this area: 

1. Notice of Rights to the Program Beneficiaries – Recognizing that 

Treasury does not directly interact with SLFRF program beneficiaries, 

SLFRF can be a source of information for program beneficiaries by 

publishing a civil rights’ notice in the SLFRF program webpages, and 

specifically notifying the program recipients of the requirement to inform 

the program beneficiaries of their civil rights. 

2. Notice to the Recipients about their Compliance Responsibilities - 

TEOAF and SLFRF can supplement the notice they already provide to 

the recipients about their civil rights compliance responsibilities by 
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distributing a copy of the Treasury Civil Rights Toolkit2 to the TEOAF 

and SLFRF recipients and encouraging them to distribute the Toolkit to 

their staff and subrecipients, as applicable.

3. Post-Award Compliance Reviews - TEOAF and SLFRF can engage with 

the Department of Justice and other agencies and consider additional 

risk-based measures to monitor recipient post-award compliance. 

4. Pre-Award Compliance Reviews - TEOAF can engage with the 

Department of Justice and OCRE and consider additional risk-based 

measures to monitor recipient pre-award compliance with the 

requirements in the Title VI regulations. 

5. Civil Rights Program Administration and Enforcement (Stakeholder 

Engagement) - Treasury can publish a request for comments in the 

Federal Register regarding (1) how the Department can advance the 

principles of nondiscrimination among its recipients of financial 

assistance, (2) ways the Department can improve its implementation of 

Title VI, (3) ways the Department can support its recipients to improve 

their compliance with Title VI, and, (4) types of data the recipients should 

collect.

6. Data Collection – For the Equitable Sharing Program, Treasury will

specifically cite the civil rights compliance data collection requirement in 

Treasury’s Title VI regulations at 31 C.F.R. § 22.6(b), including the 

collection of race and national origin data as applicable, in updates to 

program policy documents, in addition to the existing notification on its 

website. 

7. EO 14074 Monitoring - OCRE should lead the Department’s further 

development and implementation of these recommendations by creating 

a Title VI LEA Enforcement Working Group to continue the work started 

by this review. 

The effective implementation and enforcement of Title VI remains an important priority 

to Treasury in administering its programs.

2 CIVIL RIGHTS TOOLKIT (treasury.gov)