USDOJ seal U.S. Department of Justice
  Washington, D.C. 20530


May 12, 2003  
  Inspector General
FROM: Signature of Paul R. Corts
Paul R. Corts
Assistant Attorney General
for Administration
SUBJECT: Assets Forfeiture Fund and Seized Asset Deposit Fund
Annual Financial Statement Fiscal Year 2002

This memorandum transmits the Justice Management Division's (JMD) response to the recommendations contained in the subject referenced draft audit report. JMD agrees with the recommendations contained in the report and will implement corrective actions as outlined below.

Recommendation #1: The Director of the Asset Forfeiture Management Staff (AFMS) should continue to monitor and evaluate participating agencies' efforts to improve the Consolidated Assets Tracking System (CATS) data quality. This should include performing on-site monitoring, as needed, and reaffirming with the participating agencies the proper procedures for correcting errors found during physical inventory counts.

Corrective Action Plan: AFMS is taking the following actions to address these recommendations: (1) conducting 33 site reviews of participating agencies this fiscal year, focusing on high volume locations, (2) issuing detailed physical inventory and data verification instructions to the participating agencies, and (3) issuing monthly closing procedures to ensure outstanding data entry requirements are identified and addressed on a reoccurring basis. Attachment A contains a list of locations and dates where data quality reviews will be conducted this fiscal year. Attachment B contains the physical inventory and data verification instructions that were issued for this year's annual physical inventory. By the end of May 2003 the AFMS plans to issue a set of monthly closing procedures to each of the component agencies.

Recommendation #2: The Director of AFMS should ensure that all participating agencies that establish obligations for the Assets Forfeiture Fund/Seized Assets Deposit Fund monitor the status of obligations on an ongoing bases in accordance with the budgetary and accrual basis of accounting. Specifically, expenses should be recognized when goods and services are received, not when payments are processed.

Corrective Action Plan: Beginning in May 2003, an AFMS team of experiences financial analysts will review selected open obligation in FMIS2 to verify that the obligations valid and properly recorded in the FMIS2. The team will request samples of certain open obligations to verify that there is appropriate documentation support and that each obligation is valid and the delivery status in FMIS2 is correct. In addition, the team will make recommendation for improving the obligating office's practices and will provide training and/or reference materials as needed.

Should you have any questions regarding the information provided, please contact Michael A. Perez, Director, AFMS, on (202) 616-8000.

Attachment A

DQT Site Review Schedule
Review Dates Site
January 13 - 17 San Diego, CA
January 27 - 31 Los Angeles, CA
February 10 - 14 San Francisco, CA
March 3 - 7 Newark, NJ
March 10 - 14 Miami, FL
March 10 - 14 Tampa, FL
March 17 - 21 Baltimore, MD
March 17 - 21 Puerto Rico
March 24 - 28 Brooklyn, NY
March 24 - 28 Manhattan, NY
April 7 - 11 Detroit, MI
April 7 - 11 San Antonio, TX
April 21 - 25 Cleveland, OH
April 21 - 25 Pittsburgh, PA
May 5 - 9 Chicago, IL
May 5 - 9 Boston, MA
May 19 - 23 Pheonix / Tucson
May 19 - 23 Burlington, VT
June 2 - 6 Columbus, OH
June 16 - 20 Alexandria, VA
June 16 - 20 Philadelphia, PA
July 7 - 11 Houston, TX
July 7 - 11 East St. Louis, IL
July 21 - 25 New Haven, CT
July 21 - 25 Scranton, PA
August 4 - 8 Madison, WI
August 4 - 8 Washington, DC
August 18 - 22 Sacramento, CA
September 8 -12 St. Louis, MO
September 8 -12 Dallas, TX
September 22 - 26 Atlanta, GA
September 22 - 26 Portland, OR

Attachment B

USDOJ seal U.S. Department of Justice
  Washington, D.C. 20530


April 14, 2003  
TO: Distribution List
FROM: Initials of Michael A. PerezMichaeal A. Perez
Asset Forfeiture Management Staff
Justice Management Division
SUBJECT: Inventory, Data Verification and Document Submission Requirements for
Asset Forfeiture Program FY 2003 Financial Statement Audit

During fiscal year 2003, there are several important changes that influence the nature and timing of the Asset Forfeiture Program financial statement compilation, as well as the audit examination itself. Throughout this year we are required to file quarterly financial statements and, as in each of the past two years, the date for submitting annual audited financial statements has been further accelerated in order to meet Office of Management and Budget (OMB) requirements. As we plan the steps to meet these tighter time frames, we must also address the fiscal year 2002 audit recommendations and redefine certain basic closing processes to ensure that our financial and property data are both timely and accurate.

The entire schedule for completion of the Asset Forfeiture Program Fiscal Year 2003 Financial Statement Audit has been revised and accelerated to comply with tighter OMB reporting deadlines. Within the next few weeks I will be transmitting to you a set of detailed monthly closing procedures designed to ensure all components are updating the information systems that support the Asset Forfeiture Program on a continual basis. In addition, we have scheduled an audit kick-off meeting for Friday, April 25, 2003 at 1:30pm, 20 Massachusetts Ave., NW, Suite 6400. We will be providing additional information at this meeting on time frames for data pull requirements associated with the physical inventory and real estate disposition testing, as well as obligation, disbursement and revenue testing.

The remainder of this memorandum details the physical inventory procedures that must be completed by May 31, 2003, in preparation for interim audit testing during the months of June and July.

Physical Inventory Requirements

As of May 31, 2003, units responsible for seized or forfeited property under the Department's forfeiture program must complete a physical inventory, complete the processing of any necessary documents and property transfers, and update the appropriate records in the property system and financial system as applicable. The Consolidated Asset Tracking System (CATS) and FASTRACK (specific to ATF) are the property systems for purposes of these updates and the financial systems to update are either FMS, FFS, or FMIS depending on your organization.

During this inventory process, it is essential that three types of information in the respective property systems be verified as accurate and, if not up-to-date, be corrected. These three are: (1) a validation that the asset actually exists in federal custody; (2) a verification that the underlying information for the asset is accurately reflected as to standard seizure versus FIRE, seized versus forfeited, and claim/petition information; and, (3) a review of the value of the property to assure that it is based on a rational and current valuation supported by appropriate documentation.

It is important that all property seized for forfeiture in your custody or area of responsibility, be accurately reflected in the property system with the appropriate supporting documentation. To accomplish that goal, the physical inventory and associated closing processes must be conducted during the month of May 2003, based on the property system inventory of assets on hand. Please pay particular attention to ensure that all property is inspected and counted, including those stored under substitute custodial arrangements. Investigative agencies should inventory all property not yet transferred to U.S. Marshals Service custody. Investigative agencies and U.S. Attorney's Offices should review the status of all cases, updating the property system for the correct seized, forfeited and petition status as warranted.

There will be significant emphasis placed on the results of the May 31, 2003, closing and document submission in formulating the amount of additional testing performed by the auditors for their year-end work. If the error rate is outside an acceptable tolerance range, it will result in additional work and could ultimately jeopardize our ability to achieve a clean opinion. Due to accelerated closing schedule at year-end, there will be precious little time to overcome poor interim test results. Therefore, it is imperative that a concerted effort be made to ensure the accuracy of the property and financial systems data relative to each property and the availability of related documentation for each property.

The protocol for completing the inventory review is essentially the same protocol that was issued last year. The attached protocol should be closely followed and all due dates strictly followed. We appreciate your continuing cooperation and efforts in strengthening the Program's overall internal controls. Please let me know as early as possible if you need assistance from this office to accomplish these goals.

If you have any questions, or need additional information, contact either me or Tim Virtue on (202) 616-8000. Members of the Data Quality Team are available to assist you or your staff in running or interpreting CATS reports.

Attachment C

Physical Inventory Protocol
in Support of the Financial Statement Audit
of the Assets Forfeiture Fund and Seized Asset Deposit Fund
for Fiscal Year 2003

May 2003

June 13, 2002