Terrorist Financing/Money Laundering: FinCEN's BSA IT Modernization Program Is Meeting Milestones, But Oversight Remains Crucial. Audit Report.

摘要

The Financial Crimes Enforcement Network (FinCEN) administers the Bank Secrecy Act (BSA), which established the framework to combat criminal use of the financial system. BSA requires financial institutions to report certain financial transactions made by their customers. FinCEN oversees the management, processing, storage, and dissemination of BSA data. In November 2006, FinCEN began a system development effort, the BSA Information Technology Modernization Program (BSA IT Mod), to improve the collection, analysis, and sharing of BSA data. The intent of the system was, among other things, to transition BSA data from the Internal Revenue Service (IRS) to FinCEN.1 BSA IT Mod is estimated to cost $120 million and is to be completed in 2014. Pursuant to a Congressional directive, we conducted a second in a series of audits of FinCEN’s BSA IT Mod.2 Consistent with the Congressional directive, the objectives of the audit were to determine if FinCEN is (1) meeting cost, schedule, and performance benchmarks for the program and (2) providing appropriate oversight of contractors. The period covered by this audit is June 2011 through May 2012. We interviewed FinCEN program officials, Department of the Treasury Office of the Chief Information Officer (Treasury OCIO) officials, and IRS officials involved with managing and using BSA data. We interviewed representatives from Deloitte Consulting, LLP (Deloitte), and MITRE Corporation (MITRE), the contractors involved with the program. 3 We also reviewed applicable program documentation. We performed our fieldwork from March 2012 to August 2012. Appendix 1 provides a more detailed description of our audit objectives, scope, and methodology.