Terrorist Financing/Money Laundering: FinCEN's BSA IT Modernization Program Is on Schedule and Within Cost, But Requires Continued Attention to Ensure Successful Completion. Audit Report.

摘要

The Financial Crimes Enforcement Network (FinCEN) administers the Bank Secrecy Act (BSA), which establishes the framework to combat criminal use of the financial system. BSA requires financial institutions to report certain financial transactions made by their customers. These reports are currently stored in an Internal Revenue Service (IRS) system. 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. It is intended that the BSA data will transition from IRS to FinCEN as part of this effort. BSA IT Mod is a $120 million effort and is to be completed in 2014. It follows a previously failed system development effort known as BSA Direct Retrieval and Sharing (BSA Direct), terminated in July 2006 when FinCEN concluded it had no guarantee of success. We reviewed that failure and concluded that FinCEN poorly managed the predecessor project, insufficiently defined functional and user requirements, misjudged project complexity, and established an unrealistic completion date. We also found that the Treasury Office of the Chief Information Officer (OCIO) did not actively oversee the project, as required by the Clinger-Cohen Act of 1996.