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Open Recommendations

Currency Transaction Reports: Improvements Could Reduce Filer Burden While Still Providing Useful Information to Law Enforcement
GAO-25-106500
Dec 11, 2024
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4 Open Recommendations
Agency Affected Recommendation Status
Department of the Treasury The Secretary of the Treasury should ensure that the Director of FinCEN takes steps to eliminate CTR data fields that are unnecessarily burdensome for filers and of little use to law enforcement. This could be done as part of FinCEN's AMLA review or through a different method. (Recommendation 1)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Department of the Treasury The Secretary of the Treasury should ensure that the Director of FinCEN takes steps to simplify and clarify aggregation requirements. This could be done as part of FinCEN's AMLA review or through a different method. (Recommendation 2)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Department of the Treasury The Secretary of the Treasury should ensure that the Director of FinCEN establishes a performance management process that defines performance goals and measures for monitoring the usefulness of CTRs. (Recommendation 3)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Department of the Treasury The Secretary of the Treasury should ensure that the Director of FinCEN takes steps to reduce the number of CTRs filed that are not used by law enforcement, such as by raising the reporting threshold or expanding criteria to allow for further exemptions. These actions should be informed by an analysis of the characteristics of CTRs that have been less likely to be accessed by law enforcement. (Recommendation 4)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Bank Supervision: Federal Reserve and FDIC Should Address Weaknesses in Their Process for Escalating Supervisory Concerns [Reissued with revisions on Nov. 25, 2024]
GAO-25-106771
Nov 25, 2024
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5 Open Recommendations
Agency Affected Recommendation Status
Federal Reserve System The Chair of the Federal Reserve should determine whether to promulgate a regulation or enforceable guidelines on corporate governance and risk management under section 39 of the Federal Deposit Insurance Act, consistent with those issued by the other regulators, and document steps taken to make this determination. (Recommendation 1)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Federal Reserve System The Chair of the Federal Reserve should issue a regulation to implement remaining open portions of section 166 of the Dodd-Frank Act, taking into account prior proposals and public comments. (Recommendation 2)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Federal Deposit Insurance Corporation The Chair of FDIC should develop a central database for recording and reporting supervisory recommendations, similar to that used for matters requiring board attention. (Recommendation 3)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Federal Deposit Insurance Corporation The Chair of FDIC should establish procedures, such as vetting meetings, for the Continuous Examination process program to ensure that managers formally consult with the examination team and relevant stakeholders before making substantive changes to examination findings. Such vetting meetings should be documented and include any divergent views that arise. (Recommendation 4)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Federal Deposit Insurance Corporation The Chair of FDIC should consider a requirement that case managers for Continuous Examination process institutions periodically rotate assignments. (Recommendation 5)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

World Bank Procurement: Risk Monitoring Can be Enhanced as U.S. Businesses Face Challenges Competing
GAO-24-106718
Sep 26, 2024
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2 Open Recommendations
Agency Affected Recommendation Status
Department of the Treasury The Secretary of the Treasury should ensure that the Office of International Affairs develops guidance and a formal process to determine whether to monitor individual World Bank borrower projects based on risks to U.S. interests. (Recommendation 1)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Department of the Treasury The Secretary of the Treasury should ensure that the Office of International Affairs develops guidance and a formal process for how it will monitor World Bank borrower projects when it determines that monitoring is necessary. (Recommendation 2)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Anti-Money Laundering: Better Information Needed on Effectiveness of Federal Efforts [Reissued with revisions on Jun. 13, 2024]
GAO-24-106301
Jun 13, 2024
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3 Open Recommendations
Agency Affected Recommendation Status
Department of the Treasury The Secretary of the Treasury should ensure that the Director of FinCEN develop and implement a communications plan to regularly inform Congress and the public in full about its progress implementing the Anti-Money Laundering Act of 2020. (Recommendation 1)
Open
In September 2024, FinCEN informed us that the agency is updating its internal tracking mechanisms with respect to the Anti-Money Laundering Act's (AMLA) sections for which FinCEN has rulemaking, reporting, or other anti-money laundering-related implementation responsibilities. These tracking mechanisms will be used as a basis for a public communications plan that will include updates to FinCEN's AMLA webpage and congressional notification of such updates. FinCEN anticipates implementing the communications plan by the end of February 2025.
Department of the Treasury The Secretary of the Treasury should ensure that the Director of FinCEN work with its survey vendor to improve the reliability of the agency's annual customer satisfaction surveys and appropriately disclose survey data limitations when results are reported. (Recommendation 2)
Open
In September 2024, FinCEN informed us that it is working with its vendor to explore the cost of a nonresponse bias analysis for its surveys and ways to improve survey response rates. In the meantime, beginning with its FY 2026 budget submission, FinCEN included language disclosing survey data limitations. FinCEN plans to complete its evaluation of pricing options for a nonresponse bias analysis by year-end of 2024 and its action plan to improve survey response rates in March 2025.
Department of Justice The Attorney General should lead an effort, in coordination with the Departments of Homeland Security and the Treasury, to develop a methodology for producing government-wide data on the outcomes of anti-money laundering investigations. This effort could be conducted in conjunction with the interagency working group DOJ was directed to form in the joint explanatory statement accompanying its fiscal year 2023 appropriation. (Recommendation 3)
Open
In November 2024, DOJ informed us that it is taking steps to implement this recommendation through improvements to the Organized Crime Drug Enforcement Task Forces' (OCDETF) management information system, a data management and performance analytics system that integrates data from OCDETF member agencies (which include Homeland Security and Treasury components). Specifically, OCDETF is automating agency information inputted into the system to reduce redundancy and integrating the system's database with an investigative database to develop strategic plans and intelligence products. In December 2024, OCDETF informed us that it has initiated efforts to standardize and integrate data-sharing protocols, including drafting agreements to facilitate the secure sharing and mapping of data while protecting sensitive case details. Its next steps include (1) analyzing agency data points to streamline collection and integration processes, (2) mapping data from multiple sources to standardized forms and aligning agency data interfaces, and (3) collaborating with partners to test integration and refine data collection systems. According to OCDETF, the vision is to build a unified governmentwide database that supports robust evaluation of anti-money laundering and other investigative outcomes. We will continue to update the recommendation's status as we learn new information.
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