SPIRIT OF SOCCER, INC.

EIN: 200252138

UEI: KREGNANTJGW6

Data as of August 24, 2026

SPIRIT OF SOCCER, INC.9 audit years26 findings19 repeat
9
Audit Years
26
Total Findings
19
Repeat Findings

FY 2024-12-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on November 5, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by May 5, 2026 (111 days ago).

What is a management decision? →
2024-002
Other
MATERIAL WEAKNESSREPEAT

Lack of Segregation of Duties and Organizational Monitoring - Internal Control - Material Weakness U.S. Department of State - Federal Assistance Listing Number 19.800 Weapons Removal and Abatement Program Criteria Standard accounting practice for the design of good internal controls requires that no one contracted staff member should have access to both physical assets and the related accounting records or to all phases of a transaction. Condition The condition reported as item 2024-001 above also applies to the Organization's internal control over compliance with the requirements of federal programs. The Organization's small size and limited contracted staff does not allow for it to have the checks and balances over the reporting and cash management functions that would be present in an ideal set of internal controls. Repeat Finding from Prior Year This is a repeat finding of a prior year. Cause Due to the limited contracted staff within the Organization, certain internal controls and other critical systems could lack the necessary safeguards and appropriate compensating controls. Effect This condition could result in errors being made in the accounting records and federal grant reporting and going undetected due to the lack of "cross-checking." Further one individual could have the opportunity to perpetrate fraud (by either intentional misstatements of the grant reports, or misappropriation of the Organization's assets) and conceal it without the proper oversight. Recommendation We recommend that all accounting areas be evaluated to ensure adequate controls are in place and operating as expected. We believe certain oversight or monitoring procedures should be put in place to enhance the systems of internal control. Our recommendation is for the Board to review all accounting and program duties and consider realigning certain incompatible duties to improve internal controls. Views of Responsible Officials Management agrees with the recommendation and has added an additional board member with a financial background who is working towards developing policies and procedures to implement another layer of oversight and improve documentation of reports submitted for the federal award programs. Management will continue to work to implement the other necessary components of the recommendation. -

Show full finding ▾
Full finding narrative

Lack of Segregation of Duties and Organizational Monitoring - Internal Control - Material Weakness U.S. Department of State - Federal Assistance Listing Number 19.800 Weapons Removal and Abatement Program Criteria Standard accounting practice for the design of good internal controls requires that no one contracted staff member should have access to both physical assets and the related accounting records or to all phases of a transaction. Condition The condition reported as item 2024-001 above also applies to the Organization's internal control over compliance with the requirements of federal programs. The Organization's small size and limited contracted staff does not allow for it to have the checks and balances over the reporting and cash management functions that would be present in an ideal set of internal controls. Repeat Finding from Prior Year This is a repeat finding of a prior year. Cause Due to the limited contracted staff within the Organization, certain internal controls and other critical systems could lack the necessary safeguards and appropriate compensating controls. Effect This condition could result in errors being made in the accounting records and federal grant reporting and going undetected due to the lack of "cross-checking." Further one individual could have the opportunity to perpetrate fraud (by either intentional misstatements of the grant reports, or misappropriation of the Organization's assets) and conceal it without the proper oversight. Recommendation We recommend that all accounting areas be evaluated to ensure adequate controls are in place and operating as expected. We believe certain oversight or monitoring procedures should be put in place to enhance the systems of internal control. Our recommendation is for the Board to review all accounting and program duties and consider realigning certain incompatible duties to improve internal controls. Views of Responsible Officials Management agrees with the recommendation and has added an additional board member with a financial background who is working towards developing policies and procedures to implement another layer of oversight and improve documentation of reports submitted for the federal award programs. Management will continue to work to implement the other necessary components of the recommendation. -

Corrective Action Plan

Management agrees with the recommendation and has added an additional board member with a financial background who is working towards developing policies and procedures to implement another layer of oversight and improve documentation of reports submitted for the federal award programs. Management will continue to work to implement the other necessary components of the recommendation.

Prior Finding References

2023-002

About Other →
2024-003
Cash Management
MATERIAL WEAKNESSREPEAT

Subrecipient Transfers - Internal Control and Compliance - Material Weakness - Noncompliance with Cash Management and Subrecipient Monitoring U.S. Department of State - Federal Assistance Listing Number 19.800 Weapons Removal and Abatement Program Criteria The Uniform Guidance requires that non-federal entities mIrnmIze the time between drawdowns of Federal funds and its expenditure for Federal program purposes. Condition Since there is no reconciliation process in place regarding the amounts sent to and expended by subrecipients, we were unable to determine whether federal funds were being passed through faster than necessary. Repeat Finding from Prior Year This is a repeat finding of a prior year. Cause The Organization does not have policies and a process in place to reconcile amounts drawn down on various grants with the amounts being spent on the various grants. Effect The Organization is not in compliance with cash management and subrecipient monitoring requirements. Recommendation We recommend that the Organization develop and implement a system whereby they can reconcile their grant drawdowns with the amounts being expended and amounts passed through to subrecipients. We would further recommend that the monthly reports that foreign country managers submit be signed by the party submitting the report and then signed by the International Director once the report is reviewed. Views of Responsible Officials Management agrees with the recommendation and will work to implement the necessary components of the recommendation. Accounting policies and procedures have been developed and will continue to be implemented.

Show full finding ▾
Full finding narrative

Subrecipient Transfers - Internal Control and Compliance - Material Weakness - Noncompliance with Cash Management and Subrecipient Monitoring U.S. Department of State - Federal Assistance Listing Number 19.800 Weapons Removal and Abatement Program Criteria The Uniform Guidance requires that non-federal entities mIrnmIze the time between drawdowns of Federal funds and its expenditure for Federal program purposes. Condition Since there is no reconciliation process in place regarding the amounts sent to and expended by subrecipients, we were unable to determine whether federal funds were being passed through faster than necessary. Repeat Finding from Prior Year This is a repeat finding of a prior year. Cause The Organization does not have policies and a process in place to reconcile amounts drawn down on various grants with the amounts being spent on the various grants. Effect The Organization is not in compliance with cash management and subrecipient monitoring requirements. Recommendation We recommend that the Organization develop and implement a system whereby they can reconcile their grant drawdowns with the amounts being expended and amounts passed through to subrecipients. We would further recommend that the monthly reports that foreign country managers submit be signed by the party submitting the report and then signed by the International Director once the report is reviewed. Views of Responsible Officials Management agrees with the recommendation and will work to implement the necessary components of the recommendation. Accounting policies and procedures have been developed and will continue to be implemented.

Corrective Action Plan

Management agrees with the recommendation and will work to implement the necessary components of the recommendation. Accounting policies and procedures have been developed and will continue to be implemented.

Prior Finding References

2023-003

About Cash Management →
2024-004
Activities Allowed or Unallowed
MATERIAL WEAKNESS

Missing Support - Internal Control and Compliance - Material Weakness - Noncompliance with Activities Allowed and Unallowed U.S. Department of State - Federal Assistance Listing Number 19.800 Weapons Removal and Abatement Program Criteria Standard auditing practice is to review invoices and other support for numbers recorded in the general ledger. During our testing, four invoices and five contracts for the contracted staff could not be provided. Condition Since the above items could not be provided, we were unable to determine whether federal funds were spent in conjunction with the grant agreement. Cause The Organization does not have a central physical location. The contracted staff are in multiple countries. Effect The Organization is not in compliance with activities allowed and unallowed requirements. Recommendations We recommend that the Organization maintain all pertinent documents in a central location so they can be easily accessed. In addition, all general ledger transactions should be accompanied by support. Views of Responsible Officials Management agrees with the recommendation. Currently working on establishing a better setup with Administration on Google Drive to have every Sub-recipient and Contracted employee upload everything into each individual country folder.

Show full finding ▾
Full finding narrative

Missing Support - Internal Control and Compliance - Material Weakness - Noncompliance with Activities Allowed and Unallowed U.S. Department of State - Federal Assistance Listing Number 19.800 Weapons Removal and Abatement Program Criteria Standard auditing practice is to review invoices and other support for numbers recorded in the general ledger. During our testing, four invoices and five contracts for the contracted staff could not be provided. Condition Since the above items could not be provided, we were unable to determine whether federal funds were spent in conjunction with the grant agreement. Cause The Organization does not have a central physical location. The contracted staff are in multiple countries. Effect The Organization is not in compliance with activities allowed and unallowed requirements. Recommendations We recommend that the Organization maintain all pertinent documents in a central location so they can be easily accessed. In addition, all general ledger transactions should be accompanied by support. Views of Responsible Officials Management agrees with the recommendation. Currently working on establishing a better setup with Administration on Google Drive to have every Sub-recipient and Contracted employee upload everything into each individual country folder.

Corrective Action Plan

Management agrees with the recommendation. Currently working on establishing a better setup with Administration on Google Drive to have every Sub-recipient and Contracted employee upload everything into each individual country folder.

About Activities Allowed or Unallowed →

FY 2023-12-31

FAC accepted this audit on December 27, 2024 — management decision was due June 27, 2025.

2023-002
Other
MATERIAL WEAKNESSREPEAT

The condition reported as Item 2023-001 above also applies to the Organization’s internal control over compliance with the requirements of federal programs. The Organization’s small size and limited staff does not allow for it to have the checks and balances over the reporting and cash management functions that would be present in an ideal set of internal controls. Questioned Costs: None noted. Whether Sampling was Statistically Valid: Sampling was not used. Repeat Finding from Prior Year: This is a repeat finding of a prior year. Cause: Due to the limited staff within the Organization, certain internal controls and other critical systems could lack the necessary safeguards and appropriate compensating controls. Effect: This condition could result in errors being made in the accounting records and federal grant reporting and going undetected due to the lack of “cross-checking.” Further one individual could have the opportunity to perpetrate fraud (by either intentional misstatements of the grant reports, or misappropriation of the Organization’s assets) and conceal it without the proper oversight. Recommendation: We recommend that all accounting areas be evaluated to assure adequate controls are in place and operating as expected. We believe certain oversight or monitoring procedures should be put in place to enhance the systems of internal control. Our recommendation is for the Board to review all accounting and program duties and consider realigning certain incompatible duties to improve internal controls. Views of Responsible Officials: Management agrees with the recommendation and has added an additional board member with a financial background who is working towards developing policies and procedures to implement another layer of oversight and improve documentation of reports submitted for the federal award programs. Management will continue to work to implement the other necessary components of the recommendation.

Show full finding ▾
Full finding narrative

2023-002: Lack of Segregation of Duties & Organizational Monitoring – Internal Control – Material Weakness - U.S. Department of State – Assistance Listing # 19.800 - Weapons Removal and Abatement Program - Criteria: Standard accounting practice for the design of good internal controls requires that no one employee should have access to both physical assets and the related accounting records or to all phases of a transaction. Condition: The condition reported as Item 2023-001 above also applies to the Organization’s internal control over compliance with the requirements of federal programs. The Organization’s small size and limited staff does not allow for it to have the checks and balances over the reporting and cash management functions that would be present in an ideal set of internal controls. Questioned Costs: None noted. Whether Sampling was Statistically Valid: Sampling was not used. Repeat Finding from Prior Year: This is a repeat finding of a prior year. Cause: Due to the limited staff within the Organization, certain internal controls and other critical systems could lack the necessary safeguards and appropriate compensating controls. Effect: This condition could result in errors being made in the accounting records and federal grant reporting and going undetected due to the lack of “cross-checking.” Further one individual could have the opportunity to perpetrate fraud (by either intentional misstatements of the grant reports, or misappropriation of the Organization’s assets) and conceal it without the proper oversight. Recommendation: We recommend that all accounting areas be evaluated to assure adequate controls are in place and operating as expected. We believe certain oversight or monitoring procedures should be put in place to enhance the systems of internal control. Our recommendation is for the Board to review all accounting and program duties and consider realigning certain incompatible duties to improve internal controls. Views of Responsible Officials: Management agrees with the recommendation and has added an additional board member with a financial background who is working towards developing policies and procedures to implement another layer of oversight and improve documentation of reports submitted for the federal award programs. Management will continue to work to implement the other necessary components of the recommendation.

Corrective Action Plan

Response - Management agrees with the recommendation and will continue to work at implementing the necessary components of the recommendation. New board members have come aboard and are working to implement changes. A finance committee has been established (independent of the CEO) and their role will be to ensure the adoption and recommendations of the CAP to ensure transparency and accountability. A bookkeeper was added March 2021 as another tier of financial control, along with CEO handing over some financial duties to the financial advisor and bookkeeper. Regular meetings are held by bookkeeper, financial advisor, and finance committee member of the Board. Please note though, that the small size of our staff, precludes the total elimination of this weakness.

Prior Finding References

2022-002

About Other →
2023-003
Cash Management
MATERIAL WEAKNESSREPEAT

Since there is no reconciliation process in place regarding the amounts sent to and expended by subrecipients, we were unable to determine whether federal funds were being passed through faster than necessary. Questioned Costs: None noted. Whether Sampling was Statistically Valid: Sampling was not used. Repeat Finding from Prior Year: This is a repeat finding of a prior year. Cause: The Organization does not have policies and a process in place to reconcile amounts drawn down on various grants with the amounts being spent on the various grants. Effect: The Organization is not in compliance with cash management and subrecipient monitoring requirements. Recommendation: We recommend that the Organization develop and implement a system whereby they can reconcile their grant drawdowns with the amounts being expended and amounts passed through to subrecipients. We would further recommend that the monthly reports that foreign country managers submit be signed by the party submitting the report and then signed by the International Director once the report is reviewed. Views of Responsible Officials: Management agrees with the recommendation and will work to implement the necessary components of the recommendation. Accounting policies and procedures have been developed and will continue to be implemented in 2023.

Show full finding ▾
Full finding narrative

2023-003: Subrecipient Transfers – Internal Control and Compliance – Material Weakness – Noncompliance with Cash Management & Subrecipient Monitoring - U.S. Department of State – Assistance Listing # 19.800 - Weapons Removal and Abatement Program - Criteria: The Uniform Guidance requires that non-federal entities minimize the time between drawdowns of Federal funds and its expenditure for Federal program purposes. Condition: Since there is no reconciliation process in place regarding the amounts sent to and expended by subrecipients, we were unable to determine whether federal funds were being passed through faster than necessary. Questioned Costs: None noted. Whether Sampling was Statistically Valid: Sampling was not used. Repeat Finding from Prior Year: This is a repeat finding of a prior year. Cause: The Organization does not have policies and a process in place to reconcile amounts drawn down on various grants with the amounts being spent on the various grants. Effect: The Organization is not in compliance with cash management and subrecipient monitoring requirements. Recommendation: We recommend that the Organization develop and implement a system whereby they can reconcile their grant drawdowns with the amounts being expended and amounts passed through to subrecipients. We would further recommend that the monthly reports that foreign country managers submit be signed by the party submitting the report and then signed by the International Director once the report is reviewed. Views of Responsible Officials: Management agrees with the recommendation and will work to implement the necessary components of the recommendation. Accounting policies and procedures have been developed and will continue to be implemented in 2023.

Corrective Action Plan

Response - Management agrees with the recommendation and will implement the necessary components of the recommendation. Accounting policies and procedures have been developed which pertain to our subrecipient reporting and monitoring and are in the process of being implemented. Also, by adding the bookkeeper in March of 2021, receipt spot checking of subrecipients on a monthly basis has been implemented to help ensure compliance.

Prior Finding References

2022-003

About Cash Management →

FY 2022-12-31

FAC accepted this audit on September 28, 2023 — management decision was due March 28, 2024.

2022-002
Other
MATERIAL WEAKNESS

The condition reported as Item 2022-001 above also applies to the Organization?s internal control over compliance with the requirements of federal programs. The Organization?s small size and limited staff does not allow for it to have the checks and balances over the reporting and cash management functions that would be present in an ideal set of internal controls. Questioned Costs: None noted. Whether Sampling was Statistically Valid: Sampling was not used. Repeat Finding from Prior Year: This is a repeat finding of a prior year. Cause: Due to the limited staff within the Organization, certain internal controls and other critical systems could lack the necessary safeguards and appropriate compensating controls. Effect: This condition could result in errors being made in the accounting records and federal grant reporting and going undetected due to the lack of ?cross-checking.? Further one individual could have the opportunity to perpetrate fraud (by either intentional misstatements of the grant reports, or misappropriation of the Organization?s assets) and conceal it without the proper oversight. Recommendation: We recommend that all accounting areas be evaluated to assure adequate controls are in place and operating as expected. We believe certain oversight or monitoring procedures should be put in place to enhance the systems of internal control. Our recommendation is for the Board to review all accounting and program duties and consider realigning certain incompatible duties to improve internal controls. Views of Responsible Officials: Management agrees with the recommendation and has added an additional board member with a financial background who is working towards developing policies and procedures to implement another layer of oversight and improve documentation of reports submitted for the federal award programs. Management will continue to work to implement the other necessary components of the recommendation.

Show full finding ▾
Full finding narrative

2022-002 - Lack of Segregation of Duties & Organizational Monitoring ? Internal Control ? Material Weakness U.S. Department of State ? Assistance Listing # 19.800 Weapons Removal and Abatement Program Criteria: Standard accounting practice for the design of good internal controls requires that no one employee should have access to both physical assets and the related accounting records or to all phases of a transaction. Condition: The condition reported as Item 2022-001 above also applies to the Organization?s internal control over compliance with the requirements of federal programs. The Organization?s small size and limited staff does not allow for it to have the checks and balances over the reporting and cash management functions that would be present in an ideal set of internal controls. Questioned Costs: None noted. Whether Sampling was Statistically Valid: Sampling was not used. Repeat Finding from Prior Year: This is a repeat finding of a prior year. Cause: Due to the limited staff within the Organization, certain internal controls and other critical systems could lack the necessary safeguards and appropriate compensating controls. Effect: This condition could result in errors being made in the accounting records and federal grant reporting and going undetected due to the lack of ?cross-checking.? Further one individual could have the opportunity to perpetrate fraud (by either intentional misstatements of the grant reports, or misappropriation of the Organization?s assets) and conceal it without the proper oversight. Recommendation: We recommend that all accounting areas be evaluated to assure adequate controls are in place and operating as expected. We believe certain oversight or monitoring procedures should be put in place to enhance the systems of internal control. Our recommendation is for the Board to review all accounting and program duties and consider realigning certain incompatible duties to improve internal controls. Views of Responsible Officials: Management agrees with the recommendation and has added an additional board member with a financial background who is working towards developing policies and procedures to implement another layer of oversight and improve documentation of reports submitted for the federal award programs. Management will continue to work to implement the other necessary components of the recommendation.

Corrective Action Plan

2022-002 - Lack of Segregation of Duties & Organizational Monitoring? Internal Control - Material Weakness Recommendation - We recommend that all accounting areas be evaluated to assure adequate controls are in place and operating as expected. We believe certain oversight or monitoring procedures should be put in place to enhance the systems of internal control. Our recommendation is for the Board to review all accounting and program duties and consider realigning certain incompatible duties to improve internal controls.2022-002 - Lack of Segregation of Duties & Organizational Monitoring? Internal Control - Material Weakness (continued) Response - Management agrees with the recommendation and will continue to work at implementing the necessary components of the recommendation. New board members have come aboard and are working to implement changes. A finance committee has been established (independent of the CEO) and their role will be to ensure the adoption and recommendations of the CAP to ensure transparency and accountability. A bookkeeper was added March 2021 as another tier of financial control, along with CEO handing over some financial duties to the financial advisor and bookkeeper. Regular meetings are held by bookkeeper, financial advisor, and finance committee member of the Board. Please note though, that the small size of our staff, precludes the total elimination of this weakness.

About Other →
2022-003
Cash Management / Subrecipient Monitoring
MATERIAL WEAKNESS

Since there is no reconciliation process in place regarding the amounts sent to and expended by subrecipients, we were unable to determine whether federal funds were being passed through faster than necessary. Questioned Costs: None noted. Whether Sampling was Statistically Valid: Sampling was not used. Repeat Finding from Prior Year: This is a repeat finding of a prior year. Cause: The Organization does not have policies and a process in place to reconcile amounts drawn down on various grants with the amounts being spent on the various grants. Effect: The Organization is not in compliance with cash management and subrecipient monitoring requirements. Recommendation: We recommend that the Organization develop and implement a system whereby they can reconcile their grant drawdowns with the amounts being expended and amounts passed through to subrecipients. We would further recommend that the monthly reports that foreign country managers submit be signed by the party submitting the report and then signed by the International Director once the report is reviewed. Views of Responsible Officials: Management agrees with the recommendation and will work to implement the necessary components of the recommendation. Accounting policies and procedures have been developed and will continue to be implemented in 2023.

Show full finding ▾
Full finding narrative

2022-003: Subrecipient Transfers ? Internal Control and Compliance ? Material Weakness ? Noncompliance with Cash Management & Subrecipient Monitoring U.S. Department of State ? Assistance Listing # 19.800 Weapons Removal and Abatement Program Criteria: The Uniform Guidance requires that non-federal entities minimize the time between drawdowns of Federal funds and its expenditure for Federal program purposes. Condition: Since there is no reconciliation process in place regarding the amounts sent to and expended by subrecipients, we were unable to determine whether federal funds were being passed through faster than necessary. Questioned Costs: None noted. Whether Sampling was Statistically Valid: Sampling was not used. Repeat Finding from Prior Year: This is a repeat finding of a prior year. Cause: The Organization does not have policies and a process in place to reconcile amounts drawn down on various grants with the amounts being spent on the various grants. Effect: The Organization is not in compliance with cash management and subrecipient monitoring requirements. Recommendation: We recommend that the Organization develop and implement a system whereby they can reconcile their grant drawdowns with the amounts being expended and amounts passed through to subrecipients. We would further recommend that the monthly reports that foreign country managers submit be signed by the party submitting the report and then signed by the International Director once the report is reviewed. Views of Responsible Officials: Management agrees with the recommendation and will work to implement the necessary components of the recommendation. Accounting policies and procedures have been developed and will continue to be implemented in 2023.

Corrective Action Plan

2022-003 - Subrecipient Transfers ? Internal Control and Compliance - Material Weakness ? Noncompliance with Cash Management & Subrecipient Monitoring Recommendation - We recommend that the Organization develop and implement a system whereby they can reconcile their grant drawdowns with the amounts being expended and amounts passed through to subrecipients. We would further recommend that the monthly reports that foreign country managers submit be signed by the party submitting the report and then signed by the International Director once the report is reviewed. Response - Management agrees with the recommendation and will implement the necessary components of the recommendation. Accounting policies and procedures have been developed which pertain to our subrecipient reporting and monitoring and are in the process of being implemented. Also, by adding the bookkeeper in March of 2021, receipt spot checking of subrecipients on a monthly basis has been implemented to help ensure compliance.

About Cash Management, Subrecipient Monitoring →

FY 2021-12-31

FAC accepted this audit on September 22, 2022 — management decision was due March 22, 2023.

2021-002
Other
MATERIAL WEAKNESSREPEAT

The condition reported as Item 2021-001 above also applies to the Organization?s internal control over compliance with the requirements of federal programs. The Organization?s small size and limited staff does not allow for it to have the checks and balances over the reporting and cash management functions that would be present in an ideal set of internal controls. Questioned Costs: None noted. Whether Sampling was Statistically Valid: Sampling was not used. Repeat Finding from Prior Year: This is a repeat finding of a prior year. Cause: Due to the limited staff within the Organization, certain internal controls and other critical systems could lack the necessary safeguards and appropriate compensating controls. Effect: This condition could result in errors being made in the accounting records and federal grant reporting and going undetected due to the lack of ?cross-checking.? Further one individual could have the opportunity to perpetrate fraud (by either intentional misstatements of the grant reports, or misappropriation of the Organization?s assets) and conceal it without the proper oversight. Recommendation: We recommend that all accounting areas be evaluated to assure adequate controls are in place and operating as expected. We believe certain oversight or monitoring procedures should be put in place to enhance the systems of internal control. Our recommendation is for the Board to review all accounting and program duties and consider realigning certain incompatible duties to improve internal controls. Views of Responsible Officials: Management agrees with the recommendation and has added an additional board member with a financial background who is working towards developing policies and procedures to implement another layer of oversight and improve documentation of reports submitted for the federal award programs. Management will continue to work to implement the other necessary components of the recommendation.

Show full finding ▾
Full finding narrative

2021-002: Lack of Segregation of Duties & Organizational Monitoring ? Internal Control ? Material Weakness U.S. Department of State ? CFDA 19.800 Weapons Removal and Abatement Program January 1, 2021 ? December 31, 2021 Criteria: Standard accounting practice for the design of good internal controls requires that no one employee should have access to both physical assets and the related accounting records or to all phases of a transaction. Condition: The condition reported as Item 2021-001 above also applies to the Organization?s internal control over compliance with the requirements of federal programs. The Organization?s small size and limited staff does not allow for it to have the checks and balances over the reporting and cash management functions that would be present in an ideal set of internal controls. Questioned Costs: None noted. Whether Sampling was Statistically Valid: Sampling was not used. Repeat Finding from Prior Year: This is a repeat finding of a prior year. Cause: Due to the limited staff within the Organization, certain internal controls and other critical systems could lack the necessary safeguards and appropriate compensating controls. Effect: This condition could result in errors being made in the accounting records and federal grant reporting and going undetected due to the lack of ?cross-checking.? Further one individual could have the opportunity to perpetrate fraud (by either intentional misstatements of the grant reports, or misappropriation of the Organization?s assets) and conceal it without the proper oversight. Recommendation: We recommend that all accounting areas be evaluated to assure adequate controls are in place and operating as expected. We believe certain oversight or monitoring procedures should be put in place to enhance the systems of internal control. Our recommendation is for the Board to review all accounting and program duties and consider realigning certain incompatible duties to improve internal controls. Views of Responsible Officials: Management agrees with the recommendation and has added an additional board member with a financial background who is working towards developing policies and procedures to implement another layer of oversight and improve documentation of reports submitted for the federal award programs. Management will continue to work to implement the other necessary components of the recommendation.

Corrective Action Plan

2021-002 - Lack of Segregation of Duties & Organizational Monitoring? Internal Control - Material Weakness Recommendation - We recommend that all accounting areas be evaluated to assure adequate controls are in place and operating as expected. We believe certain oversight or monitoring procedures should be put in place to enhance the systems of internal control. Our recommendation is for the Board to review all accounting and program duties and consider realigning certain incompatible duties to improve internal controls. Response - Management agrees with the recommendation and will continue to work at implementing the necessary components of the recommendation. New board members have come aboard and are working to implement changes. A finance committee has been established (independent of the CEO) and their role will be to ensure the adoption and recommendations of the CAP to ensure transparency and accountability. A bookkeeper was added March 2021 as another tier of financial control, along with CEO handing over some financial duties to the financial advisor and bookkeeper. Regular meetings are held by bookkeeper, financial advisor, and finance committee member of the Board. Please note though, that the small size of our staff, precludes the total elimination of this weakness.

Prior Finding References

2020-002

About Other →
2021-003
Cash Management / Subrecipient Monitoring
MATERIAL WEAKNESSREPEAT

Since there is no reconciliation process in place regarding the amounts sent to and expended by subrecipients, we were unable to determine whether federal funds were being passed through faster than necessary. Questioned Costs: None noted. Whether Sampling was Statistically Valid: Sampling was not used. Repeat Finding from Prior Year: This is a repeat finding of a prior year. Cause: The Organization does not have policies and a process in place to reconcile amounts drawn down on various grants with the amounts being spent on the various grants. Effect: The Organization is not in compliance with cash management and subrecipient monitoring requirements. Recommendation: We recommend that the Organization develop and implement a system whereby they can reconcile their grant drawdowns with the amounts being expended and amounts passed through to subrecipients. We would further recommend that the monthly reports that foreign country managers submit be signed by the party submitting the report and then signed by the International Director once the report is reviewed. Views of Responsible Officials: Management agrees with the recommendation and will work to implement the necessary components of the recommendation. Accounting policies and procedures have been developed and will continue to be implemented in 2021.

Show full finding ▾
Full finding narrative

2021-003: Subrecipient Transfers ? Internal Control and Compliance ? Material Weakness ? Noncompliance with Cash Management & Subrecipient Monitoring U.S. Department of State ? CFDA 19.800 Weapons Removal and Abatement Program January 1, 2021 ? December 31, 2021 Criteria: The Uniform Guidance requires that non-federal entities minimize the time between drawdowns of Federal funds and its expenditure for Federal program purposes. Condition: Since there is no reconciliation process in place regarding the amounts sent to and expended by subrecipients, we were unable to determine whether federal funds were being passed through faster than necessary. Questioned Costs: None noted. Whether Sampling was Statistically Valid: Sampling was not used. Repeat Finding from Prior Year: This is a repeat finding of a prior year. Cause: The Organization does not have policies and a process in place to reconcile amounts drawn down on various grants with the amounts being spent on the various grants. Effect: The Organization is not in compliance with cash management and subrecipient monitoring requirements. Recommendation: We recommend that the Organization develop and implement a system whereby they can reconcile their grant drawdowns with the amounts being expended and amounts passed through to subrecipients. We would further recommend that the monthly reports that foreign country managers submit be signed by the party submitting the report and then signed by the International Director once the report is reviewed. Views of Responsible Officials: Management agrees with the recommendation and will work to implement the necessary components of the recommendation. Accounting policies and procedures have been developed and will continue to be implemented in 2021.

Corrective Action Plan

2021-003 - Subrecipient Transfers ? Internal Control and Compliance - Material Weakness ? Noncompliance with Cash Management & Subrecipient Monitoring Recommendation - We recommend that the Organization develop and implement a system whereby they can reconcile their grant drawdowns with the amounts being expended and amounts passed through to subrecipients. We would further recommend that the monthly reports that foreign country managers submit be signed by the party submitting the report and then signed by the International Director once the report is reviewed. Response - Management agrees with the recommendation and will implement the necessary components of the recommendation. Accounting policies and procedures have been developed which pertain to our subrecipient reporting and monitoring and are in the process of being implemented. Also, by adding the bookkeeper in March of 2021, receipt spot checking of subrecipients on a monthly basis has been implemented to help ensure compliance.

Prior Finding References

2020-003

About Cash Management, Subrecipient Monitoring →

FY 2020-12-31

FAC accepted this audit on September 29, 2021 — management decision was due March 29, 2022.

2020-002
Other
MATERIAL WEAKNESSREPEAT

The condition reported as Item 2020-001 above also applies to the Organization?s internal control over compliance with the requirements of federal programs. The Organization?s small size and limited staff does not allow for it to have the checks and balances over the reporting and cash management functions that would be present in an ideal set of internal controls. Questioned Costs: None noted. Whether Sampling was Statistically Valid: Sampling was not used. Repeat Finding from Prior Year: This is a repeat finding of a prior year. Cause: Due to the limited staff within the Organization, certain internal controls and other critical systems could lack the necessary safeguards and appropriate compensating controls. Effect: This condition could result in errors being made in the accounting records and federal grant reporting and going undetected due to the lack of ?cross-checking.? Further one individual could have the opportunity to perpetrate fraud (by either intentional misstatements of the grant reports, or misappropriation of the Organization?s assets) and conceal it without the proper oversight. Recommendation: We recommend that all accounting areas be evaluated to assure adequate controls are in place and operating as expected. We believe certain oversight or monitoring procedures should be put in place to enhance the systems of internal control. Our recommendation is for the Board to review all accounting and program duties and consider realigning certain incompatible duties to improve internal controls. Views of Responsible Officials: Management agrees with the recommendation and has added an additional board member with a financial background who is working towards developing policies and procedures to implement another layer of oversight and improve documentation of reports submitted for the federal award programs. Management will continue to work to implement the other necessary components of the recommendation.

Show full finding ▾
Full finding narrative

2020-002: Lack of Segregation of Duties & Organizational Monitoring ? Internal Control ? Material Weakness U.S. Department of State ? CFDA 19.800 Weapons Removal and Abatement Program January 1, 2020 ? December 31, 2020 Criteria: Standard accounting practice for the design of good internal controls requires that no one employee should have access to both physical assets and the related accounting records or to all phases of a transaction. Condition: The condition reported as Item 2020-001 above also applies to the Organization?s internal control over compliance with the requirements of federal programs. The Organization?s small size and limited staff does not allow for it to have the checks and balances over the reporting and cash management functions that would be present in an ideal set of internal controls. Questioned Costs: None noted. Whether Sampling was Statistically Valid: Sampling was not used. Repeat Finding from Prior Year: This is a repeat finding of a prior year. Cause: Due to the limited staff within the Organization, certain internal controls and other critical systems could lack the necessary safeguards and appropriate compensating controls. Effect: This condition could result in errors being made in the accounting records and federal grant reporting and going undetected due to the lack of ?cross-checking.? Further one individual could have the opportunity to perpetrate fraud (by either intentional misstatements of the grant reports, or misappropriation of the Organization?s assets) and conceal it without the proper oversight. Recommendation: We recommend that all accounting areas be evaluated to assure adequate controls are in place and operating as expected. We believe certain oversight or monitoring procedures should be put in place to enhance the systems of internal control. Our recommendation is for the Board to review all accounting and program duties and consider realigning certain incompatible duties to improve internal controls. Views of Responsible Officials: Management agrees with the recommendation and has added an additional board member with a financial background who is working towards developing policies and procedures to implement another layer of oversight and improve documentation of reports submitted for the federal award programs. Management will continue to work to implement the other necessary components of the recommendation.

Corrective Action Plan

2020-002 - Lack of Segregation of Duties & Organizational Monitoring? Internal Control - Material Weakness Recommendation - We recommend that all accounting areas be evaluated to assure adequate controls are in place and operating as expected. We believe certain oversight or monitoring procedures should be put in place to enhance the systems of internal control. Our recommendation is for the Board to review all accounting and program duties and consider realigning certain incompatible duties to improve internal controls. Response - Management agrees with the recommendation and will continue to work at implementing the necessary components of the recommendation. New board members have come aboard and are working to implement changes. A finance committee has been established (independent of the CEO) and their role will be to ensure the adoption and recommendations of the CAP to ensure transparency and accountability. A bookkeeper was added March 2021 as another tier of financial control, along with CEO handing over some financial duties to the financial advisor and bookkeeper. Regular meetings are held by bookkeeper, financial advisor, and finance committee member of the Board. Please note though, that the small size of our staff, precludes the total elimination of this weakness.

Prior Finding References

2019-002

About Other →
2020-003
Cash Management / Subrecipient Monitoring
MATERIAL WEAKNESSREPEAT

Since there is no reconciliation process in place regarding the amounts sent to and expended by subrecipients, we were unable to determine whether federal funds were being passed through faster than necessary. Questioned Costs: None noted. Whether Sampling was Statistically Valid: Sampling was not used. Repeat Finding from Prior Year: This is a repeat finding of a prior year. Cause: The Organization does not have policies and a process in place to reconcile amounts drawn down on various grants with the amounts being spent on the various grants. Effect: The Organization is not in compliance with cash management and subrecipient monitoring requirements. Recommendation: We recommend that the Organization develop and implement a system whereby they can reconcile their grant drawdowns with the amounts being expended and amounts passed through to subrecipients. We would further recommend that the monthly reports that foreign country managers submit be signed by the party submitting the report and then signed by the International Director once the report is reviewed. Views of Responsible Officials: Management agrees with the recommendation and will work to implement the necessary components of the recommendation. Accounting policies and procedures have been developed and will continue to be implemented in 2021.

Show full finding ▾
Full finding narrative

2020-003: Subrecipient Transfers ? Internal Control and Compliance ? Material Weakness ? Noncompliance with Cash Management & Subrecipient Monitoring U.S. Department of State ? CFDA 19.800 Weapons Removal and Abatement Program January 1, 2020 ? December 31, 2020 Criteria: The Uniform Guidance requires that non-federal entities minimize the time between drawdowns of Federal funds and its expenditure for Federal program purposes. Condition: Since there is no reconciliation process in place regarding the amounts sent to and expended by subrecipients, we were unable to determine whether federal funds were being passed through faster than necessary. Questioned Costs: None noted. Whether Sampling was Statistically Valid: Sampling was not used. Repeat Finding from Prior Year: This is a repeat finding of a prior year. Cause: The Organization does not have policies and a process in place to reconcile amounts drawn down on various grants with the amounts being spent on the various grants. Effect: The Organization is not in compliance with cash management and subrecipient monitoring requirements. Recommendation: We recommend that the Organization develop and implement a system whereby they can reconcile their grant drawdowns with the amounts being expended and amounts passed through to subrecipients. We would further recommend that the monthly reports that foreign country managers submit be signed by the party submitting the report and then signed by the International Director once the report is reviewed. Views of Responsible Officials: Management agrees with the recommendation and will work to implement the necessary components of the recommendation. Accounting policies and procedures have been developed and will continue to be implemented in 2021.

Corrective Action Plan

2020-003 - Subrecipient Transfers ? Internal Control and Compliance - Material Weakness ? Noncompliance with Cash Management & Subrecipient Monitoring Recommendation - We recommend that the Organization develop and implement a system whereby they can reconcile their grant drawdowns with the amounts being expended and amounts passed through to subrecipients. We would further recommend that the monthly reports that foreign country managers submit be signed by the party submitting the report and then signed by the International Director once the report is reviewed. Response - Management agrees with the recommendation and will implement the necessary components of the recommendation. Accounting policies and procedures have been developed which pertain to our subrecipient reporting and monitoring and are in the process of being implemented. Also, by adding the bookkeeper in March of 2021, receipt spot checking of subrecipients on a monthly basis has been implemented to help ensure compliance.

Prior Finding References

2019-003

About Cash Management, Subrecipient Monitoring →

FY 2019-12-31

FAC accepted this audit on November 15, 2020 — management decision was due May 15, 2021.

2019-002
Other
MATERIAL WEAKNESSREPEAT

The condition reported as Item 2019-001 above also applies to the Organization?s internal control over compliance with the requirements of federal programs. The Organization?s small size and limited staff does not allow for it to have the checks and balances over the reporting and cash management functions that would be present in an ideal set of internal controls. Questioned Costs: None noted. Whether Sampling was Statistically Valid: Sampling was not used. Repeat Finding from Prior Year: This is a repeat finding of a prior year. Cause: Due to the limited staff within the Organization, certain internal controls and other critical systems could lack the necessary safeguards and appropriate compensating controls. Effect: This condition could result in errors being made in the accounting records and federal grant reporting and going undetected due to the lack of ?cross-checking.? Further one individual could have the opportunity to perpetrate fraud (by either intentional misstatements of the grant reports, or misappropriation of the Organization?s assets) and conceal it without the proper oversight. Recommendation: We recommend that all accounting areas be evaluated to assure adequate controls are in place and operating as expected. We believe certain oversight or monitoring procedures should be put in place to enhance the systems of internal control. Our recommendation is for the Board to review all accounting and program duties and consider realigning certain incompatible duties to improve internal controls. Views of Responsible Officials: Management agrees with the recommendation and has added an additional board member with a financial background who is working towards developing policies and procedures to implement another layer of oversight and improve documentation of reports submitted for the federal award programs. Management will continue to work to implement the other necessary components of the recommendation.

Show full finding ▾
Full finding narrative

2019-002: Lack of Segregation of Duties & Organizational Monitoring ? Internal Control ? Material Weakness U.S. Department of State ? CFDA 19.800 Weapons Removal and Abatement Program January 1, 2019 ? December 31, 2019 Criteria: Standard accounting practice for the design of good internal controls requires that no one employee should have access to both physical assets and the related accounting records or to all phases of a transaction. Condition: The condition reported as Item 2019-001 above also applies to the Organization?s internal control over compliance with the requirements of federal programs. The Organization?s small size and limited staff does not allow for it to have the checks and balances over the reporting and cash management functions that would be present in an ideal set of internal controls. Questioned Costs: None noted. Whether Sampling was Statistically Valid: Sampling was not used. Repeat Finding from Prior Year: This is a repeat finding of a prior year. Cause: Due to the limited staff within the Organization, certain internal controls and other critical systems could lack the necessary safeguards and appropriate compensating controls. Effect: This condition could result in errors being made in the accounting records and federal grant reporting and going undetected due to the lack of ?cross-checking.? Further one individual could have the opportunity to perpetrate fraud (by either intentional misstatements of the grant reports, or misappropriation of the Organization?s assets) and conceal it without the proper oversight. Recommendation: We recommend that all accounting areas be evaluated to assure adequate controls are in place and operating as expected. We believe certain oversight or monitoring procedures should be put in place to enhance the systems of internal control. Our recommendation is for the Board to review all accounting and program duties and consider realigning certain incompatible duties to improve internal controls. Views of Responsible Officials: Management agrees with the recommendation and has added an additional board member with a financial background who is working towards developing policies and procedures to implement another layer of oversight and improve documentation of reports submitted for the federal award programs. Management will continue to work to implement the other necessary components of the recommendation.

Corrective Action Plan

2019-002 - Lack of Segregation of Duties & Organizational Monitoring? Internal Control - Material Weakness Recommendation - We recommend that all accounting areas be evaluated to assure adequate controls are in place and operating as expected. We believe certain oversight or monitoring procedures should be put in place to enhance the systems of internal control. Our recommendation is for the Board to review all accounting and program duties and consider realigning certain incompatible duties to improve internal controls. Response - Management agrees with the recommendation and will continue to work at implementing the necessary components of the recommendation. New board members have come aboard and are working to implement changes. A finance committee has been established (independent of the CEO) and their role will be to ensure the adoption and recommendations of the CAP to ensure transparency and accountability. Please note though, that the small size of our staff, precludes the total elimination of this weakness.

Prior Finding References

2018-002

About Other →
2019-003
Cash Management / Subrecipient Monitoring
MATERIAL WEAKNESSREPEAT

Since there is no reconciliation process in place regarding the amounts sent to and expended by subrecipients, we were unable to determine whether federal funds were being passed through faster than necessary. Questioned Costs: None noted. Whether Sampling was Statistically Valid: Sampling was not used. Repeat Finding from Prior Year: This is a repeat finding of a prior year. Cause: The Organization does not have policies and a process in place to reconcile amounts drawn down on various grants with the amounts being spent on the various grants. Effect: The Organization is not in compliance with cash management and subrecipient monitoring requirements. Recommendation: We recommend that the Organization develop and implement a system whereby they can reconcile their grant drawdowns with the amounts being expended and amounts passed through to subrecipients. We would further recommend that the monthly reports that foreign country managers submit be signed by the party submitting the report and then signed by the International Director once the report is reviewed. Views of Responsible Officials: Management agrees with the recommendation and will work to implement the necessary components of the recommendation. Accounting policies and procedures have been developed and will continue to be implemented in 2020.

Show full finding ▾
Full finding narrative

2019-003: Subrecipient Transfers ? Internal Control and Compliance ? Material Weakness ? Noncompliance with Cash Management & Subrecipient Monitoring U.S. Department of State ? CFDA 19.800 Weapons Removal and Abatement Program January 1, 2019 ? December 31, 2019 Criteria: The Uniform Guidance requires that non-federal entities minimize the time between drawdowns of Federal funds and its expenditure for Federal program purposes. Condition: Since there is no reconciliation process in place regarding the amounts sent to and expended by subrecipients, we were unable to determine whether federal funds were being passed through faster than necessary. Questioned Costs: None noted. Whether Sampling was Statistically Valid: Sampling was not used. Repeat Finding from Prior Year: This is a repeat finding of a prior year. Cause: The Organization does not have policies and a process in place to reconcile amounts drawn down on various grants with the amounts being spent on the various grants. Effect: The Organization is not in compliance with cash management and subrecipient monitoring requirements. Recommendation: We recommend that the Organization develop and implement a system whereby they can reconcile their grant drawdowns with the amounts being expended and amounts passed through to subrecipients. We would further recommend that the monthly reports that foreign country managers submit be signed by the party submitting the report and then signed by the International Director once the report is reviewed. Views of Responsible Officials: Management agrees with the recommendation and will work to implement the necessary components of the recommendation. Accounting policies and procedures have been developed and will continue to be implemented in 2020.

Corrective Action Plan

2019-003 - Subrecipient Transfers ? Internal Control and Compliance - Material Weakness ? Noncompliance with Cash Management & Subrecipient Monitoring Recommendation - We recommend that the Organization develop and implement a system whereby they can reconcile their grant drawdowns with the amounts being expended and amounts passed through to subrecipients. We would further recommend that the monthly reports that foreign country managers submit be signed by the party submitting the report and then signed by the International Director once the report is reviewed. Response - Management agrees with the recommendation and will implement the necessary components of the recommendation. Accounting policies and procedures have been developed which pertain to our subrecipient reporting and monitoring and will be implemented in 2020.

Prior Finding References

2018-004

About Cash Management, Subrecipient Monitoring →

FY 2018-12-31

FAC accepted this audit on September 29, 2019 — management decision was due March 29, 2020.

2018-002
Other
MATERIAL WEAKNESSREPEAT

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-004

About Other →
2018-003
Cash Management
MATERIAL WEAKNESSREPEAT

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-006

About Cash Management →
2018-004
Cash Management / Subrecipient Monitoring
MATERIAL WEAKNESSREPEAT

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-007

About Cash Management, Subrecipient Monitoring →

FY 2017-12-31

FAC accepted this audit on September 27, 2018 — management decision was due March 27, 2019.

2017-004
Other
MATERIAL WEAKNESSREPEAT

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-004

About Other →
2017-005
Other
MATERIAL WEAKNESSREPEAT

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-005

About Other →
2017-006
Cash Management
MATERIAL WEAKNESSREPEAT

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-006

About Cash Management →
2017-007
Cash Management / Subrecipient Monitoring
MATERIAL WEAKNESSREPEAT

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-007

About Cash Management, Subrecipient Monitoring →
2017-008
Other
REPEAT

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-008

About Other →

FY 2016-12-31

FAC accepted this audit on September 28, 2017 — management decision was due March 28, 2018.

2016-004
Other
MATERIAL WEAKNESS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Other →
2016-005
Other
MATERIAL WEAKNESS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Other →
2016-006
Cash Management
MATERIAL WEAKNESSREPEAT

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2015-003

About Cash Management →
2016-007
Cash Management / Subrecipient Monitoring
MATERIAL WEAKNESS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Cash Management, Subrecipient Monitoring →
2016-008
Other

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Other →

Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.

Are you this organization?

Track your findings and corrective action plans across audit cycles.

Start tracking findings →

Do you fund this organization?

Monitor subrecipient audit findings and compliance status.

Start monitoring →

Product

Resources

Legal

Single Audit Intelligence is an independent tool powered by Federal Audit Clearinghouse data. Not affiliated with GSA, OMB, or any federal agency.

© 2026 Single Audit Intelligence. All data is public domain.