Panthera CorporationNon-Profit

2024-001: Activities Allowed or Unallowed & Allowable Costs/Cost Principles - Material Weakness in Internal Control and Material Noncompliance Repeat of Prior Audit Finding 2023-001 Federal Program: Trans-National Crime Federal Agency: U.S. Department of State - Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2024 Criteria: 2 CFR section 200.303(a) of the Uniform Guidance requires all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. In addition, 2 CFR sections 200.405 and 200.403(g) require federal awards be expended only for allowable activities and be adequately documented, respectively. Condition/Context: The Corporation was unable to provide a signed contract or reconciliation to evidence allowability of the expenditures or documentation of review and approval for the following: • For 5 out of 40 selections, no evidence of approval of signed contract could be provided (control). • For 6 out of 40 selections, no evidence of signed contract or reconciliation support could be provided (compliance). This was not a statistically valid sample. Questioned Costs: Questioned costs were approximately $19,428. Cause: The Corporation did not retain/could not retrieve the signed contract or due to poor document retention. Effect: The Corporation has not complied with the specific requirements for activities allowed or unallowed and allowable costs/cost principles as described in the Uniform Guidance. Unallowable costs may have been charged to the federal program. Recommendation: We recommend that the Corporation review its process and implement procedures that would allow management to properly maintain all required documentation on its federal expenditures. Views of Responsible Officials: The Corporation has sustained and built upon the improvements achieved in 2023, maintaining a reduced occurrence of the findings noted in prior audits. The HR solution, Rippling, implemented in 2024, continues to be an integral part of ensuring that all agreements and rate changes are accurately tracked and fully documented. This system has strengthened the Corporation’s document retention practices and supported ongoing compliance with federal regulations. The rollout of Rippling’s timesheet module was completed for all of the Corporation’s South American entities, Central America, UK, France, Gabon and Senegal. The Corporation continued roll out into 2025 and completed that for all remaining entities including Thailand, Malaysia, UAE, Saudia Arabia, Central and South Africa.

2023-001: Activities Allowed or Unallowed & Allowable Costs/Cost Principles - Material Weakness in Internal Control and Material Noncompliance Repeat of Prior Audit Finding 2022-001 Federal Program: Trans-National Crime Federal Agency: U.S. Department of State - Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2023 Criteria: 2 CFR section 200.303(a) of the Uniform Guidance requires all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. In addition, 2 CFR sections 200.405 and 200.403(g) require federal awards be expended only for allowable activities and be adequately documented, respectively. Condition/Context: The Corporation was unable to provide a signed contract, payment information, invoice or reconciliation to evidence allowability of the expenditures or documentation of review and approval for the following: • For 3 out of 80 selections, no evidence of approval of the invoice or approval of signed contract could be provided (control). • For 27 out of 80 selections, no evidence of signed contract or payment support could be provided (compliance). This was not a statistically valid sample. Questioned Costs: Questioned costs were approximately $24,563. Cause: The Corporation did not retain/could not retrieve the signed contract or any related support for the disbursements due to poor document retention and staffing turnover and did not follow its internal control procedures by including formal, written review of disbursement payments. Effect: The Corporation has not complied with the specific requirements for activities allowed or unallowed and allowable costs/cost principles as described in the Uniform Guidance. Unallowable costs may have been charged to the federal program. Recommendation: We recommend that the Corporation review its process and implement procedures that would allow management to properly maintain all required documentation on its federal expenditures. Views of Responsible Officials: Over the past year, the Corporation has made significant improvements, reducing the occurrence of these findings compared to 2022. To continue to improve on and address this, the Corporation implemented a new HR solution, Rippling, in 2024, which will ensure all future agreements and rate changes are properly tracked and documented. This system will enhance the Corporation's document retention process and ensure compliance with federal regulations moving forward.

2023-002: Subrecipient Monitoring - Significant Deficiency Internal Control and Compliance Repeat of Prior Audit Finding 2022-005 Federal Program: Trans-National Crime Federal Agency: U.S. Department of State - Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2023 Criteria: 2 CFR section 200.303(a) of the Uniform Guidance requires all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. In addition, 2 CFR section 200.332 requires pass-through entities to monitor the subrecipient, including verifying that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's federal expenditures exceed the threshold. Condition/Context: For the selection of 2 subrecipients, the Corporation did not inquire of the subrecipients to confirm their applicability of an annual Uniform Guidance audit, nor does the Corporation request a copy of the Uniform Guidance audit report to be provided, when applicable. This was not a statistically valid sample. Questioned Costs: Not determinable. Cause: The Corporation's procedures did not include this process as part of its policies and procedures. As a result, the Corporation did not request for an affirmation or a copy of the Uniform Guidance audit to be provided. Consequently, the Corporation did not verify whether the Uniform Guidance audit was applicable to any of its subrecipients. Effect: The Corporation's control design and operation does not provide reasonable assurance that the Corporation is managing the subrecipient monitoring requirements of the Uniform Guidance. Recommendation: We recommend that the Corporation appropriately monitor its subrecipients to ensure that they are being audited in accordance with the Uniform Guidance, when applicable. In the event that such subrecipients do not require a Uniform Guidance audit, the Corporation should obtain and retain supporting documentation such as an affirmation letter from the subrecipients. When a subrecipient is subject to the Uniform Guidance audit, the Corporation should obtain a copy of the related audit report and perform a review of such audit report and note any potential findings that could pertain to the funding that the Corporation provided to such subrecipient. In addition, the Corporation should consider checking the Federal Audit Clearinghouse website to verify if its subrecipients submitted the single audit reporting package in the year that the Corporation funded. View of Responsible Officials: The Corporation will implement a process to obtain single audit affirmation letters from subrecipients annually, if applicable, and confirm as per current understanding and discussions with subrecipients during the due diligence process that their funding from the United States federal government sources during the agreement period will not exceed $750,000 annually. These steps will ensure proper subrecipient monitoring in alignment with federal regulations.

Repeat of Prior Audit Finding 2021-001 Federal Program: Trans-National Crime Federal Agencies: United States Department of State- United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200.303(a) of the Uniform Guidance require all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. In addition, 2 CFR section 200.405 requires federal awards be expended only for allowable activities. Condition/Context: Panthera Corporation was unable to provide a signed contract, payment information, invoice or reconciliation to evidence allowability of the expenditures or documentation of review and approval for the following: ? For 34 out of 80 selections, no evidence of approval of the invoice or approval of signed contract could be provided (control) ? For 63 out of 80 selections, no evidence of approval of payment could be provided (control) ? For 46 out of 80 selections, no evidence of signed contract or payment support could be provided (compliance) This was not a statistically valid sample. Questioned Costs: Questioned costs were approximately $65,341. Cause: Panthera Corporation did not retain/could not retrieve the signed contract or any related support for the disbursements due to poor document retention and staffing turnover and did not follow its internal control procedures by including formal, written review of disbursement payments. Effect: Panthera Corporation has not complied with the specific requirements for activities allowed or unallowed and allowable costs/cost principles as described in the Uniform Guidance. Unallowable costs may have been charged to the federal program. Recommendation: We recommend that Panthera Corporation review its process and implement procedures that would allow management to properly maintain all required documentation on its federal expenditures. Views of Responsible Officials: Management acknowledges the finding and is in the process of attaining the proper systems to adequately track and maintain documentation including the review and approval process.

Repeat of Prior Audit Finding 2021-001 Federal Program: Trans-National Crime Federal Agency: United States Department of State - United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200.303(a) of the Uniform Guidance require all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. In addition, 2 CFR section 200.405 requires federal awards be expended only for allowable activities.   Condition/Context: Panthera Corporation was unable to provide a signed contract, payment information, invoice or reconciliation to evidence allowability of the expenditures or documentation of review and approval for the following: • For 34 out of 80 selections, no evidence of approval of the invoice or approval of signed contract could be provided (control). • For 63 out of 80 selections, no evidence of approval of payment could be provided (control). • For 46 out of 80 selections, no evidence of signed contract or payment support could be provided (compliance). This was not a statistically valid sample. Questioned Costs: Questioned costs were approximately $65,341. Cause: Panthera Corporation did not retain/could not retrieve the signed contract or any related support for the disbursements due to poor document retention and staffing turnover and did not follow its internal control procedures by including formal, written review of disbursement payments. Effect: Panthera Corporation has not complied with the specific requirements for activities allowed or unallowed and allowable costs/cost principles as described in the Uniform Guidance. Unallowable costs may have been charged to the federal program. Recommendation: We recommend that Panthera Corporation review its process and implement procedures that would allow management to properly maintain all required documentation on its federal expenditures. Views of Responsible Officials: Management acknowledges the finding and is in the process of attaining the proper systems to adequately track and maintain documentation including the review and approval process.

Repeat of Prior Audit Finding 2021-002 Federal Program: Trans-National Crime Federal Agencies: United States Department of State- United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200.303(a) of the Uniform Guidance require all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that a non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. Condition/Context: Panthera Corporation prepares and reviews a quarterly expenditure file to track and compile quarterly costs to be submitted for reimbursement to the funding agency. For the selection of 2 quarterly expenditure files, we were unable to verify that the file was formally reviewed prior to requesting reimbursement. This was not a statistically valid sample. Questioned Costs: None Cause: Panthera Corporation developed written cash management procedures, however, did not follow such procedures by including formal, written review of quarterly expenditure files. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is appropriately managing the cash management compliance requirement of the Uniform Guidance. Improper cash drawdowns could occur. Recommendation: We recommend that Panthera Corporation implement written approval on their quarterly expenditure files. Views of Responsible Officials: Management acknowledges the finding and has implemented an approval process within Chrome River.

Repeat of Prior Audit Finding 2021-002 Federal Program: Trans-National Crime Federal Agency: United States Department of State - United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200.303(a) of the Uniform Guidance require all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that a non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. Condition/Context: Panthera Corporation prepares and reviews a quarterly expenditure file to track and compile quarterly costs to be submitted for reimbursement to the funding agency. For the selection of two quarterly expenditure files, we were unable to verify that the file was formally reviewed prior to requesting reimbursement. This was not a statistically valid sample.  Questioned Costs: None Cause: Panthera Corporation developed written cash management procedures, however, did not follow such procedures by including formal, written review of quarterly expenditure files. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is appropriately managing the cash management compliance requirement of the Uniform Guidance. Improper cash drawdowns could occur. Recommendation: We recommend that Panthera Corporation implement written approval on their quarterly expenditure files. Views of Responsible Officials: Management acknowledges the finding and has implemented an approval process within Chrome River.

Repeat of Prior Audit Finding 2021-003 Federal Program: Trans-National Crime Federal Agencies: United States Department of State- United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200.303(a) of the Uniform Guidance requires all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that a non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. 2 CFR Part 200.306 of the Uniform Guidance requires shared costs or matching funds be accepted as part of the non-Federal entity's cost sharing or matching when they are verifiable, necessary and reasonable and are allowable. Condition/Context: Panthera Corporation prepares and reviews a quarterly expenditure file to track and compile quarterly costs and calculate the cost-sharing component to be submitted for reimbursement to the funding agency. For the selection of 2 quarterly expenditure files, we were unable to verify that the file was formally reviewed. This was not a statistically valid sample. Questioned Costs: None Cause: Panthera Corporation developed written matching procedures, however, did not follow such procedures by including formal, written review of quarterly expenditure files. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is managing the matching compliance requirement of the Uniform Guidance. Recommendation: We recommend that Panthera Corporation implement documented approval on their quarterly expenditure files. Views of Responsible Officials: Management acknowledges the finding and has implemented an approval process within Chrome River.

Federal Program: Trans-National Crime Federal Agency: United States Department of State - United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200.303(a) of the Uniform Guidance requires all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that a non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. 2 CFR Part 200.306 of the Uniform Guidance requires shared costs or matching funds be accepted as part of the non-Federal entity's cost sharing or matching when they are verifiable, necessary and reasonable and are allowable. Condition/Context: Panthera Corporation prepares and reviews a quarterly expenditure file to track and compile quarterly costs and calculate the cost-sharing component to be submitted for reimbursement to the funding agency. For the selection of two quarterly expenditure files, we were unable to verify that the file was formally reviewed. This was not a statistically valid sample. Questioned Costs: None Cause: Panthera Corporation developed written matching procedures, however, did not follow such procedures by including formal, written review of quarterly expenditure files. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is managing the matching compliance requirement of the Uniform Guidance. Recommendation: We recommend that Panthera Corporation implement documented approval on their quarterly expenditure files. Views of Responsible Officials: Management acknowledges the finding and has implemented an approval process within Chrome River.

Repeat of Prior Audit Finding 2021-004 Federal Program: Trans-National Crime Federal Agencies: United States Department of State- United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200 Subpart D Section 200.320 identifies small purchases as purchases greater than the micro-purchase threshold but not exceeding the simplified acquisition threshold. For small purchases, rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. 2 CFR Part 200 Subpart D Section 200.320 (c) of the Uniform Guidance establishes specific circumstances in which noncompetitive procurement can be used. Condition/Context: For the selection of 2 subcontractors which was utilized by Panthera Corporation during the year that received federal expenditures greater than the micro-purchase threshold, but did not exceed the simplified acquisition threshold, this purchase did not go through a procurement process. Management asserted that one subcontractor came highly recommended and the other was due to space limitations for an event, however, Panthera Corporation did not document these rationales at the time the contract was awarded, nor were they able to provide documentation that the subcontractors satisfied the specific circumstances for which noncompetitive procurement can be used. This was not a statistically valid sample. Questioned Costs: Not determinable Cause: Panthera Corporation developed written procurement procedures, however, did not follow such procedures in obtaining competitive bids or maintaining documentation to support why competitive bids could not be obtained. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is managing the procurement compliance requirement of the Uniform Guidance. Recommendation: We recommend that Panthera Corporation follow its policies and procedures by ensuring that purchases requiring procurement go through the appropriate procurement process as well as maintaining documentation to allow for an audit trail. Views of Responsible Officials: Management acknowledges the finding and has implemented an approval process.

Repeat of Prior Audit Finding 2021-004 Federal Program: Trans-National Crime Federal Agency: United States Department of State - United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200 Subpart D Section 200.320 identifies small purchases as purchases greater than the micro-purchase threshold but not exceeding the simplified acquisition threshold. For small purchases, rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. 2 CFR Part 200 Subpart D Section 200.320 (c) of the Uniform Guidance establishes specific circumstances in which noncompetitive procurement can be used. Condition/Context: For the selection of two subcontractors which was utilized by Panthera Corporation during the year that received federal expenditures greater than the micro-purchase threshold, but did not exceed the simplified acquisition threshold, this purchase did not go through a procurement process. Management asserted that one subcontractor came highly recommended, and the other was due to space limitations for an event, however, Panthera Corporation did not document these rationales at the time the contract was awarded, nor were they able to provide documentation that the subcontractors satisfied the specific circumstances for which noncompetitive procurement can be used. This was not a statistically valid sample. Questioned Costs: Not determinable. Cause: Panthera Corporation developed written procurement procedures, however, did not follow such procedures in obtaining competitive bids or maintaining documentation to support why competitive bids could not be obtained. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is managing the procurement compliance requirement of the Uniform Guidance. Recommendation: We recommend that Panthera Corporation follow its policies and procedures by ensuring that purchases requiring procurement go through the appropriate procurement process as well as maintaining documentation to allow for an audit trail. Views of Responsible Officials: Management acknowledges the finding and has implemented an approval process.

Repeat of Prior Audit Finding 2021-005 Federal Program: Trans-National Crime Federal Agencies: United States Department of State- United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200, Subpart D Section 200.332 of the Uniform Guidance require all non-Federal entities to assess subrecipients' risk, as well as monitor sub-awards passed through. All requirements imposed by the pass-through entity on the subrecipient are to ensure that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award. Condition/Context: For the selection of 2 subrecipients, we were unable to verify that the respective subaward agreements contained accurate award information, such as the identification of the funding being U.S. federal funds, the federal Assistance Listing Number and the requirements that the subrecipients would need to comply with the Uniform Guidance. In addition, for 2 other subrecipients, we could not determine the quarterly programmatic and financial reports were reviewed or approved by Panthera Corporation as there was no evidence of formal review and approval. There was also no evidence that those subrecipients had been audited or monitored under appropriate local government regulations. This was not a statistically valid sample. Questioned Costs: Not determinable Cause: Panthera Corporation's procedures did not ensure the required written subrecipient monitoring policies were implemented in accordance with the Uniform Guidance. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is managing the subrecipient monitoring requirements of the Uniform Guidance. Recommendation: We recommend that Panthera Corporation clearly identify in each agreement with subrecipients the reference to the applicable federal Assistance Listing Number and request audited reports from subrecipients when applicable. We further recommend that Panthera Corporation follow its policies and procedures by ensuring that subrecipient quarterly reports are subject to the appropriate process as well as maintaining documentation to allow for an audit trail. View of Responsible Officials: Management acknowledges the finding and will be retaining support and updating subrecipient agreements to include the relevant award information and the Uniform Guidance compliance requirements for subrecipients.

Repeat of Prior Audit Finding 2021-005 Federal Program: Trans-National Crime Federal Agency: United States Department of State - United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200, Subpart D Section 200.332 of the Uniform Guidance require all non-Federal entities to assess subrecipients' risk, as well as monitor sub-awards passed through. All requirements imposed by the pass-through entity on the subrecipient are to ensure that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award. Condition/Context: For the selection of two subrecipients, we were unable to verify that the respective subaward agreements contained accurate award information, such as the identification of the funding being U.S. federal funds, the federal Assistance Listing Number and the requirements that the subrecipients would need to comply with the Uniform Guidance. In addition, for two other subrecipients, we could not determine whether the quarterly programmatic and financial reports were reviewed or approved by Panthera Corporation as there was no evidence of formal review and approval. There was also no evidence that those subrecipients had been audited or monitored under appropriate local government regulations. This was not a statistically valid sample. Questioned Costs: Not determinable. Cause: Panthera Corporation's procedures did not ensure the required written subrecipient monitoring policies were implemented in accordance with the Uniform Guidance. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is managing the subrecipient monitoring requirements of the Uniform Guidance. Recommendation: We recommend that Panthera Corporation clearly identify in each agreement with subrecipients the reference to the applicable federal Assistance Listing Number and request audited reports from subrecipients when applicable. We further recommend that Panthera Corporation follow its policies and procedures by ensuring that subrecipient quarterly reports are subject to the appropriate process as well as maintaining documentation to allow for an audit trail. View of Responsible Officials: Management acknowledges the finding and will be retaining support and updating subrecipient agreements to include the relevant award information and the Uniform Guidance compliance requirements for subrecipients.

Repeat of Prior Audit Finding 2021-001 Federal Program: Trans-National Crime Federal Agencies: United States Department of State- United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200.303(a) of the Uniform Guidance require all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. In addition, 2 CFR section 200.405 requires federal awards be expended only for allowable activities. Condition/Context: Panthera Corporation was unable to provide a signed contract, payment information, invoice or reconciliation to evidence allowability of the expenditures or documentation of review and approval for the following: ? For 34 out of 80 selections, no evidence of approval of the invoice or approval of signed contract could be provided (control) ? For 63 out of 80 selections, no evidence of approval of payment could be provided (control) ? For 46 out of 80 selections, no evidence of signed contract or payment support could be provided (compliance) This was not a statistically valid sample. Questioned Costs: Questioned costs were approximately $65,341. Cause: Panthera Corporation did not retain/could not retrieve the signed contract or any related support for the disbursements due to poor document retention and staffing turnover and did not follow its internal control procedures by including formal, written review of disbursement payments. Effect: Panthera Corporation has not complied with the specific requirements for activities allowed or unallowed and allowable costs/cost principles as described in the Uniform Guidance. Unallowable costs may have been charged to the federal program. Recommendation: We recommend that Panthera Corporation review its process and implement procedures that would allow management to properly maintain all required documentation on its federal expenditures. Views of Responsible Officials: Management acknowledges the finding and is in the process of attaining the proper systems to adequately track and maintain documentation including the review and approval process.

Repeat of Prior Audit Finding 2021-001 Federal Program: Trans-National Crime Federal Agency: United States Department of State - United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200.303(a) of the Uniform Guidance require all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. In addition, 2 CFR section 200.405 requires federal awards be expended only for allowable activities.   Condition/Context: Panthera Corporation was unable to provide a signed contract, payment information, invoice or reconciliation to evidence allowability of the expenditures or documentation of review and approval for the following: • For 34 out of 80 selections, no evidence of approval of the invoice or approval of signed contract could be provided (control). • For 63 out of 80 selections, no evidence of approval of payment could be provided (control). • For 46 out of 80 selections, no evidence of signed contract or payment support could be provided (compliance). This was not a statistically valid sample. Questioned Costs: Questioned costs were approximately $65,341. Cause: Panthera Corporation did not retain/could not retrieve the signed contract or any related support for the disbursements due to poor document retention and staffing turnover and did not follow its internal control procedures by including formal, written review of disbursement payments. Effect: Panthera Corporation has not complied with the specific requirements for activities allowed or unallowed and allowable costs/cost principles as described in the Uniform Guidance. Unallowable costs may have been charged to the federal program. Recommendation: We recommend that Panthera Corporation review its process and implement procedures that would allow management to properly maintain all required documentation on its federal expenditures. Views of Responsible Officials: Management acknowledges the finding and is in the process of attaining the proper systems to adequately track and maintain documentation including the review and approval process.

Repeat of Prior Audit Finding 2021-002 Federal Program: Trans-National Crime Federal Agencies: United States Department of State- United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200.303(a) of the Uniform Guidance require all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that a non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. Condition/Context: Panthera Corporation prepares and reviews a quarterly expenditure file to track and compile quarterly costs to be submitted for reimbursement to the funding agency. For the selection of 2 quarterly expenditure files, we were unable to verify that the file was formally reviewed prior to requesting reimbursement. This was not a statistically valid sample. Questioned Costs: None Cause: Panthera Corporation developed written cash management procedures, however, did not follow such procedures by including formal, written review of quarterly expenditure files. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is appropriately managing the cash management compliance requirement of the Uniform Guidance. Improper cash drawdowns could occur. Recommendation: We recommend that Panthera Corporation implement written approval on their quarterly expenditure files. Views of Responsible Officials: Management acknowledges the finding and has implemented an approval process within Chrome River.

Repeat of Prior Audit Finding 2021-002 Federal Program: Trans-National Crime Federal Agency: United States Department of State - United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200.303(a) of the Uniform Guidance require all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that a non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. Condition/Context: Panthera Corporation prepares and reviews a quarterly expenditure file to track and compile quarterly costs to be submitted for reimbursement to the funding agency. For the selection of two quarterly expenditure files, we were unable to verify that the file was formally reviewed prior to requesting reimbursement. This was not a statistically valid sample.  Questioned Costs: None Cause: Panthera Corporation developed written cash management procedures, however, did not follow such procedures by including formal, written review of quarterly expenditure files. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is appropriately managing the cash management compliance requirement of the Uniform Guidance. Improper cash drawdowns could occur. Recommendation: We recommend that Panthera Corporation implement written approval on their quarterly expenditure files. Views of Responsible Officials: Management acknowledges the finding and has implemented an approval process within Chrome River.

Repeat of Prior Audit Finding 2021-003 Federal Program: Trans-National Crime Federal Agencies: United States Department of State- United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200.303(a) of the Uniform Guidance requires all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that a non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. 2 CFR Part 200.306 of the Uniform Guidance requires shared costs or matching funds be accepted as part of the non-Federal entity's cost sharing or matching when they are verifiable, necessary and reasonable and are allowable. Condition/Context: Panthera Corporation prepares and reviews a quarterly expenditure file to track and compile quarterly costs and calculate the cost-sharing component to be submitted for reimbursement to the funding agency. For the selection of 2 quarterly expenditure files, we were unable to verify that the file was formally reviewed. This was not a statistically valid sample. Questioned Costs: None Cause: Panthera Corporation developed written matching procedures, however, did not follow such procedures by including formal, written review of quarterly expenditure files. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is managing the matching compliance requirement of the Uniform Guidance. Recommendation: We recommend that Panthera Corporation implement documented approval on their quarterly expenditure files. Views of Responsible Officials: Management acknowledges the finding and has implemented an approval process within Chrome River.

Federal Program: Trans-National Crime Federal Agency: United States Department of State - United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200.303(a) of the Uniform Guidance requires all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that a non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. 2 CFR Part 200.306 of the Uniform Guidance requires shared costs or matching funds be accepted as part of the non-Federal entity's cost sharing or matching when they are verifiable, necessary and reasonable and are allowable. Condition/Context: Panthera Corporation prepares and reviews a quarterly expenditure file to track and compile quarterly costs and calculate the cost-sharing component to be submitted for reimbursement to the funding agency. For the selection of two quarterly expenditure files, we were unable to verify that the file was formally reviewed. This was not a statistically valid sample. Questioned Costs: None Cause: Panthera Corporation developed written matching procedures, however, did not follow such procedures by including formal, written review of quarterly expenditure files. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is managing the matching compliance requirement of the Uniform Guidance. Recommendation: We recommend that Panthera Corporation implement documented approval on their quarterly expenditure files. Views of Responsible Officials: Management acknowledges the finding and has implemented an approval process within Chrome River.

Repeat of Prior Audit Finding 2021-004 Federal Program: Trans-National Crime Federal Agencies: United States Department of State- United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200 Subpart D Section 200.320 identifies small purchases as purchases greater than the micro-purchase threshold but not exceeding the simplified acquisition threshold. For small purchases, rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. 2 CFR Part 200 Subpart D Section 200.320 (c) of the Uniform Guidance establishes specific circumstances in which noncompetitive procurement can be used. Condition/Context: For the selection of 2 subcontractors which was utilized by Panthera Corporation during the year that received federal expenditures greater than the micro-purchase threshold, but did not exceed the simplified acquisition threshold, this purchase did not go through a procurement process. Management asserted that one subcontractor came highly recommended and the other was due to space limitations for an event, however, Panthera Corporation did not document these rationales at the time the contract was awarded, nor were they able to provide documentation that the subcontractors satisfied the specific circumstances for which noncompetitive procurement can be used. This was not a statistically valid sample. Questioned Costs: Not determinable Cause: Panthera Corporation developed written procurement procedures, however, did not follow such procedures in obtaining competitive bids or maintaining documentation to support why competitive bids could not be obtained. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is managing the procurement compliance requirement of the Uniform Guidance. Recommendation: We recommend that Panthera Corporation follow its policies and procedures by ensuring that purchases requiring procurement go through the appropriate procurement process as well as maintaining documentation to allow for an audit trail. Views of Responsible Officials: Management acknowledges the finding and has implemented an approval process.

Repeat of Prior Audit Finding 2021-004 Federal Program: Trans-National Crime Federal Agency: United States Department of State - United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200 Subpart D Section 200.320 identifies small purchases as purchases greater than the micro-purchase threshold but not exceeding the simplified acquisition threshold. For small purchases, rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. 2 CFR Part 200 Subpart D Section 200.320 (c) of the Uniform Guidance establishes specific circumstances in which noncompetitive procurement can be used. Condition/Context: For the selection of two subcontractors which was utilized by Panthera Corporation during the year that received federal expenditures greater than the micro-purchase threshold, but did not exceed the simplified acquisition threshold, this purchase did not go through a procurement process. Management asserted that one subcontractor came highly recommended, and the other was due to space limitations for an event, however, Panthera Corporation did not document these rationales at the time the contract was awarded, nor were they able to provide documentation that the subcontractors satisfied the specific circumstances for which noncompetitive procurement can be used. This was not a statistically valid sample. Questioned Costs: Not determinable. Cause: Panthera Corporation developed written procurement procedures, however, did not follow such procedures in obtaining competitive bids or maintaining documentation to support why competitive bids could not be obtained. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is managing the procurement compliance requirement of the Uniform Guidance. Recommendation: We recommend that Panthera Corporation follow its policies and procedures by ensuring that purchases requiring procurement go through the appropriate procurement process as well as maintaining documentation to allow for an audit trail. Views of Responsible Officials: Management acknowledges the finding and has implemented an approval process.

Repeat of Prior Audit Finding 2021-005 Federal Program: Trans-National Crime Federal Agencies: United States Department of State- United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200, Subpart D Section 200.332 of the Uniform Guidance require all non-Federal entities to assess subrecipients' risk, as well as monitor sub-awards passed through. All requirements imposed by the pass-through entity on the subrecipient are to ensure that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award. Condition/Context: For the selection of 2 subrecipients, we were unable to verify that the respective subaward agreements contained accurate award information, such as the identification of the funding being U.S. federal funds, the federal Assistance Listing Number and the requirements that the subrecipients would need to comply with the Uniform Guidance. In addition, for 2 other subrecipients, we could not determine the quarterly programmatic and financial reports were reviewed or approved by Panthera Corporation as there was no evidence of formal review and approval. There was also no evidence that those subrecipients had been audited or monitored under appropriate local government regulations. This was not a statistically valid sample. Questioned Costs: Not determinable Cause: Panthera Corporation's procedures did not ensure the required written subrecipient monitoring policies were implemented in accordance with the Uniform Guidance. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is managing the subrecipient monitoring requirements of the Uniform Guidance. Recommendation: We recommend that Panthera Corporation clearly identify in each agreement with subrecipients the reference to the applicable federal Assistance Listing Number and request audited reports from subrecipients when applicable. We further recommend that Panthera Corporation follow its policies and procedures by ensuring that subrecipient quarterly reports are subject to the appropriate process as well as maintaining documentation to allow for an audit trail. View of Responsible Officials: Management acknowledges the finding and will be retaining support and updating subrecipient agreements to include the relevant award information and the Uniform Guidance compliance requirements for subrecipients.

Repeat of Prior Audit Finding 2021-005 Federal Program: Trans-National Crime Federal Agency: United States Department of State - United States Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2022 Criteria: 2 CFR Part 200, Subpart D Section 200.332 of the Uniform Guidance require all non-Federal entities to assess subrecipients' risk, as well as monitor sub-awards passed through. All requirements imposed by the pass-through entity on the subrecipient are to ensure that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award. Condition/Context: For the selection of two subrecipients, we were unable to verify that the respective subaward agreements contained accurate award information, such as the identification of the funding being U.S. federal funds, the federal Assistance Listing Number and the requirements that the subrecipients would need to comply with the Uniform Guidance. In addition, for two other subrecipients, we could not determine whether the quarterly programmatic and financial reports were reviewed or approved by Panthera Corporation as there was no evidence of formal review and approval. There was also no evidence that those subrecipients had been audited or monitored under appropriate local government regulations. This was not a statistically valid sample. Questioned Costs: Not determinable. Cause: Panthera Corporation's procedures did not ensure the required written subrecipient monitoring policies were implemented in accordance with the Uniform Guidance. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is managing the subrecipient monitoring requirements of the Uniform Guidance. Recommendation: We recommend that Panthera Corporation clearly identify in each agreement with subrecipients the reference to the applicable federal Assistance Listing Number and request audited reports from subrecipients when applicable. We further recommend that Panthera Corporation follow its policies and procedures by ensuring that subrecipient quarterly reports are subject to the appropriate process as well as maintaining documentation to allow for an audit trail. View of Responsible Officials: Management acknowledges the finding and will be retaining support and updating subrecipient agreements to include the relevant award information and the Uniform Guidance compliance requirements for subrecipients.

Repeat of prior audit finding 2020-001 and 2020-003 Federal Program: Trans-National Crime Federal Agency: United States Department of State Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2021 Criteria: 2 CFR Part 200.303(a) of the Uniform Guidance require all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. In addition, 2 CFR section 200.405 requires federal awards be expended only for allowable activities. Condition/Context: Panthera Corporation was unable to provide a signed contract, payment information or invoice to evidence allowability of the expenditures or documentation of review and approval for the following: ? For 18 out of 80 selections, no evidence of approval of the invoice or signed contract could be provided (control & compliance) ? For 60 out of 80 selections, no evidence of approval of payment could be provided (control) ? For 27 out of 80 selections, no evidence of signed contract or payment support could be provided (control & compliance) This was not a statistically valid sample. Questioned Costs: Questioned costs were approximately $27,803. Cause: Panthera Corporation did not retain/could not retrieve the signed contract or any related support for the disbursements due to poor document retention and staffing turnover and did not follow its internal control procedures by including formal, written review of disbursement payments. Effect: Panthera Corporation has not complied with the specific requirements for activities allowed or unallowed and allowable costs/cost principles as described in the Uniform Guidance. Unallowable costs may have been charged to the federal program. Recommendation: We recommend that Panthera Corporation review its process and implement procedures that would allow management to properly maintain all required documentation on its federal expenditures. Views of Responsible Officials: Management acknowledges the finding and will retain all contracts in a centralized location.

Repeat of prior audit finding 2020-004 Federal Program: Trans-National Crime Federal Agency: United States Department of State Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2021 Criteria: 2 CFR Part 200.303(a) of the Uniform Guidance require all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that a non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. Condition/Context: Panthera Corporation prepares and reviews a quarterly expenditure file to track and compile quarterly costs to be submitted for reimbursement to the funding agency. For the selection of 2 quarterly expenditure files, we were unable to verify that the file was formally reviewed prior to requesting reimbursement. This was not a statistically valid sample. Questioned Costs: None Cause: Panthera Corporation developed written cash management procedures, however, did not follow such procedures by including formal, written review of quarterly expenditure files. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is appropriately managing the cash management compliance requirement of the Uniform Guidance. Improper cash drawdowns could occur. Recommendation: We recommend that Panthera Corporation implement written approval on their quarterly expenditure files. Views of Responsible Officials: Management acknowledges the finding and has implemented an approval process within Chrome River

Repeat of prior audit finding 2020-005 Federal Program: Trans-National Crime Federal Agency: United States Department of State Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2021 Criteria: 2 CFR Part 200.303(a) of the Uniform Guidance requires all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that a non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. 2 CFR Part 200.306 of the Uniform Guidance requires shared costs or matching funds be accepted as part of the non-Federal entity's cost sharing or matching when they are verifiable, necessary and reasonable and are allowable. Condition/Context: Panthera Corporation prepares and reviews a quarterly expenditure file to track and compile quarterly costs and calculate the cost-sharing component to be submitted for reimbursement to the funding agency. For the selection of 2 quarterly expenditure files, we were unable to verify that the file was formally reviewed. This was not a statistically valid sample. Questioned Costs: None Cause: Panthera Corporation developed written matching procedures, however, did not follow such procedures by including formal, written review of quarterly expenditure files. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is managing the matching compliance requirement of the Uniform Guidance. Recommendation: We recommend that Panthera Corporation implement documented approval on their quarterly expenditure files. Views of Responsible Officials: Management acknowledges the finding and has implemented an approval process within Chrome River.

Federal Program: Trans-National Crime Federal Agency: United States Department of State Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2021 Criteria: 2 CFR Part 200 Subpart D Section 200.320 identifies small purchases as purchases greater than the micro-purchase threshold but not exceeding the simplified acquisition threshold. For small purchases, rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. 2 CFR Part 200 Subpart D Section 200.320 (c) of the Uniform Guidance establishes specific circumstances in which noncompetitive procurement can be used. Condition/Context: For the selection of 1 subcontractor which was utilized by Panthera Corporation during the year that received federal expenditures greater than the micro-purchase threshold, but did not exceed the simplified acquisition threshold, this purchase did not go through a procurement process. Management asserted that such subcontractor came highly recommended, however, Panthera Corporation did not document this rationale at the time the contract was awarded, nor were they able to provide documentation that the subcontractor satisfied the specific circumstances for which noncompetitive procurement can be used. Questioned Costs: None Cause: Panthera Corporation developed written procurement procedures, however, did not follow such procedures in obtaining competitive bids or maintaining documentation to support by competitive bids could not be obtained. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is managing the procurement compliance requirement of the Uniform Guidance. Recommendation: We recommend that Panthera Corporation follow its policies and procedures by ensuring that purchases requiring procurement go through the appropriate procurement process as well as maintaining documentation to allow for an audit trail. Views of Responsible Officials: Management acknowledges the finding and has implemented an approval process.

Repeat of prior audit finding 2020-002 Federal Program: Trans-National Crime Federal Agency: United States Department of State Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2021 Criteria: 2 CFR Part 200, Subpart D Section 200.332 of the Uniform Guidance require all non-Federal entities to assess subrecipients' risk, as well as monitor sub-awards passed through. All requirements imposed by the pass-through entity on the subrecipient are to ensure that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award. Condition/Context: For the selection of 2 subrecipients, we were unable to verify that the respective subaward agreements contained accurate award information, such as the identification of the funding being U.S. federal funds, the federal Assistance Listing Number and the requirements that the subrecipients would need to comply with the Uniform Guidance. This was not a statistically valid sample. Questioned Costs: None Cause: Panthera Corporation's procedures did not ensure the required written subrecipient monitoring policies were implemented in accordance with the Uniform Guidance. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is managing the subrecipient monitoring requirements of the Uniform Guidance. Recommendation: We recommend that Panthera Corporation clearly identify in each agreement with subrecipients the reference to the applicable federal Assistance Listing Number and request audited reports from subrecipients when applicable. View of Responsible Officials: Management acknowledges the finding and will be updating subrecipient agreements to include the relevant award information and the Uniform Guidance compliance requirements for subrecipients.

Federal Program: Trans-National Crime Federal Agency: United States Department of State Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2020 Criteria: 2 CFR Part 200.303(a) of the Uniform Guidance require all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that an non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. In addition, 2 CFR section 200.405 requires federal awards be expended only for allowable activities. Condition/Context: For 1 out of 23 expenditures selected for testing, Panthera Corporation was unable to provide a signed contract, payment information or invoice to evidence allowability of the expenditures or documentation of review and approval. This was not a statistically valid sample. Questioned Costs: Questioned costs were approximately $3,694 and were deemed immaterial. Cause: Panthera Corporation did not retain/could not retrieve the signed contract or any related support for the disbursement due to poor document retention and staffing turnover. Effect: Panthera Corporation has not complied with the specific requirements for activities allowed or unallowed & allocable costs/cost principles as described in the Uniform Guidance. Unallowable costs may have been charged to the federal program. Recommendation: We recommend that Panthera Corporation review its process and implement procedures that would allow management to properly maintain all required documentation on its federal expenditures. Views of Responsible Officials: Management acknowledges the finding and will retain all contracts in a centralized location.

Federal Program: Trans-National Crime Federal Agency: United States Department of State Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2020 Criteria: 2 CFR Part 200, Subpart D Section 200.332 of the Uniform Guidance require all non-Federal entities to assess subrecipients' risk, as well as monitor sub-awards passed through. All requirements imposed by the pass-through entity on the subrecipient are to ensure that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award. Condition/Context: For the selection of 3 subrecipients, we were unable to verify that the respective subaward agreements contained accurate award information, such as the identification of the funding being U.S. federal funds, the federal Assistance Listing Number and the requirements that the subrecipients would need to comply with the Uniform Guidance. In addition, we could not determine that quarterly programmatic and financial reports were reviewed and approved by Panthera Corporation. Although emails were provided confirming existence, there was no evidence of formal review and approval. There was also no evidence that such subrecipients had been audited or monitored under appropriate local government regulations. Last, we noted that subrecipient risk assessment was not performed or documented for the 3 subrecipient agreements selected for testing. This was not a statistically valid sample. Questioned Costs: $220,017 Cause: Panthera Corporation's procedures did not ensure the required written subrecipient monitoring policies were implemented in accordance with the Uniform Guidance. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is managing the subrecipient monitoring requirements of the Uniform Guidance. Recommendation: We recommend that Panthera Corporation clearly identify in each agreement with subrecipients the reference to the applicable Federal Assistance Listing Number. We also recommend that Panthera Corporation revise their current written policy, implement written review and approval on quarterly reports, perform risk assessment and request audited reports from subrecipients when applicable. Views of Responsible Officials: Management acknowledges the finding and will be retaining support and performing risk assessment on all subrecipients.

Federal Program: Trans-National Crime Federal Agency: United States Department of State Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2020 Criteria: 2 CFR Part 200.303(a) of the Uniform Guidance require all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that an non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. In addition, 2 CFR section 200.405 requires Federal awards be expended only for allowable activities. Condition/Context: Management was unable to provide the audit evidence on review and approval of expenditures for 8 of 40 testing sample selections. This was not a statistically valid sample. Questioned Costs: None Cause: Panthera Corporation discontinued the use of Concur software in 2020, which was a platform that enabled electronic review and approval of invoices as part of Panthera Corporation's expense management process. Consequently, management was not able to access the data that would have provided evidence of review and approval of federal expenditures. Management did not retain screen shots of invoice approval from Concur. Effect: Panthera Corporation has not complied with the specific requirements for review and approval of invoices as described in the Uniform Guidance. Unallowable costs may have been charged to the Federal program. Recommendation: We recommend that Panthera Corporation follow its policies and procedures by reviewing all invoices and retaining evidence on review and approval as part of the audit trail. Views of Responsible Officials: Management acknowledges the finding and has implemented Chrome River for the review and approval of invoices.

Federal Program: Trans-National Crime Federal Agency: United States Department of State Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2020 Criteria: 2 CFR Part 200.303(a) of the Uniform Guidance require all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that an non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. Condition/Context: Panthera Corporation prepares and reviews a quarterly expenditure file to track and compile quarterly costs to be submitted for reimbursement to the funding agency. For the selection of 4 quarterly expenditure files, we were unable to verify that the file was formally reviewed prior to requesting reimbursement. This was not a statistically valid sample. For 1 of 12 selections, there was no evidence of invoice approval prior to reimbursement of subrecipient payment. Questioned Costs: None Cause: Panthera Corporation developed written cash management procedures, however, did not follow such procedures by including formal, written review of quarterly expenditure files. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is appropriately managing the cash management compliance requirement of the Uniform Guidance. Improper cash drawdowns could occur. Recommendation: We recommend that Panthera Corporation implements written approval on their quarterly expenditure files. Views of Responsible Officials: Management acknowledges the finding and has implemented an approval process.

Federal Program: Trans-National Crime Federal Agency: United States Department of State Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2020 Criteria: 2 CFR Part 200.303(a) of the Uniform Guidance requires all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that an non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. 2 CFR Part 200.306 of the Uniform Guidance requires and shared costs or matching funds be accepted as part of the non-Federal entity's cost sharing or matching when they are verifiable, necessary and reasonable and are allowable. Condition/Context: Panthera Corporation prepares and reviews a quarterly expenditure file to track and compile quarterly costs and calculate the cost-sharing component to be submitted for reimbursement to the funding agency. For the selection of 4 quarterly expenditure files, we were unable to verify that the file was formally reviewed. This was not a statistically valid sample. Questioned Costs: None Cause: Panthera Corporation developed written matching procedures, however, did not follow such procedures by including formal, written review of quarterly expenditure files. Effect: Panthera Corporation's control design and operation does not provide reasonable assurance that Panthera Corporation is managing the matching compliance requirement of the Uniform Guidance. Recommendation: We recommend that Panthera Corporation implements documented approval on their quarterly expenditure files. Views of Responsible Officials: Management acknowledges the finding and has implemented an approval process.

Federal Program: Trans-National Crime Federal Agency: United States Department of State CFDA Number: 19.705 Federal Award Year: December 31, 2019 Criteria: 2 CFR Part 200, Subpart D Sections 200.003 and 200.317 through 200.326 of the Uniform Guidance require all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. Condition/Context: Panthera did not have any written policies and procedures documenting Panthera's internal control procedures for adhering to each of the compliance requirements described in the OMB Compliance Supplement for its major federal program. Questioned Costs: None Cause: Panthera's management did not ensure the required written policies and procedures were developed and implemented in accordance with the Uniform Guidance. Effect: Panthera has not complied with the specific requirements for written policies and procedures as described in the Uniform Guidance. Recommendation: We recommend that Panthera document in writing of its internal control over compliance with each of the applicable types of compliance requirements. Views of Responsible Officials: Management acknowledges the finding. For details on actions taken, refer to the Corrective Action Plan.

Federal Program: Trans-National Crime Federal Agency: United States Department of State CFDA Number: 19.705 Federal Award Year: December 31, 2019 Criteria: 2 CFR section 215.22 of the Uniform Guidance requires costs for which reimbursement was requested by recipients to be paid prior to the date of the reimbursement request. Condition/Context: For 8 out of 40 expenditures selected for testing, Panthera requested reimbursement for these expenditures before they were paid. While the federal awards were maintained in an interest bearing cash account, the total interest income generated for the year ended December 31, 2019 was $230. As a result, Panthera is not required to remit any interest income to the federal government as the actual annual interest is not in excess of the $500 per year threshold required under 2 CFR Part 200, Subpart D Section 200.305(9). Our sample was selected from a population of 1,955 expenditures submitted for reimbursement. Our sample was a statistically valid sample. Questioned Costs: None Cause: Panthera requested reimbursements without paying attention to the timing of when the incurred expenditures were paid by Panthera. Panthera utilized the monthly expenditures report from the accounting software, which does not indicate the timing of actual payments of the expenditures. Effect: Panthera has not complied with the specific requirements for cash management as described in the Uniform Guidance. Recommendation: We recommend that Panthera implement written policies and procedures to require that federal expenditures are not requested for reimbursement before they are paid by Panthera. Views of Responsible Officials: Management acknowledges the finding. For details on actions taken, refer to the Corrective Action Plan.

Federal Program: Trans-National Crime Federal Agency: United States Department of State CFDA Number: 19.705 Federal Award Year: December 31, 2019 Criteria: 2 CFR Subpart F Part 200.512 of the Uniform Guidance requires the audit to be completed, data collection form to be submitted, and the reporting package to be submitted within the earlier of 30 calendar days after receipt of the auditors' report, or nine months after the end of the audit period. Due to the COVID-19 pandemic, Panthera's filing deadline was extended through December 31, 2020 (a 3-month additional extension). Condition/Context: Panthera did not submit its audit report or reporting package prior to the extended due date of December 31, 2020. Questioned Costs: None Cause: Management had significant turnover in early 2020, resulting in analyses and support not being available timely. Effect: Completion of the audit, submission of the data collection form, and submission of the reporting package occurred after the extended due date of December 31, 2020. Recommendation: We recommend that management evaluate the timeliness of its closing process and prepare for its Uniform Guidance audit earlier. Views of Responsible Officials: Management acknowledges the finding. For details on actions taken, refer to the Corrective Action Plan.

Federal Program: Trans-National Crime Federal Agency: United States Department of State CFDA Number: 19.705 Federal Award Year: December 31, 2019 Criteria: Panthera prepares and reviews a quarterly expenditure file to track and compile quarterly costs to be submitted for reimbursement to the funding agency. Condition/Context: For the selection of 4 quarterly expenditure files, we were unable to verify that the file was formally reviewed, as such process was not documented. Questioned Costs: None Cause: Panthera's procedures did not ensure the required written cash management policies were developed and implemented in accordance with the Uniform Guidance to ensure formal, written review of quarterly expenditure files. Effect: Panthera's control design and operation does not provide reasonable assurance that Panthera is managing the cash management compliance requirement of the Uniform Guidance. Recommendation: We recommend that Panthera implements written approval on their quarterly expenditure files. Views of Responsible Officials: Management acknowledges the finding. For details on actions taken, refer to the Corrective Action Plan.

Federal Program: Trans-National Crime Federal Agency: United States Department of State CFDA Number: 19.705 Federal Award Year: December 31, 2019 Criteria: Panthera prepares and reviews a quarterly expenditure file to track and compile quarterly costs and calculate the cost-sharing component to be submitted for reimbursement to the funding agency. Condition/Context: For the selection of 4 quarterly expenditure files, we were unable to verify that the file was formally reviewed, as such process was not documented. Questioned Costs: None Cause: Panthera's procedures did not ensure the required written matching policies were developed and implemented in accordance with the Uniform Guidance to ensure formal, written review of quarterly expenditure files. Effect: Panthera's control design and operation does not provide reasonable assurance that Panthera is managing the matching compliance requirement of the Uniform Guidance. However, there is no noncompliance with the matching compliance requirement. Recommendation: We recommend that Panthera implements written approval on their quarterly expenditure files. Views of Responsible Officials: Management acknowledges the finding. For details on actions taken, refer to the Corrective Action Plan.

Federal Program: Trans-National Crime Federal Agency: United States Department of State CFDA Number: 19.705 Federal Award Year: December 31, 2019 Criteria: 2 CFR Part 200 Subpart D Section 200.320 identifies small purchases as purchases greater than the micro-purchase threshold but not exceeding the simplified acquisition threshold. For small purchases, rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. 2 CFR Part 200 Subpart D Section 200.320 (c) of the Uniform Guidance establishes specific circumstances in which noncompetitive procurement can be used. Condition/Context: Two subcontractors were utilized by Panthera during the year that received federal expenditures greater than the micro-purchase threshold, but did not exceed the simplified acquisition threshold. These purchases did not go through a procurement process. Management claimed such subcontractors were the only ones who could perform the work due to a lack of qualified providers, however, Panthera did not document this rationale at the time the contracts were awarded, nor were they able to provide documentation that the subcontractors satisfied the specific circumstances for which noncompetitive procurement can be used. Questioned Costs: None Cause: Panthera's procedures did not ensure the required written procurement policies were developed and implemented in accordance with the Uniform Guidance that identified purchases where procurement was necessary. Effect: Panthera did not obtain competitive bids and did not maintain documentation to support why competitive bids could not be obtained. Recommendation: We recommend that Panthera document in writing of internal control over compliance with 2 CFR Part 200 Subpart D Sections 200.317 through 200.326 of the Uniform Guidance and implement internal controls to ensure compliance and that purchases requiring procurement are identified and go through the appropriate procurement process as well as maintaining documentation to allow for an audit trail. Views of Responsible Officials: Management acknowledges the finding. For details on actions taken, refer to the Corrective Action Plan.