Global Ties U.S. and AffiliateNon-Profit

2022 ? 001 Reporting, Federal Funding Accountability and Transparency Act Federal agency: U.S. Department of State, Professional and Cultural Exchange Programs Federal program title: International Visitor Leadership Program CFDA Number: 19.402 Award Period: January 1, 2020 ? June 30, 2022; February 2, 2022 ? June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: As noted in 2 CFR Part 170, the recipients (i.e. direct recipients) of grants or cooperative agreements who make first tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) and report subaward data through FSRS no later than the end of the month following the month in which the obligation was made. Condition: During our testing, we noted Global Ties U.S. did not register all the original and subsequent first tier subawards of $30,000 or more in FSRS within the requirement timeline. Questioned costs: None Context: FFATA reporting was not submitted in FSRS. Cause: During the fiscal year under audit, Global Ties U.S. received several tranches of the direct award and distributed them to all the subrecipients. Due to the volume of the disbursement activity required to fulfil the obligations under this awards, the organization did not have sufficient staffing to comply with FFATA reporting requirements within the specified deadlines throughout the year. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-005. Effect: Global Ties U.S could fail to ensure that subrecipients are in compliance with the federal award requirements. Recommendation: We recommend Global Ties U.S. design controls to ensure all first tier awards in excess of $30,000 are accurately and timely registered with the Federal Funding Accountability and Transparency Act Subaward Reporting System. In addition, Global Ties U.S. should ensure that any subawards are reported within the required time frame. The list of data elements required to be reported for each subaward in excess of $30,000 include the following: ? Subaward date ? Subaward UEI number ? Subaward amount ? Subaward obligation/action date ? Subaward number ? Subaward report submission date. Views of responsible officials: There is no disagreement with the audit finding.

2021 ? 004 Allowable Costs Federal agency: U.S. Department of State, Professional and Cultural Exchange Programs Federal program title: USA Pavilion at 2020 EXPO in Dubai CFDA Number: 19.040 Award Period: February 11, 2020 ? June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires the organization to only claim costs that were expanded in the fiscal year. Condition: During our testing, we noted Global Ties recorded certain prepaid costs as grant expenditures for the fiscal year ended September 30, 2021. Adjustments to correct for these matters were posted to the Schedule of Expenditures for Federal Awards by Global Ties. Questioned costs: $220,054 Context: $220,054 of prepaid expenditures were recorded as grant expenditures for the year ended September 30, 2021. The SEFA was adjusted for the identified errors. Cause: Significant internal staffing changes occurred during the year under audit contributed to the inappropriate accounting for the grant costs and corresponding compliance considerations. Repeat Finding: This is not a repeat finding. Effect: Failure to comply with 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requirements to only record costs expanded during the fiscal year may jeopardize Global Ties' eligibility for future awards and/or delays in payments. Recommendation: The organization should establish an internal control to monitor and ensure compliance with the allowable costs requirements of the award. Views of responsible officials: There is no disagreement with the audit finding.

2021 ? 005 Reporting, Federal Funding Accountability and Transparency Act Federal agency: U.S. Department of State, Professional and Cultural Exchange Programs Federal program title: International Visitor Leadership Program CFDA Number: 19.402 Award Period: January 1, 2020 ? June 30, 2021; February 5, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: As noted in 2 CFR Part 170, the recipients (i.e. direct recipients) of grants or cooperative agreements who make first tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) and report subaward data through FSRS no later than the end of the month following the month in which the obligation was made. Condition: During our testing, we noted Global Ties U.S. did not register all the original and subsequent first tier subawards of $30,000 or more in FSRS within the requirement timeline. Questioned costs: None Context: FFATA reporting was not submitted in FSRS. Cause: During the fiscal year under audit, Global Ties U.S. received several tranches of the direct award and distributed them to all the subrecipients. Due to the volume of the disbursement activity required to fulfil the obligations under this awards, the organization did not have sufficient staffing to comply with FFATA reporting requirements within the specified deadlines throughout the year. Repeat Finding: This is not a repeat finding. Effect: Global Ties U.S could fail to ensure that subrecipients are in compliance with the federal award requirements. Recommendation: We recommend Global Ties U.S. design controls to ensure all first tier awards in excess of $30,000 are accurately and timely registered with the Federal Funding Accountability and Transparency Act Subaward Reporting System. In addition, Global Ties U.S. should ensure that any subawards are reported within the required time frame. The list of data elements required to be reported for each subaward in excess of $30,000 include the following: ? Subaward date ? Subaward DUNS number ? Subaward amount ? Subaward obligation/action date ? Subaward number ? Subaward report submission date. Views of responsible officials: There is no disagreement with the audit finding.

2021 ? 006 Reporting Federal agency: U.S. Department of State, Professional and Cultural Exchange Programs Federal program title: International Visitor Leadership Program CFDA Number: 19.402 Award Period: January 1, 2020 ? June 30, 2021; February 5, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires submitting the interim and/or quarterly and/or semi-annual performance and financial reports within 30 days after the end of the reporting period and final performance and financial reports within 90 calendar days after the period of performance end date. Condition: During our testing, we noted Global Ties did not file one semi-annual financial report within 30 days of the end of each respective reporting period. Questioned costs: None Context: One semi-annual financial report tested was submitted 39 days after the required submission date. Cause: Various organizational changes in the fiscal years 2020 and 2021 contributed to the delayed filings of the reports. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2020-002. Effect: Failure to comply with these reporting requirements may jeopardize Global Ties' eligibility for future awards and/or delays in payments. Recommendation: The organization should establish an internal control to monitor and ensure compliance with the reporting requirements of the award. Views of responsible officials: There is no disagreement with the audit finding.

2020 ? 002 Reporting Federal agency: U.S. Department of State, Professional and Cultural Exchange Programs Federal program title: International Visitor Leadership Program CFDA Number: 19.402 Award Period: January 1, 2019 ? December 31, 2019; January 1, 2020 ? December 31, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires submitting the interim and/or quarterly performance and financial reports within 30 days after the end of the reporting period and final performance and financial reports within 90 calendar days after the period of performance end date. Condition: During our testing, we noted Global Ties did not file one quarterly financial report within 30 days of the end of each respective reporting period. It did not file one final performance report within 90 calendar days after the period of performance end date. Questioned costs: None Context: One quarterly report tested was submitted 25 days after the required submission date. One final performance report was submitted 127 days late. Cause: Various organizational changes in the fiscal years 2019 and 2020 contributed to the delayed filings of the reports. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2019-003. Effect: Failure to comply with these reporting requirements may jeopardize Global Ties' eligibility for future awards and/or delays in payments. Recommendation: The organization should establish an internal control to monitor and ensure compliance with the reporting requirements of the award. Views of responsible officials: There is no disagreement with the audit finding.

2020 ? 003 Allowable Costs/Costs Principles Federal agency: U.S. Department of State, Professional and Cultural Exchange Programs Federal program title: International Visitor Leadership Program CFDA Number: 19.402 Award Period: January 1, 2019 ? December 31, 2019; January 1, 2020 ? December 31, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Department of Interior (the cognizant agency) requires the organization submits a new indirect cost proposal within six months after the close of each fiscal year. The Global Ties U.S. should have internal controls designed to ensure compliance with that provision. Condition: During our testing, we noted Global Ties U.S. did not have documentation to support timely submission of Negotiation Indirect Cost Proposal application (NICRA) for the fiscal year ended September 30, 2019 within the requirement timeline. Questioned costs: None Context: During our testing, it was noted that Global Ties U.S. did not have documentation to support timely submission of NICRA for the fiscal year ended September 30, 2019 that was required to be submitted by March 31, 2020. Cause: Global Ties U.S. had various delays in closing out the books for the fiscal year 2019 as indicated in the prior year finding 2019-001, and was unable to file NICRA within specified deadline. Effect: Untimely submission of NICRA may result is delay of the indirect cost negotiations resulting in potential inability to use more favorable negotiated rate by the organization. Recommendation: We recommend Global Ties U.S. design controls to ensure an adequate review process is in place to comply with NICRA filing timelines established by the cognizant agency. Views of responsible officials: There is no disagreement with the audit finding.

2019 ? 002 Reporting, Data Collection Form Federal Agency: U.S. Department of State, Professional and Cultural Exchange Programs Federal Program Title: International Visitor Leadership Program CFDA Number: 19.402 Award Period: January 1, 2018 ? December 31, 2018; January 1, 2019 ? December 31, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires submitting the data collection form and the reporting package to the FAC within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period. Internal controls should be in place to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP in a timely manner. Condition: During our testing, we noted Global Ties did not file the fiscal year 2019 data collection form within the specified time period. Questioned costs: None Context: Global Ties did not obtain the auditor?s report(s) for the year ended September 30, 2018 until April 10, 2020 and this along with turnover and changes in the financial reporting process delayed the completion of the preparation for and performance of the fiscal year 2019 audit. Cause: Information supporting the timely filing of the data collection form and performance of the audit was not ready prior to the filing deadline. Effect: Global Ties will not be considered a low-risk auditee due to noncompliance with the data collection form requirements for the next two fiscal years. Recommendation: Internal controls over the financial reporting process should be structured to ensure the year-end closing and audit preparation occurs within adequate time following year-end to allow for the performance and completion of the audit and timely submission of the data collection form. Views of responsible officials: There is no disagreement with the audit finding.

2019 ? 003 Reporting Federal Agency: U.S. Department of State, Professional and Cultural Exchange Programs Federal Program Title: International Visitor Leadership Program CFDA Number: 19.402 Award Period: January 1, 2018 ? December 31, 2018; January 1, 2019 ? December 31, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires submitting the interim and/or quarterly performance and financial reports within 30 days after the end of the reporting period and final performance and financial reports within 90 calendar days after the period of performance end date. Condition: During our testing, we noted Global Ties did not file 2 out of 2 quarterly reports and one interim performance report within 30 days of the end of each respective reporting period. It did not file one final financial report and one final performance report within 90 calendar days after the period of performance end date. Questioned costs: None Context: 2 quarterly reports tested were submitted one day after the required submission date. 1 interim performance report was submitted 475 days late. 1 final performance report was submitted 86 days late. 1 final financial report was submitted 628 days late. All reports selected for testing were submitted late. Cause: Global Ties outsourced submission of the reports as part of the outsourced accounting function and the outsourcing service provider did not submit the reports in a timely manner. Effect: Failure to comply with these reporting requirements may jeopardize Global Ties? eligibility for future awards and/or delays in payments. Recommendation: The organization should establish an internal control to monitor and ensure compliance with the reporting requirements of the award. Views of responsible officials: There is no disagreement with the audit finding.

2019 ? 004 Procurement Federal Agency: U.S. Department of State, Professional and Cultural Exchange Programs Federal Program Title: International Visitor Leadership Program CFDA Number: 19.402 Award Period: January 1, 2018 ? December 31, 2018; January 1, 2019 ? December 31, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with procurement requirements using the micro-purchase threshold of $10,000 and simplified acquisition threshold of $250,000. However, the organization did not yet update their procurement policy to the higher regulatory thresholds. The organization?s micro-purchase threshold is $3,000 and simplified acquisition threshold is $150,000. Condition: During our testing, we noted Global Ties did not comply with the simplified acquisition threshold established in the organization?s procurement policy for 3 out of 8 selections. Questioned costs: None Context: Global Ties? procurement policy thresholds are more stringent than those established in the federal regulations. Because the organization?s policy was not updated to match allowable federal levels, the procedures performed evaluated the compliance with the organization?s procurement policy and determined 3 instances of noncompliance out of 8 selected procurements. Cause: Global Ties did not maintain document to support compliance with their procurement policy. Effect: Global Ties? internal controls did not operate effectively and resulted in 3 instances of noncompliance with the organization?s procurement policy. Recommendation: The organization should consider updating their procurement policy to the allowable thresholds established in the federal regulation and enhance their monitoring controls over the procurement process to ensure they are in compliance with the Global Ties procurement policy and documentation to support this is maintained. Views of responsible officials: There is no disagreement with the audit finding.

2019 ? 005 Procurement ? Suspension and Debarment Federal Agency: U.S. Department of State, Professional and Cultural Exchange Programs Federal Program Title: International Visitor Leadership Program CFDA Number: 19.402 Award Period: January 1, 2018 ? December 31, 2018; January 1, 2019 ? December 31, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Global Ties U.S. should have internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted Global Ties U.S. did not have documentation to support that internal controls were performed to ensure vendors were not suspended or debarred. Questioned costs: None Context: During our testing, it was noted that for 1 of 14 items tested that Global Ties U.S. did not have documentation to support that it had reviewed vendors prior to entering into a contract with a vendor to ensure the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration. We verified that the selected vendor was not suspended or debarred. Cause: Global Ties U.S. was unable to locate documentation to support the performance of procedures to ensure vendors were not suspended or debarred. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Recommendation: We recommend Global Ties U.S. design controls to ensure an adequate review process is in place to review potential vendors to determine they are not suspended or debarred and to ensure documentation to support this is maintained. Views of responsible officials: There is no disagreement with the audit finding.