Management Action Plan

Financial Transactions and Reports Analysis of Canada opinion of the Audit Report:

FINTRAC has reviewed and accepts the recommendations contained in the Office of the Comptroller General (OCG) audit report.

FINTRAC takes its financial management responsibilities very seriously, as seen in the Centre's record of unqualified audit opinions from external auditors of its annual financial statements, as well as the results of a review of internal controls over financial reporting conducted by an external consultant during fiscal year 2012–13.

The period of the OCG audit was one of transition for FINTRAC, including changes in leadership, significant changes to central agency policies, as well as the implementation of revised internal policies and procedures. Throughout the transition period FINTRAC ensured it complied with the spirit and intent of all central agency and internal policies, sought legal opinions where necessary and prudent, and ensured the proper and responsible use of public funds.

FINTRAC is committed to addressing all of the audit recommendations. In fact, corrective actions have already taken place in many of the areas the audit identified as needing improvement. A management action plan has been developed based on the recommendations and, through its implementation, management is confident that sound financial management practices will be reinforced and that FINTRAC will continue to operate an effective financial control environment. Work has already commenced to implement the plan and management expects to complete the remaining changes by Q2 2014–15. 

Audit Entity Sign Off on the Management Action Plan
Gérald Cossette
Director
Financial Transactions and Reports Analysis of Canada


Management Action Plan
Recommendations Priority Response and Planned Actions Responsibilities (position title responsible for the action) Timelines
  1. FINTRAC should ensure that the Delegation of Financial Signing Authorities Instrument is reviewed annually, including updating signature specimen cards to reflect the authorities granted in the Delegation of Financial Signing Authorities Instrument.

High

Response:

The regular practice at FINTRAC is to review the Delegation of Financial Signing Authorities Instrument annually, however, during 2012–13, a comprehensive review of the Delegation of Financial Signing Authorities Instrument, including all specimen signature cards, was underway to ensure the instrument complied with all relevant internal and central government agency policies. Required changes were completed and the updated instrument was approved by the Minister of Finance in 2013–14. All specimen signature cards were subsequently updated in 2013–14.

Planned Actions:

FINTRAC will continue to conduct an annual review of the Delegation of Financial Signing Authorities Instrument and related specimen signature cards and document the results.

Deputy Chief Financial Officer

Completed in Q3 2013–14 and to be reviewed annually

  1. FINTRAC should ensure that the acquisition card limits are set by the responsibility center manager, are used solely for authorized business-related purchases of goods or services; and proper documentation is retained on file.

Medium

Response:  

During 2012–13, with the implementation of a new acquisition card application form, all new acquisition card holders were required to sign off on their responsibilities, and responsibility centre managers approved the issuance of acquisition cards, including the credit limits.

FINTRAC mitigates the risk on misuse of the acquisition cards through monthly account verifications conducted by the responsibility centre manager, as well as a detailed monthly statement review by the Section 33 signatory.

Planned Actions:

Finance will communicate the required information to acquisition card holders to review acquisition card policies and procedures. This will be provided at the bi-monthly Finance and Administration Community ForumFootnote 1 meeting in Q4 2013–14. Additional communications will be made via email and through postings on the FINTRAC intranet site.

Head, Accounting Operations

Q4 2013–14

  1. FINTRAC should ensure that the custodians of accountable advances reconcile and report on the funds on a monthly basis.

Low

Response:

Due to the relatively low dollar value of petty cash funds and infrequency of petty cash transactions, FINTRAC has not required monthly reconciliations by petty cash administrators due to the low risk of loss.

Planned Actions:

FINTRAC will review its procedures to ensure that petty cash funds are reconciled on a monthly basis. Petty cash custodians and responsibility centre managers will be reminded of their responsibilities via an annual communique and monthly email reminders, as well as at the Finance and Administration Community Forum meeting in Q4 2013–14.

Head, Accounting Operations

Q4 2013–14

  1. FINTRAC should ensure that the business processes are improved to ensure that procurement activities are consistently performed in compliance with the Treasury Board Contracting Policy and that documentation is retained on file.

High

Response:

During 2012–13, FINTRAC made several changes and improvements in the area of Procurement which address many of the audit recommendations, such as: the staffing of a Senior Procurement Officer, a detailed Procurement File Review and Report, the revision of several procurement policies, procedures, templates and processes, and the development of procurement training sessions. 

Planned Actions:

  1. Ensure that the appropriate procurement vehicle continues to be used given FINTRAC's security posture and special authorities by analyzing the requirements and helping clients determine which vehicle is the best fit.
  2. Ensure that all checkboxes and areas on checklists and Procurement forms relating to sole source justification are marked appropriately.
  3. FINTRAC's revised Policy on Procurement will come into effect April 1st, 2014 and will require for all requirements under $25,000, a detailed justification when sole sourcing a contract under one of the exceptions provided for in the Government Contracts Regulations. FINTRAC managers will be provided with additional guidance on how to prepare appropriate detailed justification.
  4. Ensure that all evaluation criteria and/or selection methodology is included in all solicitation documents. FINTRAC is currently developing an Evaluation Report template which will be introduced in 2014–15.
  5. Ensure that Procurement requests include the appropriate Manager's pre-approval either via email or via the signature block on the Client Procurement Request Form.
  6. Ensure that all amendments requests include appropriate justification. Training has been delivered (starting in Q3 2012–13) to clients in which proper contract management has been addressed as well as the need for flagging amendments as soon as possible. This training will continue to be offered on a regular basis.
  7. FINTRAC will document, communicate and implement a business process where those employees who are best able to provide evidence of receipt of goods or services will initial and date invoices using a "goods received" stamp. Managers performing the account verification will use the initial goods received stamp as further evidence that the goods or services have been received. It will be appropriate for a manager performing the account verification to also initial that the goods have been received or services have been rendered if they have knowledge of such evidence. This process will be communicated to pertinent employees during a mandatory Finance and Administration Community Forum meeting held in Q4 2013–14.

Head, Administration

  1. Completed
    Q3 2013–14
  2. Completed
    Q3 2013–14
  3. Q1 2014–15
  4. Q2 2014–15
  5. Completed
    Q3 2012–13
  6. Completed
    Q3 2012–13
  7. Q4 2013–14
  1. FINTRAC should ensure that the business processes regarding travel expenses are improved to ensure that they are consistently performed in accordance with related directives.

High

Response:

FINTRAC recognizes travel related expenses must follow applicable policies and written justification is required to be kept on file, when applicable.

Planned Actions:

  1. In Q1 2014–15, FINTRAC will be implementing Shared Travel Service's (PWGSC) Expense Management Tool (EMT). This tool will provide system controls which will support each recommendation and assist travellers to strictly comply with TBS and PWGSC travel policies. Additionally, training regarding the Travel Directive will also be provided to relevant employees during a Finance and Administration Community Forum meeting to be held in Q4 2013–14. In instances where there is a business requirement or it is more economical to select accommodations outside the PWGSC directory, FINTRAC will ensure that justification is clearly documented.
  2. During fiscal year 2013–14, FINTRAC updated the Travel Authority and Advance (TAA) form. The form includes the requirements to justify the purpose of the trip, the number of travellers and accommodations selections that are not part of the PWGSC accommodations directory or within the local city rate. The use of the new form is mandatory.  
  3. In order to ensure that all supporting documentation for travel-related expenses is included in the file, a checklist will be created in Q4 2013–14 to aid in the account verification and payment authority process. The checklist will include all relevant supporting items.

Head, Accounting Operations

  1. Q1 2014–15
  2. Completed
    Q3 2013–14
  3. Q4 2013–14
  1. FINTRAC should ensure that the documentation supporting the hospitality event is retained on file.

Medium

Response:

With the introduction of the revised Directive on the Management of Expenditures on Travel, Hospitality and Conferences in 2012–13, there have been significant changes which all government departments and agencies are adapting to. FINTRAC has developed additional processes and tools to support the requirements of the revised Directive.

Additional training and communication is planned for FINTRAC employees regarding Hospitality and will be provided at a Finance and Administration Community Forum to be held in Q4 2013–14 and through communiques which will be emailed and posted on the FINTRAC intranet site.

Planned Actions:

  1. In Q1 2013–14, FINTRAC developed a Hospitality Expense Pre-Audit form that is completed as pre-approval of all hospitality events. The form was updated in Q3 following the August 2013 amendment to the Directive on Travel, Hospitality, Conference and Event Expenditures. The form includes verification that remote meeting solutions and virtual presence had been considered, and outlines the requirement to obtain multiple quotes, including one from a Government facility. The hospitality expense pre audit form is mandatory for all hospitality events in order to ensure value for money is clearly demonstrated at the time of pre-approval.
  2. FINTRAC will ensure supporting documentation of justification is complete, in advance, for all cases where cost per person may exceed the standard, and as identified on the hospitality expense pre-audit form at the time of pre-approval.

Head, Accounting Operations

  1. Completed
    Q1 2013–14
  2. Completed
    Q1 2013–14
  1. FINTRAC should ensure that the departure forms are properly completed and signed by employees.

Medium

Response:

The purpose of the departure form is to attest that an employee leaving FINTRAC no longer has any assets in his possession and/or matters to settle with FINTRAC on their last day. It is recognized that the 11 departure forms reviewed by the auditors were duly signed by all designated FINTRAC representatives in all spheres of responsibilities. However, the auditors have noted that in two instances the employee's signature was missing.

While the Human Resource Directorate (HRD) is the custodian of the forms the last step for the employee is remittance of the form to Security.

Planned Actions:

HRD has modified the form to now include the FINTRAC Security officer's initials beside the employee signature.

Assistant Director, Human Resources

Completed
Q4 2013–14

  1. FINTRAC should ensure that the funds commitment availability is certified by someone with appropriate delegated authority, dated; and that expenses are recorded at the value expected to be incurred.

High

Response:

FINTRAC recognizes the need to ensure that funds commitment availability must be approved by an individual with the delegated authority, dated and recorded at the value expected to be incurred.

Planned Actions:

In Q3 2013–14 FINTRAC finalized a new Delegation of Financial Authority. With the implementation of the new Delegation, FINTRAC provided each delegated manager with their respective delegation chart with detailed explanations, accompanying notes and roles and responsibilities. 

FINTRAC will implement this recommendation through various forms of training and communication. Responsibility centre managers will be reminded via an electronic communique of the various requirements for expenditure initiation and commitment control. Emphasis will be placed on the importance of commitment control prior to expenditure initiation, dated signatures and accurate commitment estimates including supporting documentation.   

Additionally, in order to ensure the recommended information is included on file for review, a checklist will be created in Q4 2013–14 to aid in the account verification and payment authority process. The checklist will include all relevant supporting items.

Head, Accounting Operations

Q4 2013–14

  1. FINTRAC should ensure that the payments and settlements are carried out for the accurate amount, supported by complete documentation and done on a timely basis.

High

Response:

FINTRAC recognizes the need to ensure that account verification is performed by someone with the delegated authority, properly dated, supported by complete documentation and done on a timely basis.

Planned Actions:

In Q3 2013–14 FINTRAC finalized a new Delegation of Financial Authority. With the implementation of the new Delegation, FINTRAC provided each delegated manager with their respective delegation chart with detailed explanations, accompanying notes and roles and responsibilities. 

FINTRAC will implement this recommendation through various forms of training and communication. Responsibility centre managers will be reminded via an electronic communique of the various requirements for account verification. Emphasis will be placed on the importance that each function is carried out by someone with proper delegation of authority, that there is verification of the correctness and accuracy of each payment and this is accomplished on a timely basis.

Additionally, in order to ensure the recommended information is included on file for review, a checklist will be created in Q4 2013–14 to aid in the account verification and payment authority process. The checklist will include all relevant supporting items.

Head, Accounting Operations

Q4 2013–14

  1. FINTRAC should ensure that the payments and settlements are carried out for the accurate amount, supported by complete documentation and done on a timely basis.

High

Response:

FINTRAC recognizes the need to ensure that payment and settlement of accounts are carried out on a timely basis.

Planned Actions:

The financial operations team will use a file review checklist to ensure payments and settlements are carried out for the accurate amount and supported by complete documentation. 

FINTRAC will ensure that the financial officer certifying under Section 33 of the FAA signs and dates each invoice/expense claim to identify that payments are processed on a timely basis.

Head, Accounting Operations

Q4 2013–14

Return to footnote 1 The FINTRAC Finance and Community Forum is a bi-monthly meeting with representatives from Finance, Administration and Procurement to discuss topics of importance with all Administrative officers and those involved in corporate/financial activities.

Date Modified: