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U.S. DOC Inspector GeneralU.S. DOC Inspector Generalce o nves ga onsce o nves ga ons
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Department of CommerceDepartment of Commercenves ga onsnves ga ons
Welcome
Greetings from the U.S. Department of Commerce, Office of InspectorGeneral, Office of Investigations. We would like to congratulate you
and your co-workers for winning an award pursuant to the American.
As part of our Recovery Act Oversight Program, we ask that youparticipate in our Fraud Prevention e-training by reviewing the
.
Thank you for your participation.
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Department of CommerceDepartment of Commercenves ga onsnves ga ons
Who We Are
Office of Inspector General, primarily staffed with:
Special Agents / Criminal Investigators
Com uter Crimes Unit
Our investigative authority includes pursuing allegations of:
Criminal violations
Civil fraud violations Administrative violations
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Department of CommerceDepartment of Commercenves ga onsnves ga ons
Investigative JurisdictionOur investigative jurisdiction includes monitoring all of thefunding (i.e., contracts and grants), programs, and employeesof DOC Headquarters and each of the DOC bureaus:
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Grant frauds Contract frauds
Antitrust violations Embezzlements
Property thefts Conflicts of Interest Bribery, kickbacks False claims & invoices Bank fraud Money laundering
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Identity theft scams
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OIG Recovery Act Authority
The Recovery Act gives our office specific authority to reviewand investigate any concerns regarding the use of DOC
Recovery Act funds. Our OIG agents are authorized to:
Examine all contractor, subcontractor, state or local recordsrelated to Recovery Act funding transactions
Initiate investigations and work in connection with OIG Auditors
Interview employees
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Recovery ActRecovery Actvers g rogramvers g rogram
U.S. DOC/OIG InvestigationsRecovery Act Oversight Program
In response to the Stimulus bill, we developed an oversight
program for DOC which is responsible for:
Monitoring all DOC Recovery Act awards
Providing fraud awareness training to DOC staff working with
ecovery c awar s.
Providing fraud prevention training to contractor and grantrecipients working with DOC Recovery Act awards.
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Recovery ActRecovery Actvers g rogramvers g rogram
Our Pro ram Mission
To work with DOC bureaus and funding
awards are monitored and effectivelyprotected from waste, fraud, and abuse.
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Fraud PreventionFraud Preventionra n ng ra n ng
Fraud Prevention Training Goals
Provide fraud prevention training to funding recipients.
Encourage open communication with agency representatives.
Promote honesty, efficiency and fraud awareness efforts.
awards.
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What is Contract andWhat is Contract andran rauran rau
Contract / Grant Fraud
An act of deceit, trickery or deliberate neglect, committed by afederal funding recipient against the funding agency for the
purpose of gaining something of value.
One or more of the following acts has usually occurred:
Deliberate neglect of procurement rules and guidelines
Deliberate falsification of information
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What is Contract andWhat is Contract andran rauran rau
Contract / Grant Fraud
May be hidden, discreet or completely overt
May involve a large OR small portion of a contract or award
May involve a conspiracy between subcontractors and/orgovernment officials
May be a one-time incident or ongoing matter
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Relevant Criminal andRelevant Criminal andv a u esv a u es
18 U.S.C. 666 Theft or bribery concerning programsreceiving Federal funds
,or records
18 U.S.C. 1001 Statements or entries generally [false
18 U.S.C. 287 False, fictitious or fraudulent claims
. . . defraud United States
15 U.S.C. 1 Sherman Antitrust Act [civil]
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31 U.S.C. 3729 Civil False Claims Act
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GRANT FRAUD
A NIST Advanced Technologyrogram rec p en was conv c e or
misapplying approximately$500,000 of grant funds to pay forpersonal expenses, including rent,home renovations, cleaningservices, restaurant meals, andmiscellaneous household items.
Four officials of an EDA RevolvingLoan Fund program were convictedof fraud, conspiracy and money
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aun er ng a er conver ng near y$800,000 to their personal use.
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CONTRACT FRAUD
The CEO of a corporate entity under
false claims for submitting invoicesunder a Buy America program,
certifying U.S. origin of productssu lied when in fact the roductsoriginated in China.
The CEO of a company participating in
convicted of wire fraud for submittingfalse bids from non-existent companies,the purpose of which was to fix prices
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Please consider ourPlease consider our
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Tips for Keeping it SafeTips for Keeping it Safe
Follow government rules,regulations, and guidelines
Promote efficiency, honesty,and professionalism
Act in good faith
Ask questionsdo not
Maintain fraud preventionrefresher training
assume the answers
Report accurate information
Provide employees with acopy of contracting rulesand regulations
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Tips for Keeping it SafeTips for Keeping it Safe
Avoid gray areasor risky situations
with subcontractors
Stay organized
Report any problems timely
Require full disclosurefrom employees andsubcontractors Communicate openly and
often with our a enc
Reward employees foridentifying projectweaknesses, waste,
representative
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Red Flags a.k.a.Red Flags a.k.a.
THINGSTHINGS NOTNOT TO DOTO DO
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PREPRE--AWARDAWARDTHINGSTHINGS NOTNOT TO DOTO DO
Bid riggingbidding
arrangements are NEVER
Defective and inflated pricing
Price fixing and/or pricinga reements
aares
Consultants
Equipment
Scams and fraudulentagreements with
oo s an serv ces
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su con rac ors
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PREPRE--AWARDAWARDTHINGSTHINGS NOTNOT TO DOTO DO
Offer bribes, gifts, or
gratuities to governmentofficials
Embellishmentunrealistic
performance goals andro osed romises
Give false or misleadingproposal information
Double dipcompete forwork identical to another
Withhold information whichis required on proposals
from another federal agency.
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POSTPOST--AWARDAWARDTHINGSTHINGS NOTNOT TO DOTO DO
Double billing Deliberate product overage
Poor accounting system
Shifting costs often from onecate or or cost account to
Deliberate accounting error another without approval
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POSTPOST--AWARDAWARDTHINGSTHINGS NOTNOT TO DOTO DO
Embezzlement of project
funds or equipment
Unauthorized travel costs
Misappropriation of projectfunds or equipment
Less than arms lengthtransactions
Deliberate waste of projectfunds, equipment andresources
Use of fictitious vendors
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POSTPOST--AWARDAWARDTHINGSTHINGS NOTNOT TO DOTO DO
Give unauthorized
personnel access
Maintain ghost employees
Maintain underqualifiedpersonnel
Conduct unauthorizedchanges to personnel
Falsify time and attendancerecords
a n a n na equa e n ernacontrols (e.g., one personhandling everything)
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POSTPOST--AWARDAWARDTHINGSTHINGS NOTNOT TO DOTO DO
Co-mingle projects Mislead government
contracting/program officials nappropr a e use o cas
Alter or destroy documents
Mislead auditors/inspectors
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POSTPOST--AWARDAWARDTHINGSTHINGS NOTNOT TO DOTO DO
Claim ignorance of rules Interpret rules to your benefitor satisfaction
Attempt to convince agencyrepresentatives to change orignore the rules
Neglect or circumventBuy American provisionsunless authorized in writing
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The Golden Rule of Fraud Prevention
WHEN IN DOUBT.DONT DO IT.
appropriate guidance.
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Did ou know
Every person working on Recovery Act funded
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Whistleblower ProtectionRecovery ActThe Recover Act rovides ex licit rotections for nonfederalwhistleblowers. These protections apply to all contractor and granteestaff working on Recovery Act awards. The Act prohibits fundingrecipients from discharging, demoting or discriminating against any
employee for disclosing any concern to their supervisor, the head of afederal agency or his/her representatives, or the OIG information that theemployee believes is evidence of:
Gross mismana ement or waste of rant or contract funds.
Danger to public health or safety related to the use of funds. Abuse of authority related to the implementation or use of funds.
Violation of law, rule or regulation related to an agency contract or grant
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Whistleblower ProtectionOIG Responsibilities
Investigate all whistleblower complaints related to Recovery Act fundsthat are not frivolous or being addressed by another official proceeding.
Report of our findings to the complainant, complainants employer, headof DOC and the Recovery Accountability and Transparency Board within180 days (extensions may be applied for).
Provide a written explanation to complainants and their employers if wedecline to pursue a whistleblower allegation.
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Whistleblower ProtectionOIG Responsibilities
Uphold the Privacy Actby NOT disclosing information aboutcomplainants, except where required by law or court order.
Provide information in our semi-annual reports to Congress to include: Investigations we declined to pursue and
Investigations requiring a time extension
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1. You discover that a co-worker submitted false
government agency.
representative
b Confront the em lo ee
c) Do nothing
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2. A subcontractor employee tells you he
upper management at your company and the
subcontractors company.a) Ignore it - its probably just a rumor
b Contact the OIG
c) Contact your agency representative
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3. You believe a product/deliverable your
what is supposed to be provided.
b) Contact your Congressman
c u your o ou o rus ra ond) Contact the OIG and your agency
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4. You believe that your company is charging.
a) Contact the OIG
b) Contact your agency representative
c) All of the above
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5. Your manager tells you the governments,
look like were doing what they want.
b) Contact the OIG
c on ac your agency represen a ved) B and C
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7. Your manager demotes you for inquiring
Recovery Act award.
b) Contact the OIG as a whistleblower
c e a awsud) Do nothing
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8. You believe your company is co-mingling the
agencies.
b) Start a rumor within the company
c on ac e pressd) Contact your agency representative
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9. You are asked to charge work hours to a
work on.
b) Contact the OIG and your agencyre resentative
c) Write your congressman
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10. You believe your company is asking the
necessary for the project.
b) Contact the OIG
c on ac ed) A & B
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PROTECT YOURTAX DOLLARS!AX DOLLARS!Americans are counting onyou to be responsible withRecovery Act funding. Werely on your judgment,
to keep us informed, so wemay protect our programs!
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Please be on the lookout forPlease be on the lookout for
ANYTHING that indicates,
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OIG HOTLINEPhone: (800) 424-5497hone: (800) 424 5497
Fax: (202) 482-2803Email: [email protected]
U.S. Department of CommerceOffice of Inspector General For more information
Office of InvestigationsRecovery Act Oversight Program(202) 482-0934
please visit our websitewww.oig.doc.gov
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(202) 482 0934
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Thank you for your participation.
You have completed the
Fraud Prevention e-training.
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