Review of MCC and Implementing Partner's Management Controls, and Compliance with Laws and Regulations Related to Drug-Trafficking and Criminal Activities

We recommend that MCC/El Salvador require BANDESAL and FOMILENIO to amend all loan agreements to include language indicating that the contract would be subject to cancellation upon conviction of a narcotics offense or to engaging in drug trafficking

We recommend that MCC/El Salvador complete an independent review of approved applicants to determine if financial irregularities have been overlooked, terminate loans if applicable, and report to the appropriate local agency the results.

We recommend that MCC/El Salvador require BANDESAL and FOMILENIO to perform criminal background checks (which includes reviewing police records and excluded parties lists) on existing loan applicants.

We recommend that MCC/El Salvador require BANDESAL to develop a process, including training, for members of the organizations, loan recipients, and others to report fraud, irregularities, and questionable acts and detailed policies and procedures to investigate any allegations.

We recommend that MCC/El Salvador require BANDESAL to (a) further investigate the inconsistencies and irregularities noted in this review with regards to the loan application and loan recipients of the animal factory; (b) terminate the agreement if applicable, and (c) refer the case, if appropriate, to tax officials for investigation.