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

Recommendations

Recommendation 1

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

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Recommendation 2

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.

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Recommendation 3

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.

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Recommendation 4

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.

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Recommendation 5

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.

Questioned Cost:
$0
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