Open Recommendations

Recommendation withheld based on applicable Freedom of Information Act exemptions.

Recommendation withheld based on applicable Freedom of Information Act exemptions.

The Transportation Portfolio Monitoring Division should implement a periodic inspection schedule and coordinate with the borrowing airlines to assess use, condition, and maintenance records that help preserve the value of EXIM’s collateral.

Design and implement monitoring controls to help ensure that password configurations for the FMS-NG
application are in compliance with the FMS-NG Operations Manual [language withheld based on applicable Freedom of Information Act exemptions].

We recommend that EXIM design, document, and implement controls to ensure [language withheld based on applicable Freedom of Information Act exemptions] that logical access is restricted to only authorized users.

EXIM’s Office of the Chairman, in coordination with the Office of Policy Analysis and International Relations, the Office of Board Authorized Finance, and Office of General Counsel, should propose updated Environmental and Social Due Diligence Procedures and Guidelines for Board review and approval that incorporates, as necessary, revisions of applicable international standards.

EXIM’s Office of the Chairman, in coordination with the Office of Policy Analysis and International Relations, the Office of Board Authorized Finance, and the Office of General Counsel, should produce updated Environmental and Social Due Diligence Procedures and Guidelines for Board review and approval that clarify whether and, if so, how the ESPG relates to domestic transactions.

The Office of General Counsel should produce a written opinion on the circumstances under which Board members may withhold or approve transaction based upon environmental effects.

EXIM’s Office of Board Authorized Finance should develop a written policy or procedure that outlines the process for addressing when a project’s implementation does not align with EXIM’s Environmental and Social Due Diligence Procedures and Guidelines after the Board has approved the transaction.

EXIM’s Office of Board Authorized Finance should develop a written policy or procedure that defines when an environmental and/or social due diligence review is necessary for any restructuring or modifications requiring Board re-approval.

EXIM’s Engineering and Environment Division, in coordination with the Asset Management Division/Special Assets Group, should update EXIM’s enhanced monitoring plan for the Sasan Power Limited Project to incorporate and require more robust compliance monitoring, to include onsite monitoring, of environmental, health, and safety standards, as required by the credit agreement.

EXIM’s Engineering and Environment Division, in coordination with the Asset Management Division/Special Assets Group and the independent consultants, should identify additional information sources about activities or concerns related to the Sasan Project to help provide more robust enhanced monitoring, such as input from the local community.

EXIM’s Engineering and Environment Division, in coordination with Asset Management Division/Special Assets Group, should incorporate routine maintenance and operations into its update of the enhanced monitoring plan, to include clarifying roles and responsibilities, for the Sasan Power Limited Project.

EXIM’s Asset Management Division/Special Assets Group should require Sasan Power Limited, in coordination with Reliance Power Limited as the project sponsor, to have the original manufacturer perform detailed inspections of all transformers at the Sasan Power Limited Project.

EXIM’s Office of Board Authorized Finance should conduct a review of the Samalkot Power Limited Project’s transaction approval to determine if EXIM properly identified and accounted for the financial risks specific to the absence of a confirmed source of gas to support the project, and if any lessons learned can be applied to future EXIM transactions.

EXIM’s Office of Human Capital should conduct a staffing needs analysis for its office to determine the appropriate staffing levels needed to support a human capital function in alignment with federal regulations and guidance and develop a plan to implement the results of its assessment.

EXIM’s Office of the Chair, in coordination with the Office of Human Capital, should direct an agency-wide organizational and workforce study used to develop a strategic workforce plan that accurately identifies and portrays actual, current, and future workforce needs that align to EXIM’s work requirements in furtherance of its mission.

EXIM’s Office of Human Capital should establish an EXIM working group to research and provide recommended solutions to standardize, streamline, and track processes, including the hiring process.

EXIM’s Office of the Chair, in collaboration with EXIM’s Office of Human Capital, should conduct an agency-wide culture assessment to identify ways to improve EXIM’s culture, retention, and employee engagement.

EXIM’s Office of the Chair, in coordination with the China and Transformational Exports Program (CTEP) office, should establish policy and procedures that clearly define the authorities, roles, and responsibilities across EXIM for CTEP implementation.