Open Recommendations

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 OIG recommends the Office of Board-Authorized Finance update its policies and procedures to consider additional documentation on the status of collateral as part of the scheduled or ad hoc credit risk reviews. These updates should include information on inspections or site visits performed as well as the appropriateness of maintaining a one level improvement on the Budget Cost Level.

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 Board Authorized Finance should develop and implement a policy to address changes in exposure fees following Board approval, including in co-financing transactions.

EXIM's Office of Board Authorized Finance should define the approval responsibility for changes in exposure fees.

EXIM's Office of Board Authorized Finance in coordination with Office of General Counsel should develop and implement guidelines or a checklist requiring management to verify that appropriate legal and policy guidance is in place prior to initiating direct loan transactions.

The Office of the General Counsel (OGC) should issue and communicate guidance to the agency on ensuring and documenting how EXIM will comply with Section 2(k) of EXIM’s Charter throughout the transaction process, including timeline adjustments and delays.

The Office of Board Authorized Finance (OBAF) should develop and implement a formalized system for electronically tracking pending transactions and documenting the rationale behind timeline changes and delays for pending transactions. This process should include structured reporting mechanisms to provide non-sensitive, public-facing updates on major transactions, strengthening stakeholder engagement, increasing transparency, and ensuring compliance with EXIM’s statutory obligations under Section 2(b)(1)(J) of the EXIM Charter. Additionally, EXIM should consider establishing performance benchmarks for different transaction types to help manage processing expectations while accounting for necessary due diligence and risk assessments.

The Chair should coordinate with the Board to implement a process for advancing transactions for a vote that includes criteria that are objective, transparent, and compliant with Section 2(k) of EXIM’s Charter.

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 Policy Analysis and International Relations should consider conducting a study with existing EEP exporters, to identify the key factors resulting in the decision to utilize EXIM for financing the EEP export. These key factors should then be assessed for potential inclusion into future outreach efforts with potential U.S. exporters to expand EEP transaction opportunities.

EXIM’s Chief Banking Officer should consider establishing periodic internal reporting of specific EEP outreach efforts by their office such that those efforts can be assessed for effectiveness in identifying and securing EEP authorizations. The reporting should include the type of outreach held, the attendees and any follow up meetings resulting from the outreach.

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 consolidate the agency’s Performance Management programs into a singular program according to federal benchmarks and organization design principles and develop a plan to expand the Performance Management program through programs that link human capital initiatives to organizational performance.

EXIM's Office of Human Capital should conduct an EXIM-wide workforce analysis, which may include analysis of grade distribution, career path opportunities, supervisory ratios, delayering, and position management to form the basis of a plan for career progression, pathways, and succession planning.

EXIM’s Office of the Chair, in cooperation with the Office of Human Capital, should establish a Workforce Development Plan, as outlined in the Office of Personnel Management’s Human Capital Framework, to provide structured pathways for EXIM employees to enhance their skills, advance their careers, and ultimately contribute more effectively to EXIM's mission and objectives.

EXIM’s Office of Chair, in coordination with its senior leadership and the Office of Human Capital, should develop an agency-wide succession plan, using relevant agency workforce data and evidence such as vacancy, hiring, retirement, and current and future skills gaps, which includes identifying and defining “key vacancies,” to ensure compliance with 5 CFR Part 412.

EXIM’s Office of Human Capital should develop a workforce succession plan to support the continuity of the agency’s human capital operations, to include a comparative assessment of required specialist and generalist tasks and skills and identification of single points of failure.

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 should identify the human capital functions that affect EXIM’s ability to achieve its mission and develop a plan to measure and mitigate risks.

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.

EXIM’s China and Transformational Exports Program office, in coordination with the Office of the Chair, should review the functions, roles, and responsibilities of program officials and determine whether the program is sufficiently staffed and whether obstacles exist for recruitment and retention.

EXIM’s China and Transformational Exports Program office should establish a performance management framework, including measurable goals and indicators to assess program success and progress in achieving its intended purpose.

EXIM’s China and Transformational Exports Program (CTEP) office should assess how existing policies and practices may be adapted to maximize CTEP’s effectiveness and potential including whether the program has the necessary tools it requires to address Transformational Export Areas and then develop a plan to implement these policies.

The Office of the Chief Management Officer and Security Services Office assign the staffing and resources necessary to conduct pending reinvestigations.

EXIM’s Office of Human Capital, in coordination with the Office of General Counsel, should revise the Conduct, Performance, and Discipline Policy to either define the standards of conduct or cite EXIM’s Code of Business Conduct and Ethics as well as clarify policy language to ensure that all EXIM employees are held to the same standards of conduct, regardless of the employee's appointment status.