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The Office of General Counsel should conduct and document an assessment on the legal sufficiency of the Watch List program and its impact on addressing potential applicant misconduct or untrustworthiness through mitigation measures and document their conclusions.
The Office of General Counsel should update the Watch List procedures to include examples of risks warranting mitigating measures and what mitigating measures can be applied to parties when there is a match.
The Office of General Counsel should implement documentation requirements for actions taken as a result of Watch List matches, to include support for taking mitigating measures.
The Office of General Counsel should update the Watch List procedures to include examples of a suspicion and reputation of untrustworthy behavior and to add parties based on referrals from other agencies.
The Office of General Counsel should update the Watch List procedures to align with actual practices regarding parties EXIM determines should no longer be on the Watch List; the standards for deactivation or removal, including when there is a match to a party that should be deactivated or removed; and in the case of deactivation what the implications are for future searches and reactivation.
The Office of General Counsel, in coordination with the Office of the Chief Information Officer, should implement a process for automatically deactivating or removing parties that have been on the Watch List over 10 years without a match.
The Office of General Counsel should state and implement a requirement in the procedures and develop a process to concurrently notify OIG whenever there are new parties added to the Watch List, there are true matches on the Watch List, and there are parties removed or deactivated from the Watch List.
The Office General Counsel, in coordination with the Office of Communications, should upload the Watch List system of record notice to EXIM’s public website.