Unclear roles between the Legal and Treasury departments regarding private bank accounts for expropriation cases caused delays, inefficiencies, and non-compliance with internal control rules.

Why It Matters

Recommended Actions

• Request from the respective Courts the approval of the transfer/closure of deposits maintained with the private bank for settled expropriation cases
• Submit a complete report on the updated status of all expropriation cases within a specific deadline to allow the TD to reconcile the bank accounts with their intended purpose and initiate appropriate account closures, if applicable
• And Provide regular updates to AD and the Audit Team on the status of expropriation cases at least annually or as often as necessary when there are significant developments, to support continuous monitoring and timely closure of deposit accounts.

Original Audit Finding Excerpt

"ngency Action Plan Reason for . . ; | Target Implementation Partial/Delay/ . . Ref. Audit Observations Audit Recommendations Action Plan Person/Dept. Date Status of Non- Action Taken/Action to be Taken Responsible Implementation | Implementatio From To n, if applicable No. | The lack of clear delineation | We recommended and Legal July 2025 December NHA Memorandum Circular No. 2024-036 dated May 18 of responsibilities between | Management agreed to Require Department 2025 30, 2024, regarding the delineation of responsibilities the Legal and Treasury | LD to: between the Legal and Treasury Departments, was Departments in managing a. Request from the respective Treasury Not Implemented approved and signed by the General Manager. The 56 bank accounts with aj| Courts the approval of the Department Circular clearly establishes that the Treasury private bank related to | transfer/closure of deposits Department is responsible for the opening and closing expropriation cases has | maintained"

Source Document