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Recommendations Database

GAO’s recommendations database contains report recommendations that still need to be addressed. GAO’s priority recommendations are those that we believe warrant priority attention. We sent letters to the heads of key departments and agencies, urging them to continue focusing on these issues. Below you can search only priority recommendations, or search all recommendations.

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As of October 25, 2020, there are 4812 open recommendations, of which 473 are priority recommendations. Recommendations remain open until they are designated as Closed-implemented or Closed-not implemented.

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Subject Term: "Currency and coinage"

5 publications with a total of 16 open recommendations
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Virtual Currencies: Additional Information Reporting and Clarified Guidance Could Improve Tax Compliance
GAO-20-188, Feb 12, 2020
Director: James R. McTigue, Jr.,
Phone: (202) 512-9110

4 open recommendations
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Recommendation: The Commissioner of Internal Revenue should update the FAQs issued in 2019 to include a statement that the FAQs may serve as a source of general information but cannot be relied upon by taxpayers as authoritative since they are not binding on IRS. (Recommendation 1)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: IRS disagreed with this recommendation. In an August 2020 letter, IRS stated that the 2019 currency FAQs are illustrative of how longstanding tax principles apply to property transaction and IRS does not take positions contrary to public FAQs. However, if IRS intends the public FAQs on virtual currency to be binding on IRS it could address our recommendation by publishing the FAQs in the Internal Revenue Bulletin. Doing so would render a disclaimer statement unnecessary and would satisfy the intent of the recommendation. We will continue to follow up with IRS on this recommendation and will provide an update if IRS takes action.
Recommendation: The Commissioner of Internal Revenue should take steps to increase third-party reporting on taxable transactions involving virtual currency, which could include clarifying IRS's interpretation of existing third-party reporting requirements under the Internal Revenue Code and Treasury Regulations, or pursuing statutory or regulatory changes. (Recommendation 2)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: IRS agreed with this recommendation. In August 2020, IRS informed us that IRS's Office of Chief Counsel and the Department of the Treasury are developing guidance that will address third-party reporting on certain taxable transactions involving virtual currency. IRS expects that this guidance will also propose rules to avoid duplicate reporting under other information reporting regimes that may apply to transactions involving virtual currency. We will continue to monitor IRS's efforts to increase third-party reporting on taxable transactions involving virtual currency.
Recommendation: The Commissioner of Internal Revenue should clarify the application of reporting requirements under FATCA to virtual currency. (Recommendation 3)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: IRS disagreed with this recommendation. In an August 2020 letter, IRS said it intends to focus on developing guidance regarding information reporting on certain virtual currency transactions involving U.S. businesses instead of clarifying the application of reporting requirements under FATCA to virtual currency. IRS stated that additional guidance on FATCA requirements may be appropriate in the future as the workings of foreign virtual currency exchanges become more transparent over time. We found that many virtual currency stakeholders were uncertain about how, if at all, FATCA requirements apply to virtual currency and would benefit from clarifications to the guidance. We will continue to follow up with IRS on this recommendation and will provide an update if IRS takes action.
Recommendation: The Director of FinCEN, in coordination with IRS as appropriate, should make a statement about the application of foreign account reporting requirements under the Bank Secrecy Act to virtual currency readily available to the public. (Recommendation 4)

Agency: Department of the Treasury: Financial Crimes Enforcement Network
Status: Open

Comments: FinCEN agreed with this recommendation. When we can confirm that FinCEN has taken action we will provide updated information.
Individual Retirement Accounts: IRS Could Better Inform Taxpayers about and Detect Noncompliance Related to Unconventional Assets
GAO-20-210, Jan 27, 2020
Director: Mctigue, James R Jr
Phone: (202) 512-9110

3 open recommendations
Display
Recommendation: The Commissioner of Internal Revenue should assess options for updating Publications 590-A and 590-B to either include more information or direct taxpayers to other resources for IRA owners with investments in unconventional assets. Such information could include: storage requirements for IRA investments in certain precious metals; valuation methods for hard-to-value IRA assets; the Department of Labor's process for granting exemptions to IRA prohibited transactions rules; and IRA investments with the potential to create unrelated business income tax liabilities. (Recommendation 1)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Recommendation: The Commissioner of Internal Revenue, building on forthcoming compliance research using new IRA asset data, should evaluate the feasibility of requiring disclosure for high-risk IRA asset types associated with abusive schemes as transactions of interest. (Recommendation 2)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Recommendation: The Commissioner of Internal Revenue should develop resources (such as training materials or job aids) for Small Business/Self-Employed examiners conducting IRA owner audits that explain how IRAs with unconventional assets can generate unrelated business income tax liability, and how examiners can refer cases to unrelated business income experts in IRS for assistance. (Recommendation 3)

Agency: Department of the Treasury: Internal Revenue Service
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Bank Secrecy Act: Examiners Need More Information on How to Assess Banks' Compliance Controls for Money Transmitter Accounts
GAO-20-46, Dec 3, 2019
Director: Michael E. Clements
Phone: (202) 512-8678

4 open recommendations
Display
Recommendation: The Board of Governors of the Federal Reserve System should, in coordination with the other federal banking regulators, and with input from BSA/AML examiners and other relevant stakeholders, take steps to improve examiners' ability to evaluate the effectiveness of banks' BSA/AML compliance controls with respect to money transmitter accounts. Steps may include providing updates to examination procedures, examiner training, or a combination of methods. (Recommendation 1)

Agency: Federal Reserve System
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Recommendation: The Comptroller of the Currency should, in coordination with the other federal banking regulators, and with input from BSA/AML examiners and other relevant stakeholders, take steps to improve examiners' ability to evaluate the effectiveness of banks' BSA/AML compliance controls with respect to money transmitter accounts. Steps may include providing updates to examination procedures, examiner training, or a combination of methods. (Recommendation 2)

Agency: Department of the Treasury: Office of the Comptroller of the Currency
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Recommendation: The Chairman of the Federal Deposit Insurance Corporation should, in coordination with the other federal banking regulators, and with input from BSA/AML examiners and other relevant stakeholders, take steps to improve examiners' ability to evaluate the effectiveness of banks' BSA/AML compliance controls with respect to money transmitter accounts. Steps may include providing updates to examination procedures, examiner training, or a combination of methods. (Recommendation 3)

Agency: Federal Deposit Insurance Corporation
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Recommendation: The Chairman of the National Credit Union Administration should, in coordination with the other federal banking regulators, and with input from BSA/AML examiners and other relevant stakeholders, take steps to improve examiners' ability to evaluate the effectiveness of banks' BSA/AML compliance controls with respect to money transmitter accounts. Steps may include providing updates to examination procedures, examiner training, or a combination of methods. (Recommendation 4)

Agency: National Credit Union Administration
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Bank Secrecy Act: Agencies and Financial Institutions Share Information but Metrics and Feedback Not Regularly Provided
GAO-19-582, Aug 27, 2019
Director: Michael E. Clements
Phone: (202) 512-8678

4 open recommendations
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Recommendation: The Director of FinCEN, after consulting with the Commodity Futures Trading Commission (CFTC), should consider prioritizing the inclusion of the primary SRO conducting BSA examinations in the futures industry in the Bank Secrecy Act Advisory Group (BSAAG) on a more consistent basis and also making the primary futures industry association a concurrent member. (Recommendation 1)

Agency: Department of the Treasury: Financial Crimes Enforcement Network
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Recommendation: The Director of FinCEN, after consulting with CFTC, should take steps to explore providing direct BSA data access to the National Futures Association. (Recommendation 2)

Agency: Department of the Treasury: Financial Crimes Enforcement Network
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Recommendation: The Director of FinCEN should review options for FinCEN to more consistently and publicly provide summary data on the usefulness of BSA reporting. This review could either be concurrent with FinCEN's BSA value study or through another method. (Recommendation 3)

Agency: Department of the Treasury: Financial Crimes Enforcement Network
Status: Open

Comments: As of August 2020, FinCEN officials told us that they began to implement a strategy to communicate the results of its BSA Value Study (completed in April 2020) and more generally publicize statistics on the value that BSA reporting provides to industry and the public. According to FinCEN officials, they have made some progress in implementing the communication strategy, including briefing key public and private sector stakeholders and developing fact sheets, videos and other materials for eventual public release, and expect to complete the initial phase of the communication plan by the end of 2020.
Recommendation: The Director of FinCEN should review options for establishing a mechanism through which law enforcement agencies may provide regular and institution-specific feedback on BSA reporting. Options should take into consideration providing such feedback to cover different types of financial institutions and those with significant financial activity. This review could either be part of FinCEN's BSA value study or through another method. (Recommendation 4)

Agency: Department of the Treasury: Financial Crimes Enforcement Network
Status: Open

Comments: According to FinCEN officials, it will use measures outlined in response to Recommendation 3 and information gathered from the BSA Value Study to develop a specific action plan to better collect data for FinCEN and its law enforcement and other partners in a way that allows them to communicate more consistent feedback to reporting entities, and address the gaps and recommendations from the study. FinCEN anticipates the development and approval of the action plan by the end of 2020.
U.S. Currency: Financial Benefit of Switching to a $1 Coin Is Unlikely, but Changing Coin Metal Content Could Result in Cost Savings
GAO-19-300, Mar 21, 2019
Director: Andrew Von Ah
Phone: (202) 512-2834

1 open recommendations
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Recommendation: Congress should consider amending the law to provide the Secretary of the Treasury with the authority to alter the metal composition of circulating coins if the new metal compositions reduce the cost of coin production and do not affect the size, weight, appearance, or electromagnetic signature of the coins. (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: As of July 2020, the Currency Evolution Now to Save Act (the CENTS Act) has been introduced in the Senate. This bill authorizes the Department of the Treasury to prescribe a different composition of materials in the half-dollar, quarter-dollar, dime, or five-cent coin if such action reduces the overall cost of minting the coin and does not affect (1) the diameter and weight of the coin; or (2) the functionality of the coin, including the electromagnetic signature for accepting it.