Controls Over Accountable Property at the Baltimore Field Division of the Federal Bureau of Investigation

Report Number 04-37
September 2004
Office of the Inspector General

Appendix 7

FBI Policy Memorandum Establishing $1,000 Threshold


Precedence: ROUTINE   Date: 02/14/2002
To: All Divisions Attn: Personal Attention:
Assistant Director
Special Agent in Charge
Administrative Officer
Supply Technician
From: Finance Property Procurement and Management Section,
Property Management Unit
Contact: Towanna R. Johnson, ext. 8242
Approved By: Chiaradio Robert J, Lampinski Jeffrey A, Bland Andrew R III, Storms James E
Drafted By: Johnson Towanna R:jal
Case ID #: 66F-HQ-C1189737

Synopsis: Announces increase to the threshold value of accountable non-expendable property and provides comprehensive policy regarding accountable property management from time of acquisition through disposal.

Details: The FBI's accountable property inventory was completed on January 24, 2002, the first complete physical inventory of all field offices and Headquarters entities in more than ten years. The inventory resulted in the discovery of more than $52 million in lost, stolen, or unaccounted for property acquired and entered for inventory purposes into the FBI Property Management Application (PMA) since 1988. The next property inventory is scheduled for July, 2003.

On February 14, 2002, consistent with current Department of Justice (DOJ) policy, Director Mueller approved an increase in the threshold value of accountable non-expendable property from $500 or more to $1000 or more. As a consequence, nearly 154,000 items currently subject to inventory will in the future be exempt, significantly reducing the time, labor, and expense associated with the bi-annual accountable property inventory and property management in general.

Adherence to property management policy and strict accountability are the keys to minimizing future levels of lost, stolen, or unaccounted for property. A concise but yet comprehensive synopsis of current property management policy follows for those with direct and indirect responsibility for FBI property management. Detailed guidance may be found in the Accountable Property Manual which is being revised for distribution to all FBI divisions, field offices, and Legats.

In reality, beyond those persons with direct and indirect job responsibilities for property management, all FBI employees who possess FBI property are accountable for its receipt, safekeeping, transfer, and ultimate return. Division heads are therefore encouraged to bring this communication to the attention of all employees.

General Background

The FBI is required to conduct a physical inventory of property, plant, and equipment every two years. The inventory applies to non-expendable property with an acquisition value of $1000 and greater (previously $500 and greater), and to all firearms, COMSEC equipment, laptops, jewelry, and central processing units regardless of value. Property in these categories is maintained for inventory purposes in the FBI PMA. Property valued at $25,000 or more (capital assets) is recorded on the General Ledger of the FBI.

Property management responsibilities are assigned to a variety of persons within the FBI. The Section Chief of the Property Procurement and Management Section (PPMS) is the sole Property Management Officer of the FBI and is thereby responsible for the administration, coordination, and control of the FBI's Property Management Program. Assistant Directors and Special Agents in Charge of each division and field office, as Accountable Property Officers (APO), are personally responsible for the proper and effective execution of property management policy within their respective divisions. APOs may designate one or more Property Custodians (PC) or Supply Technicians (hereafter referred to as Property Custodians) to maintain records for custody and control of accountable property. The PC maintains accurate inventory control and accountability systems to effectively manage accountable property and assists in the identification of property considered excess.


The FBI acquires property through a variety of means to include requisition, purchasing, forfeiture, and/or through the transfer of excess property from other agencies. The acquisition of property through requisition requires the use of Form FD-369 to initiate purchases of expendable and non-expendable items such as supplies, furniture and equipment. The PC reviews and signs each FD-369 to ensure all items requested are classified with an FBI account number integral to all aspects of the Bureau's financial management system (FMS). Once this form has been properly completed, the PC forwards all but one copy to the PPMS.

All documents regarding property management matters must be retained in accordance with applicable FBI policies. Current policy permits record destruction once a document by creation date is two or more years old.

To obtain property through transfer from the military or another federal agency, an approved SF-122 must be completed in its entirety by the requesting office and submitted to PMU. All non-expendable property acquired from other federal agencies which meets the inventory dollar threshold of $1000 or more must be assigned a barcode label and placed on the PMA.

All non-expendable property purchased through the third-party draft system; acquired by government credit card~ or received through forfeiture and placed into official use must likewise be assigned a barcode label and placed on the PMA. All Bureau vehicles are placed on the PMA. Adjustments to vehicle inventories are provided directly to the PMU by the Fleet Management and Transportation Services Unit.


It is the responsibility of the PC to receive all shipments of supplies, furniture, and equipment consigned to the office. When such property is received, the PC must ensure the items received are correct, that no shipping damage has occurred, and also determine whether a complete or partial shipment was received. All items acquired by purchase order must be posted to the FMS Purchasing System within 48 hours of receipt. Copies of all receipt documentation must be maintained with the acquisition source document to complete the audit trail.

When a partial shipment is received from a vendor, the PC must process the Receipt Verification portion in the Purchasing System for Only the specific quantity received. Copies of partial receipts must be maintained as a part of the pending file until all goods have been received and posted to the FMS.

Field offices must establish internal procedures to ensure all property received by the office is accurately accounted for by the PC. He/she must act as the central receiving point for all accountable property, no matter how or by whom acquired.

FBIHQ program managers involved in acquisition and transfer of property to field offices are required to provide advance notification to the field offices of all property being shipped from a vendor directly to the office. The program manager, via EC, is to provide a description of the property, quantity, and anticipated arrival date. Property valued at $1000 and more which is shipped directly to the field offices from FBIHQ, Engineering Research Facility, Quantico, or any FBI off-site, is to be barcoded and added to PMA and then transferred within PMA to the field division cost center. When the property is delivered to the field division, the PC will acknowledge its receipt and assume responsibility for recording any subsequent transfer in PMA.


The barcode 15 a two-part, prenumbered decal used to identify each item of non-expendable property which meets the current inventory dollar threshold. The barcode number is the key control factor on the PMA. All assets and accountable property, if not barcoded upon delivery, must be assigned a barcode label by the PC upon receipt. When a barcode label cannot be affixed to the actual property, a 3 x 5 card containing the actual label, location, description of the property, manufacturer, model, and serial number is to be maintained by the PC.

To assist the FBI in accounting for property, some manufacturers are provided FBI barcode labels to affix to property prior to shipment to an office. In these instances, the manufacturer is instructed to place the label on the front of all property. The PC is responsible for placing this property on the PMA upon receipt. Specialty items such as CPUs must be assigned a barcode number and placed on PMA.

Although there is no requirement to enter into PMA non-expendable property valued at less than $1000, at their discretion division heads may establish policy for tracking property valued at less than this threshold. If a division head desires to track property valued at less than the threshold, such as VCRS, cameras, televisions, etc., different colored barcode labels should be used for identification purposes. The use of a barcode label different in color from that used for the tracking of accountable property will enable division personnel to discriminate between items which must as a matter of policy be inventoried bi-annually, and those subject to discretionary inventory.


Acquisitions of non-expendable property to support a covert undercover operation (UCO), special surveillance, or other special investigative need which meet the established inventory dollar threshold and have a useful life greater than one year must be reported in PMA. All property seized during a UCO which becomes FBI owned property, and meets the $1000 or more threshold, must be added to PMA.

Excess property in the custody of other federal agencies or the GSA may be obtained for use in UCOs. If an office locates property it would like to acquire in support of a specific law enforcement mission, an SP-l22 (Transfer Order) must be completed in its entirety. Once the property has been obtained, the field office should immediately coordinate inventory action with the PC by photographing the property if it bears no serial number or other singular identifier, or is considered valuable. A barcode label and brief description of the property should be placed on the back of each photograph and then added to the PMA.

Non-expendable property acquired during the course of an UCO for use as "bait" property should not be placed on the PMA. In accordance with the Confidential Funding Guide, "Each UCO is accountable for the property and must maintain a separate property ledger to account for this property."

The PC should ensure that high-dollar value special case items, such as watches, jewelry, coins, and precious stones are maintained under the physical control of the designated management representative, along with their photographs. These items should be charged out within PMA to the case agent while being utilized.


The FBI transfers property on a temporary or permanent basis within and among the Bureau, DOJ, and other federal agencies. It is the PC's responsibility to process both the transfer and verification of property.

The PC is responsible for property which is transferred from one cost center to another. The PC must process the transfer of the property using PMA's on-line transfer function.

When receiving an item transferred from another cost center, the PC must verify its receipt through PMA. Each PC may run a listing from PMA of all internal transfers which have not been verified as received by his/her cost center. Upon review of this listing, the PC must contact the originating cost center to reconcile any discrepancy.

On many occasions, the FBI transfers property to DOJ off ices, boards, bureaus and divisions as well as to other federal agencies. Transfers of property to the DOJ or other federal agencies must have prior approval of PMU.

It is critical to proper program management that the APO establish internal procedures which ensure that the PC, aside from receiving all accountable property, tracks its transfer in PMA. Procedures must be established which enable the PC to track property for all employees who transfer, retire, or separate from the FBI.


Property and supplies that have become excess to the needs of an organization or are considered unprofitable to retain are subject to disposal. Disposition is the action taken to physically remove property from the FBI's accountable property records. If the property/supplies are no longer needed to satisfy the requirement for which acquired, a canvass should be taken to determine if further use can be found within the off Ice. If the property/supplies can be used elsewhere, transfer of the items is appropriate. Once property has been determined excess to all FBI requirements, it is considered surplus property requiring PMU assistance. Do not dispose of any property determined suitable for surplus until instructions are received from FBIHQ.

Disposal of hazardous material (HAZMAT) or any other substance which is potentially dangerous to public health and safety must be done in strict accordance with Federal Property Management and Environmental Protection Agency (EPA) Regulations. When an office receives FBIHQ authority to dispose of or otherwise release HAZMAT, contact must be made with the state and local equivalent of EPA for guidance on proper disposal procedures.

Controlled substances are not required to be reported as excess and cannot under any circumstances be donated to any local or state agency. Controlled substances can be made available to federal agencies via Drug Enforcement Administration Form 223. When an office is authorized by FBIHQ to dispose of drugs, biologicals, and reagents, they must be destroyed in such a manner as to ensure total destruction.

When a determination has been made that accountable property and/or equipment can no longer be used within an office, the item must be declared excess on the PMA. When excessing property not in PMA, i.e., that which does not meet current inventory dollar thresholds but is in good condition, the item must be barcoded and reported to the PMU via an FD-508, Excess Supplies and/or Equipment Report. Similarly, when excessing property not in PMA and in scrap condition, an internal record keeping system is to be implemented to document such property donated, destroyed, or transferred. Under no circumstances should an office dispose of FBI property without obtaining FBIHQ approval.

Any supply item that has been determined as excess to the needs of an office should be declared as excess on Form FD-508. PMU will obtain a listing from the PMA of all property which has been declared excess by all offices. When a determination has been made that the property cannot be reutilized within the FBI, PMU will initiate action with GSA to surplus the property.

Once an office receives written instructions from FBIHQ (Release Authorization Memorandum), the PC should coordinate the appropriate release action. When property is released to another agency by transfer or donation, the individuals both releasing and receiving the property must sign and date the Release Memorandum This document must be returned within 30 days to FBIHQ and will serve as the documentation to remove the property from office accountability.

Surplus property may be abandoned or destroyed only after every effort has been made to dispose of it through other authorized means. Prior to authorizing the abandonment or destruction of FBI property PMU must be notified in writing that the property has no commercial value; that its attendant cost of care and handling is greater than its probable sale price; or that because of its nature the property constitutes a danger to the public health, safety, or welfare. If the office is authorized to destroy property that meets the aforementioned criteria, Form FD-5l9, Requirements and Certification for Cannibalization and Destruction of Equipment, must be completed and forwarded to the PMU for appropriate action within 30 days. Form FD-5l9 will serve as the document to remove the property from the office inventory.


Property may be exchanged/sold by the FBI in accordance with the Federal Property Management Regulations. When requiring replacement property, similar items may be exchanged or traded-in and the proceeds from this exchange applied as partial payment for the replacement property. Restrictions and limitations to trading in property require PMU assistance.


When property has been determined lost, stolen, or unaccounted for, the PC must complete Form FD-500, Report of Lost/Stolen Property. The PC must determine the circumstances and facts surrounding an incident which adversely affects accountable property. These facts must be reported on Form FD-500 and all appropriate questions answered. The APO must review the circumstances and advise of recommended action concerning the accountability and utilization of the property involved. Form FD-500 must be immediately forwarded to PMU for examination and verification of evidence presented and property record information.


Conducting physical inventories of FBI property is the act of comparing the actual property on hand, as verified by physical count, with the records maintained within PMA. The FBI is required to conduct a biannual physical inventory of all accountable non-expendable property.

In addition, the FBI performs physical inventories to ensure that its property records are accurate; its internal control procedures are being maintained; and to test the overall status of the automated PMA.


Strict adherence to policy regarding accountable property management within the FBI is every employee's responsibility. While division and field office APOs are ultimately accountable for proper and effective property management, every FBI employee who acquires, holds, is assigned, transfers, disposes of or otherwise handles FBI property is responsible for that property. Account for it and safeguard it as you would your own possessions.


Set Lead 1:


Receiving APOs are requested to bring the contents of this communication to the attention of all employees to ensure strict compliance with FBI policy and procedure regarding accountable property management.