Follow-up Audit Of The Drug Enforcement Administration's .
FOLLOW-UP AUDIT OF THEDRUG ENFORCEMENTADMINISTRATION’S HANDLINGOF CASH SEIZURESU.S. Department of JusticeOffice of the Inspector GeneralAudit DivisionAudit Report 09-37September 2009
FOLLOW-UP AUDIT OF THE DRUG ENFORCEMENTADMINISTRATION’SHANDLING OF CASH SEIZURESEXECUTIVE SUMMARYTo ensure that criminal organizations and individuals do not benefitfrom their illegal acts, federal law provides that profits from drug-relatedcrimes, including cash, are subject to forfeiture to the government. Inaddition to the Drug Enforcement Administration (DEA), state and local lawenforcement agencies also seize cash during their drug enforcementoperations. These state and local agencies may transfer seized cash to theDEA for processing through the Department’s Asset Forfeiture Program(AFP).In January 2007, the Office of the Inspector General (OIG) completedan audit of the DEA’s controls over cash seized directly by the DEA and cashtransferred to the DEA through the AFP. Our audit found that while the DEAhad established policies for safeguarding seized cash, it needed tostrengthen some of those controls. For example, we concluded that the DEAneeded to: (1) better define when the seizing agents or officers shouldcount seized cash, (2) define a timeframe for taking seized cash to a bank tominimize the time the DEA holds seized cash, and (3) speed the transfer ofseized cash to the United States Marshals Service (USMS) by mandating theuse of wire transfers where possible.In November 2008, we initiated this follow-up audit of the DEA’shandling of seized cash.OIG Audit ApproachThe purpose of our follow-up audit was to determine what actions theDEA took in response to our 2007 audit and whether those actions improvedthe DEA’s handling of seized cash. During the period August 1, 2007,through November 24, 2008, the DEA processed almost 522 million inseized cash.
At DEA headquarters we interviewed various DEA officials andreviewed documents showing the actions the DEA took in response to ourprior audit. We also examined internal inspection reports regarding DEAfield offices’ management of the DEA’s cash-seizure program and DEA Officeof Professional Responsibility (OPR) case files related to the loss or theft ofseized cash.To assess whether the DEA’s actions in response to the 2007 auditimproved the DEA’s handling of seized cash, we reviewed the files of aselected statistical sample of cash seizures processed by 29 DEA officesassociated with 7 DEA divisions to determine whether the DEA followedestablished policies for seized cash. The details of our testing methodologiesare presented in our Objectives, Scope, and Methodology contained inAppendix 1. The statistical sample design is presented in Appendix 2.Results in BriefOur 2007 audit found the DEA needed both to strengthen its internalcontrol policies and to improve its documentation when it followed internalcontrol policies already in place. In response to our 2007 audit, the DEAmade various improvements, including: (1) implementing a policy thatseized cash should not be counted by the seizing agent or officer,(2) requiring DEA offices to transport seized cash to a bank or other financialinstitution within 5 working days from when the DEA acquired the cash,(3) reminding staff they needed to follow and document that they hadfollowed the internal controls for safeguarding seized cash, (4) ensuring thatevidence custodians are properly trained to handle seized funds, and(5) updating its inspection procedures to test whether agents followedestablished controls for seized funds.In this audit, our test of 682 seizures at 29 DEA offices found that theDEA had improved its overall performance and had increased its rate ofcompliance with 8 of 10 internal controls. Specifically, we found that DEAagents more consistently documented the presence of a witness throughoutthe cash seizure and handling process, more consistently completed therequired cash-handling forms and logs, and improved its timing intransferring custody of seized cash to the USMS.As explained more fully below, the DEA eliminated the controlrequiring agents to count seized cash at the time of seizure and insteadimplemented a policy in April 2007 that its agents must arrange to havebank staff conduct an official count within 5 working days from when theDEA acquired the currency. During the 2009 audit, we found that the DEAtook slightly longer to transport cash to banks for an official count because itii
experienced problems in implementing a Department of Treasury (Treasury)program designed to streamline cash deposits by federal agencies.Our 2009 audit also found the DEA did not have a policy stating howquickly supervisors should review the cash-seizure documents afterpreparation by agents. Supervisors need to do a better job of timelyreviewing the cash-seizure documents for completeness and accuracy. TheDEA did not identify and correct deficiencies in many cash-seizuredocuments until we began our 2009 audit. For the 682 cash seizures wetested, DEA staff prepared 131 amended Reports of Investigation and othermemoranda an average of more than 276 days after the date of the seizure.DEA officials told us they prepared these documents to “better explain thehandling and processing of the seized cash.” Moreover, DEA officials told usthe information in these amended documents came from other cash-seizuredocuments, agents’ memory, and discussions during group meetings aboutthe seizure.The DEA’s Actions in Response to our 2007 AuditOur 2007 audit recommended the DEA: (1) clarify its policy oncounting seized cash and clearly define the circumstances under whichagents are and are not required to count cash at the time of seizure;(2) research best practices associated with the timely transport of seizedcash to banks for an official count and implement those practices as widelyas possible; (3) ensure seized cash is wire-transferred to the USMSwhenever possible; (4) issue to all staff involved in cash seizure activitiesperiodic reminders of the internal controls to be followed and documented;(5) monitor the cash-seizure documents to ensure they are sufficientlydetailed to show cash-handling controls are followed and the requireddocuments are maintained in the case files; (6) identify all evidencecustodians who have not attended the DEA’s comprehensive classroomtraining on cash-handling controls and ensure these custodians receive theappropriate training; and (7) revise DEA Office of Inspection procedures tomeasure compliance with the DEA’s policy regarding counting seized cashand transporting seized cash to a bank in a timely manner.Regarding our recommendation in our 2007 audit that the DEA shouldclarify its policy on counting seized cash, we asked DEA officials during thecurrent audit about the problems associated with counting seized cash. Asenior DEA official told us that counting large volumes of seized cashconsumes agent resources and can result in miscounts due to human errorand counterfeit bills among the seized cash. Any differences between theagents’ count and an official count by bank personnel can result inaccusations by the persons from whom the currency was seized and subjectiii
the agents to a DEA OPR investigation. Differences between the agents’count and the bank’s count can also create legal problems for the DEA inprosecuting cases. Further, most banks have currency-counting machines,which can quickly count large sums of cash, are sophisticated enough todetect high-quality counterfeit currency, and have staff who are trained tooperate that equipment.Thus, in response to our recommendation that it clarify its policy, theDEA implemented a policy in April 2007 that its agents should not countseized cash at the time of seizure. The new policy reiterated that seizedcash is to be immediately sealed in evidence bags and transported by twolaw enforcement officers to the bank for an official count or to the DEA officewhere it is to be secured. The DEA made an exception to the policy allowingcash to be counted at the time of seizure when another law enforcementagency involved in the seizure requires that a count be conducted. Weagreed with the DEA’s assessment of the problems associated with countingseized cash and closed this recommendation based on the DEA’s policy.Later in this report we discuss the results of our testing during this follow-upaudit to determine whether agents followed the DEA’s new policy that cashshould not be counted at the time of seizure.The DEA also implemented five other recommendations from our2007 audit. However, it did not completely implement our recommendationthat it wire-transfer seized cash to the USMS whenever possible. In2006, at the request of the USMS, the DEA entered into a Treasury programintended to simplify the process that federal agencies use for making cashdeposits. The Treasury contracted with a major U.S. bank (the Bank) toprocess government cash seizures and the Bank subcontracted with anarmored car company to count DEA cash seizures and deposit the funds intoa bank account controlled by the USMS. The DEA tested the Treasuryprogram at its New York Division Office and then began implementing theprogram at other DEA offices. However, during the “rollout,” the DEAexperienced the following problems with the armored car company, theBank, and the Treasury: 166 of 268 DEA offices were 30 to 367 miles from the nearest armoredcar facility, 11A DEA official believed that DEA offices should not be more than 30 miles from anarmored car facility due to time constraints and increased risk of loss or theft of seizedcash. Of 268 DEA offices, 72 are more than 100 miles from an armored car companyfacility.iv
DEA offices reported that the armored car company frequently mademistakes when the company prepared bank deposit slips, the armored car company’s money counting machines were slow anddid not always detect counterfeit currency, and all DEA offices that used the Treasury system had difficulty makingarrangements with the armored car company to count and depositseized cash.A DEA official told us that because of the ongoing problems with theTreasury program, the DEA had not made a substantial effort to expand theprogram to other DEA offices. The DEA said it made several attempts tocorrect problems with the Treasury program, but because the Treasury andthe Bank were not responsive to the DEA’s concerns, the DEA proposed adirect-deposit program under Department of Justice control. To that end,some DEA offices currently using the Treasury system of cash deposits haveidentified banks they would prefer to use because they believe those bankscan better service currency deposits.We will continue to follow up with the DEA until it has implementedcurrency deposit services, including the transferring of seized funds by wireto the USMS whenever possible. To implement this recommendation, theDEA can make arrangements with banks or other financial institutions thatcan timely count and transfer custody of seized funds to the USMS.Current and Prior Audit Test ResultsIn this section, we discuss our current audit test results regarding theDEA’s handling of cash seizures and how these results compare with our2007 audit results. The DEA Agents Manual requires agents to fullydocument the details of cash seizures, including the chain of custody ofseized cash in a DEA-6 Report of Investigation within 10 working days of theDEA’s acquisition of the currency. If agents discover a mistake in a DEA-6,the responsible agent has 5 working days to prepare an amended DEA-6.Agents must also document in the cash-seizure files why two agents werenot involved when transporting the seized cash or why agents did not adhereto the 5-working-day rule for transporting seized cash to a bank or otherfinancial institution for an official count.At the start of our 2009 audit, DEA officials told us they had reviewedthe investigative case files in anticipation of our audit and preparedadditional documentation to better explain the processing and handling ofthe seized cash. The DEA had no policy stating how quickly supervisorsv
were required to review the case file documentation for completeness andaccuracy after its preparation by agents. Because of the timing of thechanges to the cash-seizure files and because the changes were done inanticipation of our audit, we had concerns about the reliability of theadditional documents. We reviewed the amended DEA-6s and memoranda,which did not appear to be back-dated, to determine when and why thesedocuments were prepared.For 148 seizures we tested, the DEA prepared 118 amended DEA-6sand 44 memoranda that added or revised information related to the seizure,including the chain of custody of seized cash. 2 Exhibit 1 shows our analysisof when the DEA prepared the amended DEA-6s and memoranda. 3 Thedetails of the amended DEA-6s and other memoranda are presented inAppendices 14 and 15.2Some seizures we tested had more than one amended DEA-6 or memo thatchanged details related to the seizure.3We could not determine whether the DEA prepared the amended DEA-6s within5 working days from when agents discovered an error in a DEA-6 because we did not seethose dates documented in the cash-seizure files.vi
Exhibit 1: Analysis of Changes to theCash-Seizure DocumentationNumber ofDocumentsPrepared Beforethe AuditNumber ofDocumentsPrepared Duringthe AuditTotalAmendedDEA-6s andMemoranda2322531 to 90 daysafter seizure358more than 90days afterseizure512412931131162When Prepared0 to 30 daysafter seizureTotalSource: OIG analysis of DEA documentsExhibit 1 shows that 131 (81 percent) of the 162 changes to the cashseizure files were made during our audit. DEA staff prepared the additionaldocumentation an average of more than 276 days after the date of theseizure based on agents’ memories and other cash-seizure documents. 4DEA officials told us the source of the information for the amended reportscame from group discussions, other cash-seizure documents, and agents’memory. One official told us he instructed his agents to document the chainof custody of seized cash as best they could from memory. Because of thelength of time it took the DEA to identify and correct deficiencies in the cashseizure documentation and uncertainty about the source of the informationused to make those corrections, we are concerned about the reliability of theadditional documents. Nonetheless, we included the amended DEA-6s andmemoranda in our audit testing. However, we report our 2009 audit testresults with and without the amended DEA-6s and memoranda preparedduring our audit.During our 2007 and 2009 audits we tested 10 controls related to thehandling and processing of seized cash. Below we discuss each control andwhether the DEA improved at following, or documenting that it followed,these controls.4The additional documents consisted of memoranda which were prepared anaverage of 276.6 days after the seizure and amended DEA-6s which were prepared anaverage of 293.5 days after the seizure.vii
Control 1: Presence of a Witnessing Agent or Officer when Cash wasDiscoveredThe first control we tested was the presence of a witnessing agentwhen cash is discovered. According to DEA policy, when cash is discovered,a witnessing law enforcement officer should immediately be summoned towitness the handling of the cash.Exhibit 2: Presence of a Witnessing Agent or Officer5when Cash was Discovered2007 AuditAllDEA OfficesTested69%2009 AuditYes12%93%Could Not Determine19%3%4%NoSource: OIG analysis of DEA recordsExhibit 2 shows the DEA increased its rate of compliance with thiscontrol from 69 percent in the 2007 audit to 93 percent in the 2009 audit. 6Overall, the DEA has shown significant improvement at following ordocumenting that it followed this control.Control 2: Counting Seized CashDuring our 2007 audit, the DEA’s policy was that agents should countseized cash when it was practical to do so. In April 2007, the DEA issued anew policy which stated that agents should not count seized cash. Instead,seized cash is to be immediately sealed in an evidence bag and transportedby two law enforcement officers to a bank or other financial institution for anofficial count. If the bank is unable to immediately count the seized cash, itshould be transported to the DEA office where the currency is to be secured.5“Yes” means documentation showed that a witnessing agent or officer wasinvolved. “No” means documentation showed that only one agent or officer was involved.“Could not determine” means the documentation did not provide sufficient information toconfirm whether a witnessing agent or officer was involved. Based on our statistically validprojected point estimates, the percentages reported in this analysis of the sampled itemsare within plus or minus 1 percent of what they would have been if the entire populationhad been tested. The percentages reported are within 95 percent of the confidenceintervals of the projected point estimates. The detailed results for each office and divisiontested are presented in Appendix 4.6Based on the 2009 amended cash-seizure documents, the DEA complied with thiscontrol in 96 percent of the seizures we tested.viii
However, seized cash must be transported to a bank or other financialinstitution within 5 working days from when the DEA acquired the cash.Exhibit 3 shows that during our 2007 audit, DEA agents counted seized cashin 16 percent of the seizures tested.Exhibit 3: Counting Seized Cash 7AllDEA OfficesTested2007 Audit16%15%69%1%2009 Audit5%Yes94%Could Not DetermineNoSource: OIG analysis of DEA recordsDuring the 2009 audit, we found that agents counted seized cash in5 percent of the seizures we tested when the DEA’s policy was to not countseized cash. 8Control 3: Agents Provided a Receipt of Warrant to the Owner of the SeizedCashThe DEA Agents Manual also requires agents to provide a receipt orcopy of a seizure warrant when seizing cash. Exhibit 4 shows that the DEAincreased its rate of compliance with this control from 52 percent during the2007 audit to 65 percent during the 2009 audit. 9 Overall, the DEA improvedat following or documenting that it followed this control.7For the test of whether agents counted the seized cash, “Yes” meansdocumentation showed that agents counted the seized cash. “No” means documentationshowed that agents did not count the seized cash. “Could not determine” means thedocumentation did not provide sufficient information to confirm whether the agents countedthe seized cash. Based on our statistically valid projected point estimates, the percentagesreported in this analysis of the sampled items are within plus or minus 1 percent of whatthey would have been if the entire population had been tested. The percentages reportedare within 95 percent of the confidence intervals of the projected point estimates. Thedetailed results for each office and division tested are shown in Appendix 5.8Based on the 2009 amended cash-seizure documents, agents also counted seizedcash in 5 percent of the seizures we tested.9Based on the 2009 amended cash-seizure documents, agents also provided areceipt or copy of a seizure warrant in 65 percent of the seizures we tested.ix
Exhibit 4: Agents Provided a Receipt or Warrantto the Owner of the Seized Cash 102007 AuditAllDEA OfficesTested52%47%1%2009 AuditYes65%Could Not Determine35%NoSource: OIG analysis of DEA recordsControls 4 through 6: Presence of a Witnessing Agent or Officer at VariousStages of the Cash-Handling ProcessA witnessing agent or officer should be present when seized cash issealed in an evidence envelope and when the cash is transported to a bankor other financial institution for an official count or to the local DEA office forsafekeeping. Exhibit 5 shows the DEA improved at following or documentingthat it followed these internal controls. 1110For the test of whether agents provided a receipt to the owner of the seized cash,“Yes” means documentation showed that agents provided a receipt or warrant. “No” meansdocumentation showed that agents did not provide a receipt or warrant. “Could notDetermine” means the documentation did not provide sufficient information to confirmwhether the agents provided a receipt or warrant. Based on our statistically valid projectedpoint estimates, the percentages reported in this analysis of the sampled items are withinplus or minus 1.5 percent of what they would have been if the entire population had beentested. The percentages reported are within 95 percent of the confidence intervals of theprojected point estimates. The detailed results for each office and division tested are shownin Appendix 6.11Based on the 2009 amended cash-seizure documents, the DEA’s rate ofcompliance with controls requiring a witnessing agent or officer be present at these phasesof the cash-seizure process ranged from 49 percent having a witness present during sealingto 87 percent having a witness present during transport to a bank.x
Exhibit 5: Presence of a Witnessing Agent or Officerat Various Stages of the Cash-Handling Process 122007 auditWitness PresentDuring Sealing 2009 audit3%54%43%Witness Present 2007 auditDuring Transport2009 auditto the BankWitness Present 2007 auditDuring Transport2009 auditto the DEA4%75%21%11% 8%81%21%49%30%60%Yes11%26%63%Could Not Determine24%16%NoSource: OIG analysis of DEA recordsControl 7: Recording Seized Cash in the HVSRM LedgerThe DEA Agents Manual requires that all seized items valued at 1,000or more be recorded in a High-Value Seized and Recovered Monies (HVSRM)ledger. Exhibit 6 shows the DEA improved at following or documenting thatit followed this control. 1312“Yes” means documentation showed that a witnessing agent or officer wasinvolved. “No” means documentation showed that only one agent or officer was involved.“Could not determine” means the documentation did not provide sufficient information toconfirm whether a witnessing agent or officer was involved. Based on our statistically validprojected point estimates, the percentages reported in this analysis of the sampled itemsranged from plus or minus: (1) 2.5 percentage points of what they would have been if theentire population had been tested for the presence of a witness during the sealing of thecurrency, (2) 2 percentage points of what they would have been if the entire population hadbeen tested for the presence of a witness present during the transport of the currency tothe bank, and (3) 1 percentage point of what they would have been if the entire populationhad been tested for the presence of a witness during the transport of the currency to theDEA. The percentages reported are within 95 percent of the confidence intervals of theprojected point estimates.13Based on the 2009 amended cash-seizure documents, the DEA’s rate ofcompliance with the control requiring that seized items valued at 1,000 or more berecorded in a HVSRM ledger was also 77 percent.xi
Exhibit 6: Recording Seized Cash in the HVSRM Ledger 142007 AuditAllDEA OfficesTested19%81%2009 Audit77%Yes23%NoSource: OIG analysis of DEA recordsControl 8: Average Number of Working Days from Seizure to Transport ofCash to the BankDuring the 2007 audit, the Agents Manual required agents to transferseized cash to a bank for an official count as soon as arrangements could bemade with the bank. During that audit, agents transported seized cash tobanks in an average of 3.2 working days. Beginning in May 2008, agentswere required to transport seized cash to a bank or other financial institutionwithin 5 working days. Exhibit 7 shows that during our 2009 audit, theaverage time from seizure to transporting seized cash to the bank had risenslightly to 3.3 working days. This increase in time required to transportseized cash to a bank or other financial institution could be based in part ondifficulties the DEA encountered with the Treasury deposit program asexplained in more detail above.14“Yes” means documentation showed that the cash seizure tested was recorded onthe HVSRM ledger. “No” means documentation showed that the cash seizure tested was notrecorded on the HVSRM ledger. Based on our statistically valid projected point estimates,the percentages reported in this analysis of the sampled items are within plus or minus1 percent of what they would have been if the entire population had been tested. Thepercentages reported are within 95 percent of the confidence intervals of the projected pointestimates. The detailed results for each office and division we tested are shown inAppendix 10.xii
Exhibit 7: Average Number of Working Days from Seizureto Transport of Cash to the Bank (by division) 152009 AuditSan Diego DivisionHouston Division1.9Average Timefor the Division2.4Atlanta Division3.2Average for 7 Divisions3.3New England Division3.6Chicago Division3.6Average Timefor all 7Divisions4.5Washington Division4.8Miami DivisionSource: OIG analysis of DEA recordsControl 9: Average Number of Working Days from Seizure to Transfer ofCash to the USMSSeized property must be transferred to the custody of the USMS within15 working days of seizure. During our 2007 audit the DEA transferredseized cash to the USMS within an average of 10.6 working days. Exhibit 8shows that during the 2009 audit the DEA transferred custody of seized cashto the USMS in an average of 10.0 working days from when the DEAacquired the currency. The DEA did not materially improve its timelinesssince the 2007 audit because only 13 of the 29 offices we tested during the2009 audit were using the Treasury system of cash deposits. Those13 offices transferred custody of seized cash to the USMS within an averageof 5.4 working days after the seizure. The 16 offices that did not use theTreasury system took an average of 13.7 working days. We believe that hadall offices been using the Treasury system, the DEA would have madesignificant improvement in the timeliness of transferring custody of seizedcash to the USMS.15In this exhibit and the exhibit that follows, we did not present our 2007 audit testresults because we did not test the same seven divisions in that audit. Detailed test resultsare shown in Appendix 11 and Appendix 12.xiii
Exhibit 8: Average Number of Working Days fromSeizure to Transfer of Cash to the USMS2009 AuditSan Diego DivisionHouston Division2.15.8Miami DivisionAtlanta DivisionAverage for 7 DivisionsChicago Division6.28.710.010.6Washington Division11.9New England Division13.0Average Time for the DivisionAverage Time for all 7 DivisionsSource: OIG analysis of DEA recordsControl 10: Transfer of Cash to the Evidence Custodian Using the ProperChain of Custody FormAccording to the DEA Agents Manual, DEA employees are required todocument the transfer of any high-value item between agents and evidencecustodians using various DEA forms. Exhibit 9 shows the DEA increased itsrate of compliance with this control from 26 percent in the 2007 audit to69 percent in the 2009 audit. 1616Based on the 2009 amended cash-seizure documents, the DEA’s rate ofcompliance with the control requiring DEA employees to document the transfer of any highvalue item using the proper form was also 69 percent.xiv
Exhibit 9: Transfer of Cash to the Evidence CustodianUsing the Proper Chain of Custody Form 172007 AuditAllDEA OfficesTested26%74%2009 Audit69%Yes31%NoSource: OIG analysis of DEA recordsOverall, the DEA has shown significant improvement at following ordocumenting that it followed this control.We also examined whether the DEA’s training program covered theproblem areas we identified in our 2007 audit, whether agents and evidencecustodians were familiar with newly revised policies and had attended theDEA’s mandatory training program. We found that the updated trainingappeared to cover the problem areas identified during the 2007 audit andmost agents and evidence custodians were familiar with the new policies. Inthis audit we found that 56 percent of the evidence custodians weinterviewed had attended the DEA’s mandatory training program. Duringour 2007 audit, only 22 percent of the evidence custodians had attended thetraining.Conclusion and RecommendationsOur 2007 audit found that the DEA needed to strengthen someinternal controls over seized cash and remind staff to follow or documentthat they had followed other controls. We made seven recommendationsthat, if implemented, could reduce the risk of loss or theft of seized cash.17“Yes” means documentation showed that the agents transferred the seized cashto the evidence custodian using a DEA-12 or other appropriate form. “No” meansdocumentation showed that the agents transferred the seized cash to the evidencecustodian without using a DEA-12 or other appropriate form. “Could not determine” meansthe documentation did not provide sufficient information to confirm whether agentstransferred the seized cash to the evidence custodian using a DEA-12 or other appropriateform. Based on our statistically valid projected point estimates, the percentages reported inthis analysis of the sampled items are within plus or minus 1 percent of what they wouldhave been if the entire population had been tested. The percentages reported are within95 percent of the confidence intervals of the projected point estimates. The detailed resultsfor each office and division we tested are shown in Appendix 13.xv
Our 2009 audit found that the DEA implemented all but one of our2007 audit recommendations. The DEA: (1) refined its policy for countingseized cash, (2) defined a timeframe for transporting seized cash to banks,(3) ensured that agents and evidence custodians involved in the cashseizure and handling process were properly trained, (4) reminded agents ofthe importance of having a witness present during all phases of the cashseizure process, (5) instructed supervisors to ensure cash seizure activitiesare fully documented, and (6) updated its Office of Inspections checklist totest compliance with controls for safeguardi
Current and Prior Audit Test Results In this section, we discuss our current audit test results regarding the DEA’s handling of cash seizures and how these results compare with our 2007 audit results. The DEA Agents Manual requires agents to fully document the details of cash seizures, including the chain of custody of
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