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Audit Report OC-27-16, Institutional Trust of the Puerto Rico National Guard

August 18, 2026

Comptroller reveals multimillion-dollar non-compliance in operations of the Puerto Rico National Guard Trust

San Juan, Puerto Rico (August 18, 2026) — The Comptroller of Puerto Rico, CPA and Attorney Carmen Vega Fournier, reported today the results of an audit of the Institutional Trust of the Puerto Rico National Guard (FIGNA), covering the period from July 1, 2016 to December 31, 2022.

The report presents an adverse opinion, after identifying multiple significant deficiencies in purchasing, contracting, disbursement, property management, internal control, fund administration and compliance with legal obligations.

The audit showed that several administrative practices were not carried out as provided by Act 73-2019, Act 23-1991, Act No. 230 and other applicable rules.

The report details that FIGNA made purchases totaling $3.4 million without the involvement of the General Services Administration (GSA) and without using the bidding methods required by the applicable regulation. Likewise, it was identified that construction works and specialized services were acquired for $1.6 million without formal contracts, and that disbursements of $546,640 were made on projects that served no purpose, reflecting an inefficient use of public funds.

The audit highlighted deficiencies in documentation and incomplete files, including the absence of formal quotations, the lack of written requests and awards of goods or services without evidence of selecting the best bidder.

One of the observations relates to the recognition of a loss of $11.4 million in the financial statements from the acquisition of a parcel of land that was not used for its intended purposes.

The report also revealed that an unregulated fringe benefit was granted to one employee, without the approval of the Board of Directors and without extending that benefit to other employees on equal terms. In addition, donations granted to entities totaling $34,704 were identified that are unrelated to the purposes of Act 23-1991; as well as services provided by contractors without valid licenses, in violation of Act No. 36 and applicable regulations.

Other observations include advance payments without an invoice, disbursements without evidence of receipt of goods or services, the absence of check records and insufficient document filing. Also found were the use of credit cards without procedures approved by the Board of Directors, purchases without supporting documents, payments of taxes that should have been exempt and finance charges.

The audit also identified the concentration of incompatible functions in the Accounting Area, which affected the segregation of duties required by Act No. 230, and a lack of updated regulations for inventory processes, disposal of materials, advance payments and use of official vehicles. FIGNA also incurred the late filing of financial statements and annual reports that were not submitted, as provided by law.

In addition, the auditors noted the absence of a continuity plan for the military stores, which resulted in an interruption of revenue of $4 million and in the failure to make regulatory transfers of $2.2 million to the annuity and educational funds.

The report includes 35 recommendations addressed to various agencies, to the chief executive officer and president of the Board of Directors, and to the executive director of FIGNA.

"These recommendations seek to strengthen supervision, reinforce internal controls, improve administrative planning and ensure strict compliance with the applicable rules," said the Comptroller.

Audit Report OC-27-16 is available at www.ocpr.gov.pr.

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