Internal Control System

Authorization, Approval, and Accountability: Transactions are authorized by person(s) with delegated approval authority, with sufficient explanations and documentation to support post authorization review and audit. Unauthorized transactions are identified and central departments are informed if a loss of University assets or any material irregularity occurs.

Documentation of and adherence to policies, guidelines, and procedures, and the terms and conditions of gifts, grants, and contracts: University, department, and sponsor policies, procedures and restrictions are formalized and communicated to employees. Documentation and accessibility helps provide day-to-day guidance to staff and will promote continuity of activities in the event of prolonged employee absences or turnover. Adherence requires active promotion by management and empowerment of staff to escalate issues of non-compliance.

Physical Security: Cash, inventories, equipment, and other property are secured physically, counted periodically, and compared with control records; safeguards are provided for the loss or unauthorized use of University assets, including data.

Proper Management of Expenses: Expenses are monitored and controlled. Comparisons of actual expenses to budgeted amounts are performed on a regular basis, and all significant variances resolved.

Review and Reconciliation: Routine examination and reconciliation of transaction records to the University books of record is required to verify the accuracy of the records, the appropriateness of the transactions, and their compliance with policy.

Separation of Duties and Monitoring: Financial responsibilities are divided between different people to assure a single person does not perform every aspect of a financial transaction. Segregating responsibilities can reduce errors and prevent or detect inappropriate transactions. Based upon the level of separation of duties, management has the responsibility to monitor financial transactions and balances.

Training and Supervision: Employees receive appropriate training and guidance to ensure they have the knowledge necessary to carry out their job duties. Employees are provided with an appropriate level of direction and supervision and are aware of the proper channels for reporting suspected improprieties.

Internal Audit

Sound business conduct requires that each employee, as a basic condition of employment, assume responsibility for safeguarding and preserving the assets and resources of the University, particularly those for which he or she is responsible. In accordance with the University Professional Standards and Business Conduct Policy, each University employee is expected to report any instance of suspected ethical misconduct to the Director of Internal Audit. If presented with reasonable evidence of a suspected ethical misconduct, the Director of Internal Audit will conduct an audit to determine if the reported suspicions of fraud are valid.

Situations may arise when an individual discovers or reasonably suspects unethical or illegal behavior and yet may be reluctant to report it for fear of reprisal or retaliation. Accordingly, Boston College has selected EthicsPoint, a third-party vendor, to provide an anonymous Ethics Hotline.

EthicsPoint will facilitate confidential and anonymous reporting of concerns about any aspect of University compliance, through either a direct telephone call or an online intake process. 

Financial documents, internal communications shed new light on months before Enrichmond collapse

RICHMOND, Va. (WRIC) — More than 1,000 pages of newly obtained documents are providing insight on the final months of the Enrichmond Foundation before its collapse in June 2022.

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The financial records and internal communications from the local nonprofit were released through a Freedom of Information Act (FOIA) request by the Enrichmond Accountability Project, a volunteer group that was formed in the wake of the foundation’s dissolution, in an effort to track down an estimated $200,000 in missing donations. However, initial approximations may have underestimated the severity of the seemingly vanished funds.

“From the documents, it seems like anywhere from $250,000 to over $1 million was lost,” Mac Wood with the Enrichmond Accountability Project and Friends of Pump House told 8News. “It’s really unclear where that money was supposed to go, because their bookkeeping was pretty sloppy towards the end.”

Back in March, 8News reported that the sudden dissolution of the Enrichmond Foundation had left more than 80 partner organizations searching for answers and funding. Many groups were also unable to do the work they were formed to do because, once the 501(c)(3) folded, so did the partner groups’ status as nonprofit organizations.

Before it dissolved, the foundation served as a sort of umbrella organization for partner volunteer groups, including Friends of Pump House and Friends of Historic Fulton Memorial Park, assisting with financial management and marketing.

“Enrichmond took a 5% cut of every donation that each individual group received, and, in exchange for that, they were basically our bank,” Wood told 8News back in March. “Part of that agreement was that Enrichmond was not to co-mingle the funds between these organizations. So, if $20 goes to Fulton Memorial Park, that money is to stay in Memorial Park’s fund, and not to be used, say, to pay executive salaries or buy real state.”

Enrichmond’s own partner handbook noted that “funds donated to Partner groups through Enrichmond will not be deposited or commingled.” However, in reading through the hundreds of pages of documents that were handed over to Richmond’s Department of Parks & Recreation upon the foundation’s dissolution, Wood said it was clear that money was being mixed.

“The Attorney General’s Office had already gone through a small stack of sort of the most relevant information, and what was inside of it was was pretty upsetting,” Wood said Wednesday. “Pretty much all of the concerns that we had about the organization and their knowledge of the co-mingling of funds were confirmed within these documents, and I think it’s pretty indisputable to say that they knew that they were co-mingled co-mingling funds. They were aware that they were co-mingling funds and they were aware that they were spending all of the organization’s money down to the last dollar.”

Newly obtained documents showed tens — and in some cases, hundreds — of thousands of dollars being moved around through loans and payments, as well as negative net income amounts, in the months leading up to the June 2022 vote to dissolve.

In an email dated Jan. 2022, Enrichmond Foundation Board President J. David Young wrote to then-Executive Director John Sydnor on his “concerns regarding the current status & health of the Organization.” Young went on to request “a comprehensive inventory of all assets and the value of each,” “a comprehensive list of all banking accounts, including credit card, with balances and a list of who has cards and who approves the expenditures,” and “a listing of all partner agencies, the current account balances for each.”

Linda Egister Sutton with the Friends of Historic Fulton Memorial Park said that their organization had raised approximately $57,000 in donations at the time of the dissolution.

“We were about to order benches, trash receptacles, game tables, and we had extra money to start putting in the pylons to start telling our stories, and that’s when the news came: the money was gone,” she said. “We’re going to keep striving because where we from, we strong and this was a learning experience for us.”

The January email from Young also called on Sydnor “to begin preparing a ‘crisis plan'” for how Sydnor intended “to make the agency viable and able to continue operations.”

“As far as I know, there’s one remaining board member on Enrichmond, and that person is John Mitchell, Jr.,” Wood said. “I think, at this time, he’s not quite able to help. I’m not sure he has the legal ability right now to do so because, you know, the group dissolved. It ran out of money.”

Despite the hundreds of pages of internal documents obtained through FOIA request, questions still remain unanswered about exactly how much money was lost and how it went missing. But the financial reports showed some spending on salaries, operating costs and property.

8News previously reported that the Richmond Police Department (RPD) was looking into the dissolution, with Richmond City Commonwealth’s Attorney Colette McEachin confirming that her office was waiting on information from RPD “to see if charges were appropriate.” The Office of the Attorney General (OAG) and Federal Bureau of Investigation (FBI) have since begun investigating the foundation’s sudden collapse.

“How did Enrichmond get by doing all of this stuff for so long, and how do we move forward?” Wood said. “I really worry that these problems are endemic to the nonprofit industrial complex and that these groups don’t have as much oversight as they should.”

Wood added that the recently passed FY2024 budget for the City of Richmond included $250,000 “for future fundraising for all the groups that had lost money through Enrichmond.”

As for Egister Sutton, she said that, although compromises have had to be made, the project to build the Historic Fulton Memorial Park and commemorate the uprooted community have forged on, with a ribbon cutting set for Saturday morning.

“We all trusted you with our money, so we all were hurt by this,” she said. “This is all we can do now.”

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