INTERNAL AUDIT REPORT
Operational Audit
Police Department Seizures and Evidence Room
Source: Port of Seattle
January 2022 – June 2023
Issue Date: November 30, 2023
Report No. 2023-14
This report is a matter of public record, and its distribution is not limited. Additionally, in accordance with
the Americans with Disabilities Act, this document is available in alternative formats on our website.
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TABLE OF CONTENTS
Executive Summary ...................................................................................................................................... 3
Background .................................................................................................................................................. 4
Audit Scope and Methodology .................................................................................................................... 6
Schedule of Findings and Recommendations ............................................................................................ 7
Appendix A: Risk Ratings .............................................................................................................................. 9
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Executive Summary
Internal Audit (IA) completed an audit of the Port of Seattle Police Department (POSPD) for the
period January 2022 through June 2023. The audit was performed to primarily determine whether
seized property and forfeitures were accounted for and processed in compliance with federal,
state, and local laws.
Established in 1972, the POSPD provides the primary law enforcement service to the Seattle-
Tacoma International Airport (SEA) and all of the Port of Seattle (Port’s) seaport properties. Per
the Port of Seattle Police 2022 Annual Report, the POSPD is comprised of 152 employees,
representing 106 commissioned personnel and 46 civilian personnel. The department, led by
Chief Michael Villa, is divided into two major bureaus: Operations and Services.
The Operations Bureau is the most visible representation of the department and is assigned to
fight crime, while also protecting and serving the local communities. These professionals patrol
the airport and seaport jurisdictions to ensure the safety of the traveling public, airline and seaport
workers, and Port employees. Units that make up the Operations Bureau include the Marine
Patrol Unit, Dive Team, Bomb Disposal Unit, K-9 Unit, and Traffic Support Specialists.
The Services Bureau is responsible for performing all the non-uniform functions of the
department. This includes criminal investigations, 911 Fire and Police communications, and
administrative duties like training, fleet and supply, and finance and budget. The Services Bureau
consists of the Criminal Investigations Division, Communications Division, and Administrative
Services Division.
In general, Port management’s internal controls aligned with policies and procedures. However,
our audit identified an opportunity where internal controls could be enhanced or developed. This
opportunity is listed below and discussed in more detail, beginning on page seven of this report.
1. (Low) – There is no formal process established relating to the disposal of items within the
Evidence Room. During our audit, we determined that the most recent disposal was performed
over two years ago, in 2021.
Glenn Fernandes, CPA
Director, Internal Audit
Responsible Management Team
Karen Goon, Deputy Executive Director
Michael Villa, Chief of Police
Sean Gillebo, Deputy Chief of Police
Mark Thomas, Deputy Chief of Police
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Background
The Port of Seattle Police Department (POSPD) provides primary law enforcement services to
the Seattle-Tacoma International Airport (SEA) and all of the Port of Seattle (Port’s) seaport
properties. Initially created in 1972, the POSPD now has 152 total employees as of December
31, 2022. These employees are comprised of 106 commissioned officers and 46 non-
commissioned/ civilian personnel. Commissioned officers provide professional law enforcement
services by protecting the rights of individuals, preventing crime, and building community
partnerships. These commissioned officers are the primary first responders for all reported crimes
and incidents within the Port’s jurisdiction. On the other hand, non-commissioned/ civilian
personnel primarily provide administrative and support services. These include communications
specialists, 911 dispatchers, traffic support, and administrative assistants.
Seizures and forfeitures of contraband, primarily currency, drugs and drug paraphernalia, and
weapons like guns, occur at SEA on a regular basis. When police officers seize these items from
passengers, there is a well-documented process that is followed in accordance with RCW
69.50.505. Before a seizure occurs, the officers, usually in pairs or groups of three, already have
a strong reasoning for approaching passengers. Once an individual is brought in for questioning,
the lead officer/ detective completes a seizure form that is served at the time of seizure. This
notice must be sent via certified mail within 15 days of the seizure to the relevant party, also
known as the claimant. Within 45 days, a hearing request must be received and has to commence
within 90 days. During this period, the officer/ detective gathers evidence to present at the hearing
and follows up on the case as ncessary. Depending on the particular circumstances of each case,
the POSPD may opt to settle with the claimant for a negotiated amount or the seized property can
be returned to the owner if there is no basis for forfeiture. However, if no request for hearing is
received from the claimant within the 45 days, this results in an automatic default.
All seized property and cash are stored in the Evidence Room, which is located roughly 2 miles
south of the airport. The Evidence Room is a fully secure facility, with an armed alarm system and
numerous keys to the different areas (i.e. gated area with high-value items, kitchen with
refrigerated human specimen to be sent to laboratories for testing, and safes containing guns)
within the space. Only three employees have their own set of keys and full access to the room.
Lastly, there is also a sign in and out system that is required for all visitors who need access to
the room, including POSPD employees and personnel.
For all property and cash seized, 10% of the net proceeds must be remitted to the Washington
Department of Revenue. Every quarter, a report is prepared and submitted by the Port’s Tax
Analyst to the Forfeiture Administrator of Washington State. Additionally, the amount due for the
year must be remitted to the state on or before January 31 of the following year. With regards to
the forfeited property, there are a variety of methods that the POSPD can employ depending on
the property type. They may choose to retain the item for official use, sell anything that is not
harmful to the public via auction, forward to the Drug Enforcement Adminstration (DEA) for
disposition, or take custody themselves and dispose as necessary.
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The table below reflects the total cash seized value, gross proceeds, net proceeds, and 10% of
net proceeds submitted to the state every quarter during our audit period:
Time
Period
Seizure Value /
Gross Proceeds
Net Sale /
Proceeds *
10% of Net
Proceeds
Q1 2022
$ 238,622.00
$ 231,622.00
$ 23,162.20
Q2 2022
$ 51,000.00
$ 51,000.00
$ 5,100.00
Q3 2022
$ 468,030.00
$ 463,030.00
$ 46,303.00
Q4 2022
$ 225,300.00
$ 225,240.00
$ 22,524.00
Q1 2023
$ 79,210.00
$ 79,210.00
$ 7,921.00
Q2 2023
$ 137,200.00
$ 137,200.00
$ 13,720.00
Total:
$1,199,362.00
$ 1,187,302.00
$ 118,730.20
* Net of fees
Source: Port of Seattle Police Department documents
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Audit Scope and Methodology
We conducted the engagement in accordance with Generally Accepted Government Auditing
Standards and the International Standards for the Professional Practice of Internal Auditing.
Those standards require that we plan and conduct an engagement to obtain sufficient, appropriate
evidence to provide a reasonable basis for our findings and conclusions based on our
engagement objectives. We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our engagement objectives.
In some cases, we used a judgmental method to determine the samples selected for our audit
test work. In those cases, the results of the work cannot be projected to the full population as we
did not select a statistical based random sample.
The period audited was January 2022 through June 2023 and included the following procedures:
Seizures and Forfeitures:
• Reviewed RCW 69.50.505 Seizure and forfeiture policy from the Washington State
Legislature website and how it is being implemented within the POSPD.
• Conducted inquiries and performed walkthroughs to gain an understanding of the chain of
custody process.
• Tested the accuracy and completeness of various reports, including the Forfeited Property
Status Reports and Quarterly Seizure Reports, being completed, and submitted to state
agencies, as required.
• Reviewed the POSPD Seizure Report for the audit period and randomly selected 3 items
to test for completeness and accuracy of information.
• Reviewed and tested federal (1) and state (10) payments made from forfeitures to test
whether they are deemed permissible and allowable based on the Department of Justice
Asset Forfeiture Program by obtaining a copy of the respective invoice with a brief
description and/or purpose. For a full list of permissible uses, refer to Section IV of the US
Department of Justice – Guide to Equitable Sharing.
Evidence Room:
• Conducted inquiries and performed walkthroughs with key employees to gain an overall
understanding of internal controls present.
• Obtained the listing of different user groups for the evidence management system
(EvidenceOnQ) used by the POSPD and reviewed user roles and access for employees,
verifying appropriateness and reasonableness.
• Obtained the 2022 Property and Evidence Audit report conducted internally by the POSPD
and reviewed the associated memo for procedures conducted and results, noting no
exceptions.
• Performed detailed testing to test the completeness, existence, and accuracy of the items
within the Evidence Room (Traced 20 items from the List Report to the Evidence Room
and 20 additional items from the Evidence Room to the List Report, noting no exceptions.)
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Schedule of Findings and Recommendations
There is no formal process established relating to the disposal of items within the Evidence
Room. During our audit, we determined that the most recent disposal was performed over
two years ago, in 2021.
When items are ready for disposal, they are stored in boxes marked for destruction in the
Evidence Room. On our walkthrough, IA noted that there is no specified and required timeline as
to the actual disposal of items. Certain areas within the space are primarily dedicated for items
ready for disposal but the POSPD only performs a clean out whenever possible, given their
staffing capacity. In compliance with EPA regulations, disposals cannot be done locally in Seattle.
As such, the POSPD fills up a U-Haul truck with items for destruction, primarily guns, drugs, and
contraband items, and drives to Spokane, WA for proper disposal.
As part of our audit, we obtained the full listing report of the Evidence Room. Out of 6,371 total
items per the report, 1,464, or 23% are pending destruction. The items are a combination of
general destruction (guns, drugs, and contraband) and unclaimed safekeeping items (suitcases,
backpacks, etc.). They are primarily located in various “Destruction Boxes” while some are in the
“Pending Auction” and/or “Pending Donation” bins.
We noted that the different items are all segregated into different areas and marked clearly.
However, as mentioned above, items that are pending destruction represent 23% of the full
population. Additionally, evidence such as guns, drugs, and contraband are inherently risky and
susceptible to loss. Therefore, the timely destruction reduces this risk and allows for easier
reconciliation. Overcrowding of a property and evidence room can lead to disorganization or
contamination of property.
Recommendations:
A formal policy should be adopted regarding the timely disposal of items within the Evidence
Room. This will ensure that the room remains as organized and tidy as possible. This will also
prevent any possible cases of mishandling and commingling of items inappropriately (i.e., mixing
of legitimate items being kept for legal purposes with items that have been approved for
destruction). Additionally, adopting a standardized policy will also free up space within the actual
room itself, to store more items as time goes on.
Having considered relevant factors such as staffing shortages, we recommend that the disposal
process be performed on an annual basis. The drive to the disposal facility in Spokane, WA can
be treacherous and greatly affected by weather conditions, accordingly, once a year during the
summertime would be ideal. We believe that this is an attainable and reasonable goal that can be
achieved by the POSPD. Establishing an annual disposal requirement will assure that the
Evidence Room continues to remain as clean and organized as possible.
1) Rating: Low
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Management Response/Action Plan:
Management has reviewed Audit Report No. 2023-14 and concur with the findings and
recommendations that evidence disposal should occur at least annually and that the requirement
should be contained in policy. We have created a department directive (05-2023) that puts into
policy a requirement to dispose of evidence at least annually. While there were reasons for the
more than 2 years since our last evidence disposal, the timely disposal of evidence is important
and deserving of the new annual requirement being adopted into our policy manual.
DUE DATE: 12/31/2023
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Appendix A: Risk Ratings
Findings identified during the audit are assigned a risk rating, as outlined in the table below. Only
one of the criteria needs to be met for a finding to be rated High, Medium, or Low. Findings rated
Low will be evaluated and may or may not be reflected in the final report.
Rating
Financial
Stewardship
Internal
Controls
Compliance Public
Commission/
Management
High Significant
Missing or not
followed
Non-compliance
with Laws, Port
Policies,
Contracts
High probability
for external audit
issues and / or
negative public
perception
Requires
immediate
attention
Medium Moderate
Partial controls
Not functioning
effectively
Partial
compliance with
Laws, Port
Policies
Contracts
Moderate
probability for
external audit
issues and / or
negative public
perception
Requires
attention
Low Minimal
Functioning as
intended but
could be
enhanced
Mostly complies
with Laws, Port
Policies,
Contracts
Low probability
for external audit
issues and/or
negative public
perception
Does not
require
immediate
attention
