Washington State Auditor 
Troy Kelley 
November 26, 2013 

Port of Seattle Audit Committee member, 
We are pleased to present the recommendations made as a result of our 2012 accountability audit.
Each of the items discussed in the attached document is being reported as an exit item. We consider
these opportunities to improve the internal control environment at the Port but do not represent
significant or material concerns. These items will not be included or referenced in our audit report.
We have discussed each of the items with Executive management and want to share them with you
also. We are not planning on discussing these as our exit conference scheduled for December 3, 2012;
however, if you have any questions or concerns we would be happy to address them.
It was a pleasure working with Port staff and we look forward to meeting with you. 

Matthew Rose 
Washington State Auditor's Office 
Assistant Audit Manager
Enclosure 








1 
Insurance Building, P.O. Box 40021  Olympia, Washington 98504-0021  (360) 902-0370  TDD Relay (800) 833-6388

PORT OF SEATTLE 
2012 ACCOUNTABILTY AUDIT 
EXIT ITEM COMMENTS 
Police department 
Citations 
RCW 46.64.10 requires every record of traffic citations be audited monthly by the appropriate
fiscal officer of the government agency to which the traffic enforcement agency is responsible.
The Port of Seattle Police Department currently only performs an audit once a year and periodic
undocumented spot checks. 
We recommend the Department perform a monthly audit as required by state law. 
Citation Revenue 
Processing and collection of citations is performed by King County District Court. Local revenue
collected from these citations is retained by the County and the Port does not incur any costs for
processing of citations. There is no formal agreement between the two entities. 
We recommend the Department formally document the rationale behind this arrangement. 
Disposition of Unclaimed and Forfeited Property 
The Port of Seattle Police Department currently contracts with internet vendor to sell unclaimed
and forfeited property. RCW 63.32.20 requires the Port to advertise the sale of unclaimed
property in a local newspaper at least ten days prior to sale. We determined the Department
does not consistently advertise with a local newspaper. 
We recommend the Department advertise in the local newspaper and maintain record of proof
as required by state law. 
The Police department receives payments and an explanation of items sold from the internet
vendor. The department forwards the payment and a prepared deposit slip to the Accounting
Department, who deposits the check. Currently neither department performs a reconciliation of
funds received to funds deposited. 
We recommended the Port develop and follow policies and procedures to reconcile funds to
supporting documentation to ensure completeness. 
Use of Seizure Funds 
RCW 69.50.505 requires net proceeds not required to be paid to the state treasurer be used
exclusively for the expansion and improvement of controlled substance related law enforcement
activity. We determined the expenditures for the travel to the Reserve Sailor of the Year Event
do not appear to meet this requirement. 
We recommend the Department develop and follow policies and procedures to ensure use of
seizure and forfeiture net proceeds comply with state law. 
2

Third party cash receipting/processing 
Payment Card Industry (PCI) Compliance 
Per our communication with Selena Tonti, Information Security Senior Manager on 10/7/2013
the Port is not PCI compliant. The airport's parking garage is noncompliant due to
documentation of processes and monitoring. All other credit card locations and e-payments are
noncompliant due to the storage of some customers' credit card data on Port servers. The Port
has been working with a contractor to perform a gap analysis. 
We recommend the Port develop and follow policies and procedures to ensure PCI compliance. 
Service Organization Control (SOC) Report 
Per our discussions with Lisa Lam, Manager Financial Reporting & Controls and Revenue
Services/Taxes on 10/2/2013 and Selena Tonti, Information Security Senior Manager on
10/7/2013 the Port has not acquired the SOC reports for their third-party cash receipting
vendors, where applicable. 
We recommend the Port develop and follow policies and procedures to obtain and review SOC
reports for third-party cash receipting vendors to improve monitoring controls. 
State grants 
Annual Report Preparation 
We found the Port's State Schedule 16 did not include pass-thru activity for the Terminal 117
grant resulting in an understatement of approximately $298,000, or 19 percent of the
Department of Ecology grant.
We recommend the Port develop and follow policies and procedures to include all state grant
activity on the Schedule 16 to ensure completeness. 
Industrial Development Corporation 
Disbursements 
The Corporation does not have statutory authority to make payments for economic
development. Based on our review, the payments made during the audit period for the China
Trade Mission and Washington State Tourism Promotion programs appear to be for economic
development. 
RCW 39.84.130 allows a transfer of surplus funds from the Corporation to the creating entity for
growth management, planning, or other economic development purposes. We determined these
funds should have been transferred from the Corporation to the Port with expense made by the
Port.
We recommend the Corporation develop and follow policies and procedures that payments are
only made for allowable purposes or transferred to the Port to ensure compliance with state law. 



3