U.S. Immigration and Customs Enforcement (ICE) is an agency within the Department of Homeland Security. They received an appropriation for FY2019 (all one-year funds) for $10,414,160,000 to perform their mission.The appropriation has two components, "$8,650,450,000 for operations and support to include Homeland Security Investigations, Enforcement and Removal Operations, and Mission Support." The remaining "$1,763,710,000 `for Procurement, Construction, and Improvements, of which $75,000,000 shall be used only for the procurement of tactical communication equipment."

On 15 September of 2019, all but $60,000,000 of the FY2019appropriation was obligated but they had not yet obligated any money for the tactical communication equipment. The Senator who inserted the requirement for the communication equipment contacts you, the Comptroller General, to determine whether ICE has committed an Antideficiency Act violation, or other violation of fiscal law. What do you tell her?