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In the FY 1982 budget, OECE is requesting two program analysts to meet this objective, and two accountant-advisors to be available to ECE units and CRM for expert assistance in sophisticated white-collar crime cases, and to supplement the audit capability of other program agencies.

Increased Contact with Agency Headquarters: In order to strengthen the

relationship of OECE with prosecutive, investigative and program agencies and

build effective communication links between Specialists and corresponding

agency field offices, OECE plans to increase its liaison with headquarters

personnel.

Regional Conferences: In accordance with the purpose of arranging training for investigative, program and prosecutive personnel, OECE plans to conduct

regional conferences in addition to the national ECE conferences. As the ECE

program develops, the national and regional conferences will focus on advanced investigative and litigative skills, thus necessitating that OECE commit

resources to undertake the development and formulation of these advanced

techniques.

DECE's current responsibilities will expand as the program reaches full imple

mentation, and new responsibilities will be assumed when the program, as a whole, becomes operational. It is expected, therefore, that OECE will become

increasingly involved in the aforementioned activities, while undertaking a

role in the procurement of additional resources for the prosecution of significant cases and the formal evaluation of program operations.

The above narrative describes OECE's organizational relationship with to the Department and the ECE units, and its responsibilities to the ECE program; it highlights achievements to date and provides a perspective for future activities. At the same time, the above discussion, together with the following chapter, raises some programmatic and organizational issues, which, in the

judgment of the study team, can affect the future development of the ECE

program. These issues are presented in Chapter IV.

CHAPTER III
OPERATIONAL FRAMEWORK FOR
THE ECONOMIC CRIME ENFORCEMENT UNITS

The ECE program encompasses both a national aspect, administered by OECE, and

a district aspect, directed by OUSA. This program design is predicated on the notion that CRM and the OUSAS, overall, have similar interests. The program is expected to realize national objectives, while recognizing the needs and

interests of the individual districts. The Specialist, a CRM employee operating

within a participating OUSA, is the critical link between these two aspects. He provides support for and reports to both organizations and, when necessary, balances their individual interests.

At the district level, program responsibilities to be administered by the Specialist and accomplished through the ECE unit, are designed to bring a new and unified emphasis to the prevention, detection, investigation and prosecution of white-collar crime. These responsibilities are:

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To compile and analyze information on the district's white-collar

crime problem to form part of a national information system, and
establish local priorities to focus investigative and prosecutive
resources on the district's major problems;

To align the interests and coordinate the efforts of a multitude of

organizations involved in detecting, investigating and prosecuting

white-collar crime;

To focus local attention on the magnitude of white-collar crime,

its costs, and the lack of adequate sanctions against white-collar

crime offenders;

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To conduct or organize conferences and seminars to present information,

exchange ideas, and encourage the various participants in the law
enforcement effort to cooperate with one another;

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To assist investigators and prosecutors in the development and preparation of significant white-collar crime cases by suggesting new investigative techniques and prosecutive approaches, and assisting, when

appropriate, in the preparation of briefs, motions and memoranda;

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To oversee case development, and coordinate investigative and prosecu

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To accomplish these tasks, the Specialist must serve as an information source,

advisor, coordinator, and prosecutor. Although he has primary responsibility

for ensuring the attainment of program goals and objectives, the Specialist is dependent upon the ECE unit to assist in his efforts, especially in the

prosecution of significant white-collar crime cases.

INTERNAL ORGANIZATION AND OPERATIONAL RELATIONSHIPS

In forming ECE units in the various OUSAs, CRM was to provide the Office

with an experienced attorney, to serve as the Specialist, while the Office was to establish a separate unit to specialize in white-collar crime. Organi

zational formation of the unit within the OUSA was left to the discretion of

the individual U.S. Attorneys. As a result, several different configurations

have been developed for the units' organization, the Specialist's relationship

to the unit, and the placement of each within the OUSA. (See Unit Profiles,

Appendix VI.)

Office Organization: These unit configurations are derived from the overall office structure (including the presence of pre-existing units), the nature and scope of the white-collar crime problem, the organization of the Federal judiciary, and the U.S. Attorney's perception of the program and the Specialist's role. The office and unit organization may be described as

structured or flexible, and the Specialist's relationship to the unit as

integral or adjunctive.

Generally, the study team found the larger the office, the higher the degree

of specialization among the AUSAs within the office, and therefore, the

more structured the organization of the OUSA.

In contrast, the smaller

offices, having fewer resources, usually remain more flexible in order to meet the demands of their responsibilities in numerous cases and matters. Their attorneys are, for the most part, generalists.

The Attorney General's Order establishing the units outlined a structure for

these units: three experienced AUSAs (unless otherwise agreed to by the Deputy Attorney General), assigned to the unit full-time for at least 18 months. The

intent of this directive was to provide continuity and specialization in the

prosecution of white-collar crime cases, and to ensure the availability of ade

quate prosecutive resources.

Although all the OUSAs visited had established

separate units, the larger offices were better able to meet these specifications in form, while the smaller offices had difficulty in attaining the structured unit format. In general, the latter offices were unable either to designate the minimum number of attorneys or to devote their resources

full-time to the ECE unit.

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