about program goals, eliciting their participation in achieving program objectives and laying the foundation for his involvement with investigators and AUSAS on major white-collar crime cases. This involvement may require

his consultation, direction or oversight of the progress of the case. He encourages the agents to develop significant cases with the participation of the OUSA at the beginning of the investigation.

Although several OUSAs have noted that they cannot force the agencies to develop significant cases, they can bring about positive change in the quality of cases by clearly communicating their policies to the agencies, and, if necessary, exercising their declination authority. When this latter method is used in conjunction with a detailed explanation of why the case is being declined, the agency can begin to develop a clearer understanding of what is required for OUSA acceptance. Thus, OUSA interest, the Specialist's mission and the agencies' desire to have their cases prosecuted, should provide local investigative personnel with an incentive to develop cases within the scope of district and national priorities. However, until the agencies' methods of measuring achievements reflect the new emphasis on quality over quantity in law enforcement, there will continue to be a major disincentive to the reorientation of investigations and, therefore, prosecutions in the area of white-collar crime.

The OUSA's early involvement in the investigative process is the key to better cases better prosecuted, and accrues to the benefit of both the agents assigned to an investigation and the unit AUSA designated to prosecute the completed

case. The agent is assured of having a contact, the Specialist or an AUSA, within OUSA. The contact's familiarity with the developing investigation allows him to answer questions efficiently and knowledgeably, and, when required, to suggest other possible methods of developing a solid case. This familiarity may be essential to the AUSA's later successful prosecution of the case and helps the AUSA to ensure that the case will be complete and prosecutable. Both gain the mutual confidence and respect for each other which develops through a close working relationship. For example, confidence and respect are displayed by the agents' desire, at most sites, to obtain the Specialist's opinion early in the investigation because they believe it allows them to develop stronger, more complex or sophisticated cases, which the OUSA would be willing and able to prosecute successfully. Equally as important as the individual benefits is the enhancement of the overall quality of cases prepared for prosecution because the joint effort combines the investigative and prosecutive expertise to develop a strategy for apprehending and prosecuting white-collar criminals.

By having the OUSA as a focal point for pending investigations, the probability of locating and coordinating duplicative investigations is greatly increased. Furthermore, consolidation of several smaller investigations can often result in a case more significant than the sum of its parts. Coordinating the various agency interests and talents requires a certain degree of diplomacy, understanding, patience and impartiality. In many instances, the agencies have expressed their willingness and the desirability of having the Specialist fulfill the mediator's role because of his unique location within the enforcement community.

In fact, the Specialist's ability to settle disputes and coordinate investigations was often cited by the agents interviewed as one of the Specialist's most important functions.

While assisting in the development of cases, the Specialist acquires an understanding of the various agencies' program operations. In reviewing case evidence, he can discover program practices which may make the prosecution, prevention or detection of white-collar crime more difficult.

He can then make recommendations to correct such problems, sometimes a relatively simple matter. For example, one Specialist noted that employees of a particular program were filling in application forms for the applicant. Since the applicant's handwriting was not on the form, it became more difficult to show his understanding of the application and thereby prove an intent to defraud. This was easily corrected by requiring the applicant to personally complete the forms.

Another aspect of this greater involvement of the OUSA with its clientagencies is the dissemination of general information through training, seminars and conferences. Generally, the Specialists preferred the informal methods of presenting information on specific subjects, i.e., seminars and conferences, indicating that formal training was more properly the responsibility of the agency. Depending on his knowledge of the subject matter, the Specialist may conduct the session himself or arrange for someone else to present it. Examples of seminar topics are investigative auditing, how to document a trail of evidence and the use and function of the investigative grand jury. These sessions have been attended by agents and AUSAs; generally, they have

met with a favorable response. Besides being a method of transferring knowledge, these seminars serve an important role in providing an opportunity for AUSAS and agents to become acquainted, leading to closer professional relationships and increased coordinative efforts.

State and Local Investigative and Prosecutive Agencies: As the program develops, expanding its scope to include the State and local levels, the Specialist may become involved in establishing a cooperative working relationship between all levels of government. Coordinated efforts here could give both the Federal and State governments access to additional investigative and prosecutive resources, better and more complete information, and more experience to utilize. A sharing of information could eliminate duplication, and establish connections or links in investigations.

In addition, it is expected that the Federal emphasis on white-collar crime will, in many instances, produce more cases than the OUSA will be able to prosecute effectively. In light of the national priorities, it will be necessary to develop an understanding with the State and local prosecutive agencies to have State and/or local attorneys further assist in the whitecollar crime enforcement effort by prosecuting many of the cases over which they have jurisdiction.

Advisory and Interest Groups, Business Organizations, and the General Public: As the program develops, the Specialist should begin to establish liaison with interest and advisory groups to help further the gathering and analysis of white-collar crime information. Included in this effort is the development

of information on methods of preventing and detecting these crimes and the dissemination of this information to possible victims, e.g., businesses and the general public. The program hopes not only to develop new sources for leads or information on these crimes, but also ultimately to limit their occurrence by increasing the public's knowledge of prevention measures. Moreover, public awareness of detection devices, and the authorities responsible for addressing these activities will improve law enforcement efforts. Additionally, raising the public's awareness of white-collar crime, its cost, and the minimal risks taken by the criminal for maximal rewards, may help to bring about increased pressure for stricter sanctions against offenders.

DEVELOPMENTAL STAGES OF ESTABLISHING AND IMPLEMENTING AN ECE UNIT Once the Specialist is acclimated to his new role, four general phases of implementation, each an accession to the previous one, are undertaken: (1) accumulating and analyzing white-collar crime data; (2) communicating with district organizations involved or interested in white-collar crime enforcement; (3) coordinating efforts in the prevention, detection, investigation and prosecution of white-collar crime; and (4) prosecuting significant white-collar crime cases.

Prior to implementing this program, however, several activities must take place: unit site-selection, Specialist selection, administrative preparation (prior to the Specialist's entry on duty), and orientation (subsequent to the Specialist's arrival in the OUSA).