Combining investigative resources brings together differing expertise and expands the scope of possible techniques that may be employed. It also provides an informal cross-training procedure, which results in the agents being able to recognize areas where another's skills or expertise would benefit an investigation.

The Specialist's role in these large complex cases is to provide guidance for the investigative efforts. He assists in the selection of the major path of the investigation and identifies "spin-off" cases to be further investigated by new teams or prosecuted by Unit AUSAS. In the main investigation, the Specialist also acts as a mediator between conflicting interests, when they arise, thus preserving the coordinative efforts. At the completion of the investigation, the Specialist should have a solid, well-planned case, against significant criminal offenders or activities ready for prosecution.

Prosecution of Significant White-Collar Cases: The prosecutorial work of the ECE unit involves a departure from the traditional, reactive approach to a more proactive approach, focusing on major/complex cases. Insofar as this shift requires a period of transition, during which the Specialist lays the

foundation for achieving the program's prosecutorial goals, the prosecution of major white-collar crime cases is generally viewed as a second year objec

tive. This is based on the expectation that in the first year, the unit will

establish: an effective working relationship with the appropriate agencies; a sound, reliable information system for district priorities; a policy for determining what is a major case; and will have available, experienced AUSAS

to prosecute those major white-collar crime cases.

When the program reaches this stage--and a case, developed with the investigative agencies through the Specialists efforts, it is ready for prosecution--the Specialist, because of his substantial involvement in the investigation, should, in most instances, participate in the litigation. This role could be that of the lead attorney, co-counsel, or an advisor/director. His participation should be premised on some notion of case significance, be it: the prominence or culpability of the offender, the complexity, uniqueness or cost of the criminal activity, the uniqueness of the prosecutive approach, or the necessity of maintaining the investigative agencies' confidence in

the program.

UNIT ACHIEVEMENTS

Each of the seven units surveyed demonstrated significant achievements of program objectives. In reporting these achievements, it was the position of the study team that, since the seven units were still in various stages of program implementation, it would be better to report accomplishments in an aggregate manner to avoid unit-by-unit comparisons that might not adequately account for the important differences of each unit, or represent the individual characteristics, needs and conditions of each unit from which program objectives were accomplished. Due to the flexible and adaptable nature of the program, the individuality of each OUSA, and the scope of the study, it is not possible to report these achievements in measurable terms of signifi

For example, the environment in one Federal district would make the

establishment of a cooperative working relationship with various Federal

agencies by the Specialist more significant than it would be in a district

where the practice was more traditional and commonplace.

Since the ECE program is a five point program designed to enhance the Department's ability to detect, prevent, investigate, prosecute and sentence the white-collar criminal, the program accomplishments are reported under each

of the five program areas to which they are most germane. As noted earlier

in the report, the ECE units have concentrated their efforts on the enhance

ment of investigative and prosecutive capabilities, since achievements in these areas will enhance, to some extent, capabilities in detection, preven

tion and obtainment of appropriate sanctions. In fact, with respect to the

last enhancement goal, most program participants in the field thought it was a totally resultant goal, and did not mention any positive steps they could

take towards enhanced capabilities in this area.

Thus, the unit's achievements

reflect the developmental nature of the program and the emphasis which must be given to the program's investigative and prosecutive objectives. These

unit achievements are examples along the continuum of program implementation,

illustrative of program implementation and effectiveness, and are not intended

to be an exhaustive list of achievements to date.

INVESTIGATION

General Achievements:

Developed and established a district white-collar crime information

Established working relationship with Federal investigative agencies. Held meetings and conferences for program and investigative agencies, facilitating the discussion of developing cases, techniques, and

The coordinative work of one Specialist led to the discovery of connec

tions between several apparently unrelated corporations, each being investigated by a different investigative agency. The Specialist then formulated an investigative strategy which allowed the agencies

to continue their work, while avoiding the problems arising from

parallel proceedings.

One Specialist coordinated the joint investigation of a large, complex

vote buying scandal. The Specialist worked to facilitate cooperation

between the OUSA and the relevant State's law enforcement division.

The matter has already resulted in several indictments.

Additionally, Specialists have been involved in coordinating and/or

directing major, joint investigations including:

an FBI-Housing and

Urban Development team to study the illegal activities of a State

agency, an FBI -Health and Human Services team to examine specific

areas of Medicare/Medicaid fraud and an FBI-Insurance Crime Prevention

Institute team to investigate attorney-doctor phony accident schemes.

Sponsored seminars on the use of various prosecutive techniques.

Established new declination guidelines for white-collar crime cases.
Provided direction, guidance, and oversight for the prosecution of

specific, complex white-collar crime cases.

Acted as lead attorney or co-counsel on various white-collar crime

cases.

Selected Specific Achievements:

One Specialist found that a potentially major nursing home fraud case had languished for two years because of a lack of evidence of intent. The Specialist created a joint FBI-program agency task force to pursue

the case and explained what additional evidence was required. An

indictment was returned, and the case is to go to trial shortly.

The Specialist in one location, recognizing the need for greater prosecutorial knowledge of accounting, helped arrange an IRS sponsored

seminar for AUSAS.

The seminar dealt with: (a) education in the area

of basic accounting principles; (b) accounting principles frequently encountered in white-collar crime cases; and (c) hypothetical application of these principles in specific types of white-collar crime. In