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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 enhancement of investigative and prosecutive capabilities, since achievements in these areas will enhance, to some extent, capabilities in detection, prevention 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 system.

Developed an informal method for coordination of investigators in

multi-jurisdictional cases.

• Established working relationship with Federal investigative agencies.

Held meetings and conferences for program and investigative agencies, facilitating the discussion of developing cases, techniques, and

strategies for combatting white-collar crime.

Encouraged several regional Inspectors General to develop quality

cases for referral to OUSAS.

Established liaison with State and local agencies.

Selected Specific Achievements:

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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.

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Sponsored seminars on the use of various prosecutive techniques.

Identified cases for State and local prosecution.

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.

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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

another district, a Specialist discovered that a regional OIG needed training in financial investigation techniques, and arranged for a

similar IRS sponsored course.

A Specialist aided in the successful prosecution of two major recipient fraud cases, one involving Farmers Home Mortgage Administration, U.S. Department of Agriculture and one involving the Veteran's Administration. One was developed into a significant public corruption case through the combined effort of the IRS, a regional OIG, and other agencies coordinated by the Specialist. Both cases resulted in constructive suggestions for changes in the recipient verification methods to the headquarters of the program agencies.

In a similar development, a Specialist observed systematic difficulties in prosecuting a certain form of recipient fraud. The Specialist

then developed a series of recommendations for the relevant OIG to

increase recipient accountability (e.g., requiring recipient signatures, etc.).

DETECTION

General Achievements:

Established an inventory of ongoing white-collar criminal investigations.

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Identified patterns of fraud and abuse in the ECE districts.

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The Specialist in one district developed a series of indicators for
detecting toxic waste violations in the transportation industry.

PREVENTION

General Achievements:

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Provided suggestions for legislative changes at the Federal and
State levels.

Gave lectures on the subject of white-collar crime and methods

of detecting and preventing its occurrence to local interest and

business groups.

Selected Specific Achievements:

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The Specialist coordinated a multi-agency arson/insurance fraud task
force in his district because arson is a particularly egregious
problem.

A unit attorney, with expertise in arson cases, testified before
Congress on current efforts to combat arson for profit.

It was determined that the prevention of illegal dumping of toxic
wastes into public waterways was a high priority in two districts
as a result of local concern and identification of the magnitude
of the problem.

One Specialist found that the business community had a low level of awareness of the white-collar crime problem, and is, therefore, working with them to heighten their knowledge of available selfhelp techniques to reduce workplace crime.

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