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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.
then developed a series of recommendations for the relevant OIG to
increase recipient accountability (e.g., requiring recipient signatures, etc.).
Established an inventory of ongoing white-collar criminal investigations.
Identified patterns of fraud and abuse in the ECE districts.
The Specialist in one district developed a series of indicators for
detecting toxic waste violations in the transportation industry.
Provided suggestions for legislative changes at the Federal and
Gave lectures on the subject of white-collar crime and methods
of detecting and preventing its occurrence to local interest and
Selected Specific Achievements:
The Specialist coordinated a multi-agency arson/insurance fraud task
force in his district because arson is a particularly egregious
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 self
help techniques to reduce workplace crime.
The Specialist in one district, after studying and developing a
series of sentencing memoranda, produced a study on the use of the
Dangerous Special Offender Statute in white-collar crime cases.
The above narrative has described the internal and external organization and operation of the ECE units, the developmental stages that are characteristic of establishing and implementing a unit, and has identified some unit achieve
ments which highlight, to some extent, the initial effectiveness of the ECE
Together with the first two chapters, this report has documented the
operation of the OECE and the initial seven ECE units in terms of program structure and rationale, thus, fulfilling three objectives of the study and providing the basis for meeting its fourth purpose - developing recommendations
for improving management of the program.
OF THE ECONOMIC CRIME ENFORCEMENT PROGRAM AND UNITS
The preceding chapters of the report have, while presenting a description of the ECE program, noted specific observations and findings about various aspects of the program. The first chapter examined program design and determined that, theoretically, the program could accomplish its objectives. The
next two chapters considered current program operations for indications that
the program is working as contemplated and would, therefore, be able to
achieve its objectives. Together, however, these chapters form the foundation for raising some important program-wide issues that have the potential to limit the effectiveness and efficiency of the program. These issues, although discussed separately, are interrelated, focusing primarily on the role of the Specialist and his ability, as a CRM employee, to function as a change
agent in the decentralized activities of the 95 OUSAS. Specifically, the
issues to be discussed are:
The ECE program is based, in large part, upon the Specialist's ability to balance the various expectations of program participants, while acting as a catalyst to unify the enforcement efforts of 93 judicial
districts through 30 OUSAs, thus giving the program a national scope.
Can the ECE program design achieve this objective of national coverage?
What particular environment is necessary in a district to ensure the
successful initiation of an ECE unit?
What attributes of and role for the Specialist in his ECE region will best ensure the effective and efficient utilization of CRM resources?
These issues are addressed from a management perspective, with the purpose of
providing recommendations to CRM management to improve and clarify the ECE
program as they formulate plans to expand, modify and evaluate it. They are discussed within the context of the program's objective "to enhance the capabilities and capacities of the Department to prevent, detect, investi
gate and prosecute the economic crime offender nationally"* and in light of
the program's design to have ECE units operate "... in the U.S. Attorneys'
Offices and within the Criminal Division of the Department of Justice with the
goal of directing investigative and prosecutive resources for two of the
Department's top enforcement priorities: fraud and public corruption. In addition, the discussion is presented in view of the Attorney General Order's
further purpose "to mandate maximum efficiency in the utilization of personnel
in the prevention, detection, investigation and prosecution of economic crime
Finally, it is recognized that there is no one solution to address all variations of the particular situation in a specific OUSA. Indeed, the ECE program was developed with the understanding that there are innumerable variables that
affect a program of this nature, and the preferred method of handling the
variables is through flexibility in the program design. Therefore, the conclusions and recommendations in this chapter, while based on sound principles of
Attorney General Order 817-79