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.

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.

PREVENTION

General Achievements:

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:

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 self

help techniques to reduce workplace crime.

o

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

program.

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.

CHAPTER IV
ISSUES IMPACTING UPON THE ESTABLISHMENT AND IMPLEMENTATION

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

offenders."*

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