crime cases will be the responsibility of each district's United States Attorney. The coordination of efforts made by each unit or non-unit

office within a region will be the responsibility of the Economic Crime Enforcement Specialist."

While the implementing memorandum provided for the functional relationship of the Specialist to the non-unit district, it did not specify the relationship of the Specialist to the U.S. Attorney or to the AUSAS in non-unit districts. This lack of a definitive organizational relationship between the Specialist and his non-unit districts could present a dilemma for the Specialist attempting to effect change in the non-unit OUSA's prosecution of white-collar crime cases.

In addition, it can reasonably be inferred from the Deputy Attorney General's implementing memorandum (Appendix III) that the Specialist is to serve the nonunit districts in the same or similar capacity as the unit district. However, given the practical considerations of travel, time, and expense, a question arises as to whether the Specialist can effectively serve more than one district. The Specialist's role and scope of activity, budget limitations and demands on his time suggest that substantial service to non-unit districts simultaneously within a unit district cannot be achieved as efficaciously as would service restricted primarily to the unit district with limited participation in non-unit districts.

Another factor to be considered in assessing the national scope of the program is the relative size of OUSAs in unit and non-unit districts and their relationship to program design. As noted earlier, the initial seven unit locations

were selected, in part, on the basis of office size

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OECE initially chose medium sized offices as their target, but added one large office to assess its adaptibility to the ECE program. A comparison of the staffing allocations of the 93 program OUSAS to the 30 selected sites, shows that the primary target for ECE units continued to be large and medium sized offices, (see Chart V below) thus reinforcing a design focused on larger OUSAs.

The program design for the location of the 30 ECE units incorporates an implicit recognition that small offices could not effectively participate in the unit plan, since such full participation in the program would significantly reduce their ability to discharge other prosecutorial duties. It would appear, therefore, that the relationship of the Specialist and the ECE program to the 53 small non-unit offices would necessarily need to be different than it would be for the large or medium size unit and non-unit districts. As noted, white-collar crime cases can be complex and time-consuming. The

⭑ For a complete breakdown of figures see Appendix VI.

limited resources both of the program and of the smaller OUSAs generally do not allow full coverage of the program in the smaller offices. One method of bringing these small offices into the program is to have the Specialist

assist on a case-by-case basis. He could compile an initial survey for the OUSA to identify those areas of white-collar crime which appear to be a significant problem in that district. When a sizeable case in those priority areas is brought to the OUSA, the Specialist could review the case, and provide the OUSA guidance as to the manner in which they should proceed.

Therefore, while the program is designed to have a national focus, the national dimensions of the program can be affected by: the allocation of prosecutive resources among the large, medium and small OUSAS; the relationship of the Specialist to non-unit districts; the practical limitations of time, distance and budget imposed on a Specialist working within a multi-district region; and the willingness of the U.S. Attorney to accept and support the ECE program in his district. While the ECE program deals with a national problem, in effect, the program's national scope will be limited primarily to 30 unit districts until an adequate plan for addressing the functions and operations of the non-unit districts and their relationship to the unit districts is developed.

The Utilization of the Two Specialist Concept. Interrelated with the issue of whether 30 units can effect a national program is the question of how to best utilize CRM's Specialists to ensure this coverage. CRM's plan is to have two Specialists in most of the 30 ECE regions. This plan allows for three possible arrangements for locating the second Specialist within the region:

place him in the same office as the first Specialist, thus having

both Specialists primarily working for the same U.S. Attorney and

the same community;

locate the second Specialist in the same district as the first
Specialist, but in a field office of the OUSA, thereby having both
Specialists reporting to the same U.S. Attorney, but servicing
separate communities; or

situate the second Specialist in a separate district within the ECE
region, and in this way have each Specialist support different U.S.
Attorneys and communities.

In establishing the first seven units, only one unit was staffed with two Specialists, the second Specialist having been employed only a few months prior to the initiation of the study team's field work. Thus, there was insufficient evidence for the study team to fully assess the advantages of two Specialists in one region. However, the following observations, based on the study team's review of the operations of one Specialist in a region, should be considered by CRM management in the process of making decisions regarding the three alternative locations.

Located in the Same Office. Where two Specialists are located in the same district, further expansion of the program in that district, e.g., greater involvement at the State and local levels, or the initiation of coordination with the business community, can be undertaken. In addition, with the collocation of the two Specialists, a closer coordination of their program efforts is possible. However, one possible problem from further expansion in a

district is that it may overextend the OUSA's resources, thus creating an undesirable imbalance in the resource commitments of both the OUSA and the program. Overextending the OUSA's resources could lead to a problem of unduly raising the expectations for the program held by investigative agencies, thus, hindering the Specialist's attempts to gain the cooperation and confidence of these agencies. Having both Specialists in one district also fails

to eliminate the difficulties that arise from the practical considerations of one Specialist serving non-unit districts such as travel and expense; nor does it reduce the multiplicity of reporting requirements for the Specialists: to CRM, to the district U.S. Attorney, and, in some capacity, to one, two, three, or four non-unit district U.S. Attorneys, depending on the ECE region.

Located in the Same District but Separate Offices. The location of the two Specialists in separate offices allows for a more substantial involvement in a second community, thus, broadening the program's area of influence. By working in the same district, however, the Specialists are still primarily a catalyst for change in the operations of only one U.S. Attorney, and before they can expand their activities in this respect, they will have to overcome the practical considerations involved in serving the non-unit districts.

Located in Separate Districts. In separate districts, the Specialists should be able to effect a greater expansion into the region, e.g., acting as changeagents in two separate OUSAs, or developing a greater understanding of program objectives within Federal enforcement agencies in two districts on a "fulltime" basis. The use of two Specialists in this manner creates a national