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or motion pictures are priorities; other copyright matters are not.'' Domestic or international fraud by wire involving in excess of $25,000 or 10 or more victims is a priority; other frauds by wire are


The FBI's priority descriptions described above are a step in the right direction, but additional qualifying terms seem appropriate for other kinds of white collar crime. Such priority descriptions are particularly important when the implementation and evaluation of priorities are considered. Priorities defined simply as “CETA fraud” or “Offenses involving Hobbs Act violations” do not send the proper signals to investigators and prosecutors and would not effectively target resources, unless we care about all such offenses regardless of their magnitude, their victims, or other attributes. The types of white collar crime that deserve such across-the-board emphasis are, in our view, very limited.

E. Grouping the Data for Analysis

The Department's Information Request contained a suggestive list of types of white collar crime, indicating the specificity with which the respondents should identify priority or problem areas. In answering the Request, the respondents added specific types of offenses to the suggestive list, as necessary, in order to describe illegal activities occurring within their respective areas and not on the list. The result was an extended “Master List” of white collar crimes, containing over 300 items (see Appendix B).

In order to analyze the information provided, the types of white collar crime described by the respondents had to be grouped into packages that seemed to make sense. This packaging of the data was done initially by members of the Criminal Division's Office of Policy and Management Analysis. When the packages of information were analyzed by members of the relevant sections of the Criminal Division, some crimes were re-grouped in order to make analysis more manageable or meaningful.

The result was approximately 50 groups of crime, with the contents of each group summarized on a two to three page “Summary Fact Sheet". In addition to the Summary Fact Sheets, other information, including a description of the respondents identifying that type of illegal activity as a priority area and other relevant material, was collected for each illegal activity. These materials form the basis for the analysis and the conclusions contained in this report.



12 Ibid.


Before analyzing crimes within various categories, some overview of the information the Department has gathered is appropriate. The figures given below, however, should be viewed with caution. The first table (Table 2) ranks various types of white collar crime according to how many respondents identified each crime as a problem or priority area. The table also shows how many different agencies identified each crime as a priority area.

In reviewing these numbers, one should bear in mind the distribution of those responding to the Information Request. Some investigative agencies sent the Request to all district or field offices (Secret Service, Customs, ATF), while others sent it to regional offices (SEC, Postal Inspection) or responded from headquarters only (most Inspectors General). Thus, if some types of illegal activity have a high number of respondents identifying them as priority areas, it may be partially attributable to the fact that the agency with jurisdiction over that activity had a larger number of field offices providing responses to the Information Request. An illegal activity identified as a priority by only a few respondents may nevertheless be a problem of great magnitude, if, for example, those few respondents are Inspector General offices with nationwide responsibility and large programs to monitor.

Secondly, the information in Table 2 reflects the information contained in the FBI's FY 1979 surveys of its field offices. That information was of a somewhat different nature than that provided by respondents to the Division's Information Request and therefore some interpretation of the FBI surveys has been necessary in order to make the data comparable. The more recent survey of FBI field offices, asking for identification of top problem areas as of February 1980, is summarized in Table 3.

Thirdly, the grouping of information into types of illegal activity obviously required some judgment. For example, real estate frauds are separated from other types of investor fraud in the table below. Had they been consolidated, a larger category of “All Investor Fraud" would most likely have shown more agencies and more respondents reporting it as a priority area, and therefore would have appeared higher on the table.

In sum, the following table indicates in only a very general and rough way the relative frequency with which various types of illegal activity are viewed as deserving priority status. The numbers should be viewed with all of the above caveats in mind.

Some of the results of the February 1980 FBI survey are summarized below. A more complete summary is provided in Appendix C to this report. Essentially, the FBI field offices were asked to do two things: 1) rank four major categories or program areas of white collar crime-corruption, financial crimes, federal program fraud, and other white collar crime- in order of importance; and 2) list, within each of the four major program areas, the three most significant problems in their respective geographical areas of responsibility.

As shown in more detail in Appendix C, the 61 FBI field offices responding generally indicated corruption as their number one program area (54% ranked corruption as number 1), with financial crimes second (33%), federal program fraud third (11%) and other white collar crime last (2%). The specific illegal activities listed most frequently by the FBI field offices as their most significant problem areas are listed below,

The figures contained in Tables 2 and 3 are of some utility in giving a general sense of investigative agencies' and others' perceptions of major white collar crime problems. Much more important in determining priorities, however, is the specific information about each major type of Summary of Number of Agencies and Respondents Identifying Various Types of Megal Activity as Priority/Problem Areas


Number of Agencies
Identifying As Priority/
Problem Area

Number of Respondents
Identifying As Priority/
Problem Area


Type of Illegal Activity

Fraud and Corruption involving federal procurement


B01, BO2, B06, B12, B24,


F05, F07, F08, others



Victimization of private institutions (including embezzlement,
looting, espionage, extortion, but not bank fraud and embezzle-

G02, G06



Customs violations (including currency, munitions control,
other export/import violations)

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F02, F03

Insurance fraud (including arson for profit)
E22, E25, E34, E47, others Corruption of state and local officials
C07, C08, C12, others Investor Fraud, other than real estate fraud (including com-

modities, precious metals, tax shelter fraud, and Ponzi schemes)



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Fraud involving federal housing program funds (loans, grants
and subsidies)

DO2, D12



Embezzlement, misappropriation of union funds, including
pension and other benefit funds

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C04, COS



Consumer fraud (including insurance fraud, merchandise swindles, phony contests)

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C03, C16 E07, E19, E33, E43, others

Securities fraud, market manipulation Corruption of federal officials other than procurementrelated corruption



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*Indicates total number of responding offices, i.e., investigative agency field offices, Inspector General offices, Economic Crime Units, etc., identifying illegal activity as a priority or problem area.


Wegal Activities Most Frequently Identified As Significant Problem Areas By FBI

Field Offices - February 1980

Priority/Problem Area

Number of Field Offices
Identifying as Problem Area

43 (71%)*

37 (61%) 28 (46%) 28 (46%) 28 (46%) 27 (44%) 23 (38%) 23 (38%)

1. Corruption of state and local officials, including kickbacks to purchasing

agents, inspectors, legislators, members of judiciary, etc. 2. Bank fraud and embezzlement 3. Labor-related corruption 4. Housing/HUD frauds, including VA/FHA frauds 5. Copyright matters 6. Procurement-related corruption of federal officials, including GSA and Defense 7. Advance fee schemes 8. Fraud involving health, rehabilitation and welfare programs, including Medicare/

Medicaid 9. Fraud involving CETA funds and other Department of Labor Programs 10. Wire fraud/mail fraud, scheme unspecified 11. Bribery, corruption of federal officials other than procurement-related corruption 12. Bankruptcy Act/bust out schemes 13. Fraud involving SBA loans or benefits 14. Overbilling, fraud against the government involving construction and service

contractors 15. Investor fraud generally, including Ponzi schemes, franchise fraud, business

opportunity fraud

23 (38%) 22 (36%) 21 (34%) 21 (34%) 18 (30%) 16 (27%)

15 (25%)

• Figures in parentheses indicate percentage of total number of responding offices (61) identifying the illegal activity as a significant problem.

white collar crime provided by these agencies and collected from other sources. The discussion below is based on that information; however, it is limited to what appear to be the most significant attributes of each crime, consistent with the criteria described earlier for choosing national priorities.

A. Criminal Activity Threatening the Integrity of

Government Institutions and Processes

This category includes four broad areas of illegal activity:

1. Corruption of federal officials, other than GSA corruption
2. GSA corruption
3. Corruption of state and local officials
4. Bribery of foreign government officials

GSA corruption is treated separately from other federal corruption at the suggestion of the Public Integrity Section, which reviewed and summarized all public corruption-related data. The focus of this category is on corrupt activities that threaten the integrity of government institutions and procedures. These corrupt activities are often connected with fraud against the government by outsiders, particularly procurement and program fraud. The latter type of abuses, which have a major impact on government and taxpayer costs, are treated in more detail in the next section of this report.

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