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in order to determine if each unit is functioning within program

guidelines, and to identify unit accomplishments;
To identify programmatic and organizational issues which influence

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the achievement of program goals, including the effect of the
varying ECE unit models on the achievement of program objectives;
to analyze study findings in order to identify those factors which

ought to exist for an ECE unit to operate effectively in an Office

of the U.S. Attorney (OUSA); and to develop recommendations for

improving management of the program.

The study team, consisting of three analysts from the Evaluation Staff,

Justice Management Division (JMD) and two analysts from the Office of Policy

and Management Analysis, CRM, conducted on-site visits to the U.S. Attorneys'

Offices in Philadelphia, Pennsylvania; Cleveland, Ohio; Denver, Colorado;

Portland, Oregon; Los Angeles, California; New Haven, Connecticut; and Columbia,

South Carolina. For data gathering purposes, an interview questionnaire was

developed and reports were prepared to document each interview. Interview

sessions at most locations were held with the U.S. Attorney, the First

Assistant, Chief of the Criminal Section, Assistant U.S. Attorneys (AUSA)

assigned to or working with the ECE unit, the ECE Unit Chief, the ECE Specialist,

a special agent from the Federal Bureau of Investigation (FBI), agents from other major investigating agencies, and managerial and agent personnel from various Offices of the Inspectors General (OIG). The District Reports,

formal six month reports of each unit prepared by the Specialist and submitted

to the OECE, provided background data on unit developments, problems and

accomplishments.

This report contains two principal parts: the first part sets forth an explanation of the program's rationale, a discussion of the design and development of the organizational and operational concepts of the ECE program, and a description of program achievements to date (Chapters I, II, and III),

while the second part is a discussion of issues affecting program implementation (Chapter IV).

The ECE program design is flexible, allowing the Specialist to adapt program

implementation to the individuality of his OUSA in order to address its characteristics, conditions and needs. Each Specialist may stress different objectives at varying stages of unit and program development, even though all Specialists are working toward, and prospectively achieving, the same goals.

This led the study team to the conclusion that, at this time, a unit-by-unit

comparison is inappropriate. To avoid the indiscriminate comparisons of the seven units which might occur if reported separately, the findings of this

study are reported in an aggregate fashion.

In many interview situations, references were made to specific active and

completed criminal cases in order to illustrate specific program features,

activities and accomplishments. While an analysis of specific white-collar

crime cases was not within the formal scope of this study, case accomplish

ments are reflected in many of the program accomplishments discussed in this

report.

The subject and scope of white-collar crime embraces a number of terms which are frequently used interchangeably while evoking different connotations, for

example, economic crime, fraud, and public corruption. The nature and scope

of criminal activities often associated with these terms unfortunately does

not permit the formulation of neat, precise definitions. To be consistent, the study team has chosen to use the term "white-collar crime" throughout

this report, when speaking to the subject matter of the ECE program. Also

for purposes of this report, a glossary of terms is provided in Appendix I; these terms are intended to be general working definitions, applicable to

the context of the study, rather than standard definitions.

Finally, the study team recognizes that many AUSAS, several Specialists, and

a few U.S. Attorneys, are women.

For purposes of the report narrative,

however, the decision was made to use the term "he," generally to refer to

both men and women in these positions, rather than "he/she" terminology or

other variations of this structure. This is done solely to make the report

narrative more readable.

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BACKGROUND

The ECE program was formally established on February 8, 1979 by Attorney

General Order 817-79 (Appendix II) which established OECE in CRM and provided

for the creation of ECE units within selected OUSAS.

The development of

this program was preceded by a series of related events, activities and

studies generated by private and public organizations which helped to enun

ciate the scope and magnitude of the nation's white-collar crime problem.

Among these organizations were the American Bar Association (ABA), the Chamber

of Commerce, the National District Attorneys Association (NDAA), the General

Accounting Office (GAO) and the U.S. Congress.

Some of the more notable

events that heightened an awareness of the need for a more structured approach

to address the white-collar crime problem nationally were:

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Attorney General Levi formed a White-Collar Crime Committee,

composed of Federal investigators and prosecutors, to examine the problem of white-collar crime and the Federal response. The Committee found the response inadequate (1975-1976).

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that the Federal effort toward white-collar crime was "under

funded, undirected, and uncoordinated," and where resources

existed, they were either "underutilized, or frustrated by

jurisdictional considerations." (Economic Offenses. Section on Criminal Justice, Committee on Economic Offenses, Washing

ton, D.C.).

1977

Attorney General Bell declared fraud and public corruption to

be two of the Department's four major law enforcement priorities.

1978

Congress passed the Inspector General Act, mandating the establishment of Inspectors General offices in major Federal departments and agencies,* "to conduct and supervise audits and investigations relating to programs and operations" as

well as:

(A) to promote economy, efficiency and effective

ness in the administration of (such programs and operations); and (B) to prevent and detect fraud and abuse in such programs

and operations."

1978

GAO initiated a review of the Department's efforts in attacking

public corruption. This report, issued in 1980, found the

current efforts to be inadequate, but indicated that a recently

developed program (the ECE program) may provide the basis to adequately centralize, prioritize and focus the Department's efforts. (GAO Report: Justice Needs to Better Manage Its

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Fraud, Waste and Abuse in Government, chaired by the Deputy

Attorney General, with responsibility to provide leadership

and formulate policy and operational guidance to the Inspectors

General and other offices of the Executive Branch in combatting

fraud, waste and abuse in government programs.

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Prior to the Inspector General Act of 1978, many of the major Federal departments and agencies had, in part, an analogous Inspector General function which was administered through their respective offices of inspection or audit or investigation. [P... 95-452 Section 9(a)]

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