Liaison with other Agencies and Organizations: OECE has established contact with the investigative, program and regulatory agencies, the Executive Group to Combat Fraud, Waste and Abuse in Government, and the NDAA to explain program goals and operations and to establish working relationships that will further effect an open, cooperative endeavor in combatting white-collar crime. As an example of OECE's liaison role, a Specialist was recently involved in a joint case investigation by the FBI and an OIG field office. As the case developed, differing disclosure regulations between the FBI and the OIG threatened to damage the case as a result of pre-trial discovery motions made by the defense. The Specialist informed the OECE Director of this problem, who apprised the Executive Group Staff Director of the situation. Steps are now being taken to standardize and tighten the various OIG disclosure regulations to avoid this potentially destructive problem in the future. - National and District Priorities: The national white-collar crime priorities form the parameters within which Federal investigators and prosecutors are to focus their efforts. The Attorney General issued these priorities in a report entitled the National Priorities for the Investigation and Prosecution of White-Collar Crime on September 9, 1980. The priorities are the result of an extensive survey undertaken by CRM to supplement existing information with current and more comprehensive data on white-collar crime. The report was formulated on the basis of information provided by representatives of the major Federal agencies and departments involved in the investigation and prosecution of white-collar crime, including those ECE Specialists who were then in place. In general, the priorities cover the broad areas of fraud, corruption and certain regulatory violations, and are divided into seven categories reflecting broad groups of institutions and individuals victimized by white-collar crimes. The categories are: Crimes against the government by public officials, including Federal, State and local corruption; Crimes against the government by private citizens, including tax fraud, procurement fraud, program related fraud, counter- Crimes against business, including embezzlement and bank fraud, insurance fraud, bankruptcy fraud, advance fee schemes and labor Crimes against consumers, including defrauding of customers, antitrust Crimes against investors, including securities and commodities fraud and real estate swindles; Crimes against employees, including life-endangering health and safety violations and corruption by union officials, and Crimes affecting the health and safety of the general public, including the illegal discharge of toxic, hazardous, or carcinogenic waste. From the framework of national priorities each U.S. Attorney, with the concurrence of the Assistant Attorney General, CRM, is to select specific priorities that are particular to his Federal district. The district priorities will be reviewed at least once a year. Program Evaluation: The Attorney General's Order requires continued program evaluation, so that appropriate program adjustments can be made when deemed necessary. Although the program is not at a stage where formal evaluation is possible, review of the program and an informal assessment of its problems are reflected in the district annual reports, and also are undertaken by the Director and Deputy Director in their field visits. FUTURE ACTIVITIES To further implement program objectives, OECE plans to expand its role into the following program areas: ECE Units: Over the next year OECE, if given the resources requested in the Enhanced Analytical Capability: A major aspect of the program encompasses gathering district-level information regarding the nature and magnitude of white-collar crime, compiling and analyzing the data in order to develop a national picture, and identifying trends within the scope of white-collar crime activities. The location within Missouri has not yet been determined. In the FY 1982 budget, OECE is requesting two program analysts to meet this objective, and two accountant-advisors to be available to ECE units and CRM for expert assistance in sophisticated white-collar crime cases, and to supplement the audit capability of other program agencies. Increased Contact with Agency Headquarters: In order to strengthen the relationship of OECE with prosecutive, investigative and program agencies and build effective communication links between Specialists and corresponding agency field offices, OECE plans to increase its liaison with headquarters personnel. Regional Conferences: In accordance with the purpose of arranging training for investigative, program and prosecutive personnel, OECE plans to conduct regional conferences in addition to the national ECE conferences. As the ECE program develops, the national and regional conferences will focus on advanced investigative and litigative skills, thus necessitating that OECE commit resources to undertake the development and formulation of these advanced techniques. OECE's current responsibilities will expand as the program reaches full implementation, and new responsibilities will be assumed when the program, as a whole, becomes operational. It is expected, therefore, that OECE will become increasingly involved in the aforementioned activities, while undertaking a role in the procurement of additional resources for the prosecution of significant cases and the formal evaluation of program operations. The above narrative describes OECE's organizational relationship with to the Department and the ECE units, and its responsibilities to the ECE program; it highlights achievements to date and provides a perspective for future activities. At the same time, the above discussion, together with the following chapter, raises some programmatic and organizational issues, which, in the judgment of the study team, can affect the future development of the ECE program. These issues are presented in Chapter IV. |