The Department of State's Bureau of International Narcotics and Law Enforcement Affairs (INL) and the Department's Office of the Coordinator for Counter-Terrorism (SCT) are together implementing a multi-million dollar training and technical assistance program to provide law enforcement, prosecutorial and Central Bank training to countries around the globe. A prime focus of the training program was a multi-agency approach to develop or enhance financial crime and anti-money laundering regimes capable of combating not only money laundering activities but also terrorist financing in selected jurisdictions. Supported by and in coordination with the State Department, the Department of Justice, Treasury Department component agencies, the Board of Governors of the Federal Reserve, the Federal Deposit Insurance Corporation, and various nongovernment organizations offered law enforcement, regulatory and criminal justice programs worldwide.
During 2003, INL/SCT-funded programs were delivered in 49 countries to combat international financial crimes, money laundering and terrorist financing. Nearly every federal law enforcement agency assisted in this effort by providing basic and advanced training courses in all aspects of financial criminal activity. In addition, INL made funds available for intermittent posting of financial advisors at selected overseas locations. These advisors work directly with host governments to assist in the creation, implementation, and enforcement of anti-money laundering and financial crime legislation. INL also provided several federal agencies funding to conduct multi-agency financial crime training assessments and develop specialized training in specific jurisdictions worldwide to combat money laundering.
INL, along with the European Union and the Government of the United Kingdom, continues to fund the Caribbean Anti-Money Laundering Programme (CALP). INL contributed $600,000 to the CALP in 2003. The objectives of CALP are to reduce the laundering of the proceeds of all serious crime by facilitating the prevention, investigation, and prosecution of money laundering. CALP also seeks to develop a sustainable institutional capacity in the Caribbean region to address the issues related to anti-money laundering efforts at a local, regional and international level.
In 2003, INL reserved $1 million for the United Nations Global Programme against Money Laundering (GPML). In addition to sponsoring money laundering conferences and providing short-term training courses, the GPML instituted a unique longer-term technical assistance initiative through its mentoring program. The mentoring program provides advisors on a yearlong basis to specific countries or regions. A GPML mentor provided assistance to the Secretariat of the East and South Africa Anti-Money Laundering Group (ESAAMLG). INL continues to provide significant financial support for many of the anti-money laundering bodies around the globe. During 2003, INL support was furnished to the Financial Action Task Force on Money Laundering (FATF), the international standard setting organization, and to FATF-styled regional bodies (FSRBs) including the Asia/Pacific Group on Money Laundering (APG), the Council of Europe's MONEYVAL, and the Caribbean Financial Action Task Force (CFATF). INL also provided financial support to the ESAAMLG and the South American Financial Action Task Force, Grupo de Accion Financiera de Sudamerica Contra el Lavado de Activos (GAFISUD), the FATF-styled regional body in South America. INL also financially supported the Pacific Island Forum and the Organization of American States (OAS) Inter-American Drug Abuse Control Commission (CICAD) Office of Money Laundering and the OAS Counter-Terrorism Committee.
As in previous years, INL training programs continue to focus on an interagency approach and on bringing together, where possible, foreign law enforcement, judicial and Central Bank authorities in assessments and training programs. This allows for an extensive dialogue and exchange of information. This approach has been used successfully in Asia, Central and South America, Russia, the New Independent States (NIS) of the former Soviet Union, and Central Europe. INL also provides funding for many of the regional training and technical assistance programs offered by the various law enforcement agencies, including assistance to the International Law Enforcement Academies (ILEAs).
The mission of the ILEAs has been to support emerging democracies, help protect U.S. interests through international cooperation and to promote social, political and economic stability by combating crime. To achieve these goals, the ILEA program has provided high-quality training and technical assistance, supported institution building and enforcement capability and has fostered relationships of American law enforcement agencies with their counterparts in each region. ILEAs have also encouraged strong partnerships among regional countries, to address common problems associated with criminal activity.
The ILEA concept and philosophy is a united effort by all of the participants—government agencies and ministries, trainers, managers, and students alike—to achieve the common foreign policy goal of international law enforcement. The goal is to train professionals that will craft the future for rule of law, human dignity, personal safety and global security.
The ILEAs are a progressive concept in the area of international assistance programs. The regional ILEAs offer three different types of programs: the Core course, specialized training courses and regional seminars tailored to region-specific needs and emerging global threats. The Core program typically includes 50 participants, normally from three or more countries. The Specialized courses, comprised of about 30 participants, are normally one or two weeks long and often run simultaneously with the Core course. Topics of the Regional Seminars include transnational crimes, counterterrorism and financial crimes.
The United States has amended the money laundering portion of the Core course presented at each ILEA to address terrorist financing, significantly increasing the number of instruction hours dedicated to this critical topic. The ILEA program partner agencies (see below) are working on finalizing a new Specialized course that would focus specifically and in detail on terrorist financing, to be offered at all the ILEAs.
The ILEAs help develop an extensive network of alumni that exchange information with their U.S. counterparts and assist in transnational investigations. These graduates are also expected to become the leaders and decision-makers in their respective societies. The Department of State works with the Departments of Justice, Homeland Security and Treasury, and with foreign governments to implement the ILEA programs. To date, the combined ILEAs have trained over 12,000 officials from 50 countries in Africa, Asia, Europe and Latin America. The annual ILEA budget averages approximately $18-19 million.
Africa. ILEA Gaborone (Botswana) opened in 2001. The main feature of the ILEA is a six-week intensive personal and professional development program, called the Law Enforcement Executive Development Program (LEEDP), for law enforcement mid-level managers. The LEEDP brings together approximately 45 participants from several nations for training on topics such as combating transnational criminal activity, supporting democracy by stressing the rule of law in international and domestic police operations, and by raising the professionalism of officers involved in the fight against crime. ILEA Gaborone also offers specialized courses for police and other criminal justice officials to enhance their capacity to work with U.S. and regional officials to combat international criminal activities. These courses concentrate on specific methods and techniques on a variety of subjects, such as counterterrorism, anti-corruption, financial crimes, border security, drug enforcement, firearms and many others.
Instruction is provided to participants from Angola, Botswana, Lesotho, Malawi, Mauritius, Mozambique, Namibia, Seychelles, South Africa, Swaziland, Tanzania and Zambia. This area of focus was recently expanded to include key countries (Djibouti, Ethiopia, Kenya, Uganda) in East Africa and Nigeria in West Africa. Eventually this gradual expansion will reach other sub-Saharan African countries. United States and Botswana trainers provide instruction. ILEA Gaborone has offered specialized courses on money laundering/terrorist financing related topics such as Criminal Investigation (presented by FBI) and International Banking & Money Laundering Program (presented by DHS/FLETC). ILEA Gaborone trains approximately 450 students annually.
Asia. ILEA Bangkok (Thailand) opened in March 1999. The ILEA focuses on enhancing the effectiveness of regional cooperation against the principal transnational crime threats in Southeast Asia—illicit drug trafficking, financial crimes, and alien smuggling. The ILEA provides a Core course (the Supervisory Criminal Investigator Course or SCIC) of management and technical instruction for supervisory criminal investigators and other criminal justice managers. In addition, this ILEA presents two Senior Executive programs and eight to ten specialized courses—lasting one to two weeks—in a variety of criminal justice topics. The principal objectives of the ILEA were the development of effective law enforcement cooperation within the member countries of the Association of Southeast Asian Nations (ASEAN) plus China and the strengthening of each country's criminal justice institutions to increase their abilities to cooperate in the suppression of transnational crime.
Instruction is provided to participants from Brunei, Cambodia, China, Hong Kong, Indonesia, Laos, Macau, Malaysia, Philippines, Singapore, Thailand and Vietnam. Subject matter experts from the United States, Thailand, Japan, Netherlands, Australia, Philippines and Hong Kong provide instruction. ILEA Bangkok has offered specialized courses on money laundering/terrorist financing related topics such as Computer Crime Investigations (presented by FBI and DHS/BCBP) and Complex Financial Investigations (presented by IRS, DHS/BCBP, FBI and DEA). Total annual student participation is 550.
Europe. ILEA Budapest (Hungary) opened in 1995. Its mission has been to support the region's emerging democracies by combating an increase in criminal activity that emerged against the backdrop of economic and political restructuring following the collapse of the Soviet Union and its former satellite regimes. ILEA Budapest offers three different types of programs: an eight-week Core course, Regional Seminars and Specialized courses in a variety of criminal justice topics. Instruction is provided to participants from Albania, Armenia, Azerbaijan, Bulgaria, Croatia, Czech Republic, Estonia, Georgia, Hungary, Kazakhstan, Kyrgyzstan, Latvia, Lithuania, Macedonia, Moldova, Montenegro, Poland, Romania, Russia, Serbia, Slovakia, Slovenia, Tajikistan, Turkmenistan, Ukraine and Uzbekistan.
Trainers from 17 federal agencies and local jurisdictions from the United States and also from Hungary, Canada, Germany, Great Britain, Holland, Ireland, Italy, Russia, Interpol and the Council of Europe provide instruction. ILEA Budapest has offered specialized courses on money laundering/terrorist financing related topics such as Investigating/Prosecuting Organized Crime and Transnational Money Laundering (both presented by DOJ/OPDAT). ILEA Budapest trains approximately 950 students annually.
Global. ILEA Roswell (New Mexico) opened in September 2001. This ILEA offers a curriculum comprised of courses similar to those provided at a typical Criminal Justice university/college. These four-week courses have been designed and are taught by academicians for foreign law enforcement officials. This Academy is unique in its format and composition with a strictly academic focus and a worldwide student body. The participants are mid-to-senior level law enforcement and criminal justice officials from Eastern Europe, Russia, the Newly Independent States (NIS), Association of Southeast Asian Nations (ASEAN) member countries and the People's Republic of China (including the Special Autonomous Regions of Hong Kong and Macau); and member countries of the Southern African Development Community (SADC) plus other East and West African countries. The students are drawn from pools of ILEA graduates from the Academies in Bangkok, Budapest and Gaborone and other selected participants mainly from Latin American and the Caribbean. ILEA Roswell trains approximately 450 students annually.
The FRB participates in the effort to deter money laundering primarily through ensuring compliance with the Bank Secrecy Act and the USA PATRIOT Act by the domestic and foreign banking organizations that it supervises.
In another initiative to combat money laundering, FRB staff conducted training in anti-money laundering tactics and provided technical assistance to banking supervisors and law enforcement officials throughout the world. Programs for Mexico, as well as courses designed for students from Eastern and Southern African countries, were provided in 2003. In addition, the FRB collaborated with the U.S. State Department as well as other bank regulatory agencies in presenting counterterrorist financing regulatory training to numerous South East Asian, Central American, and South American countries.
In addition to its international training programs, the FRB presented training courses to U.S. law enforcement agencies at the Federal Law Enforcement Training Center to the Internal Revenue Service, the Federal Bureau of Investigation, the U.S. Postal Inspection Service, Department of Homeland Security's Bureau for Immigration and Customs Enforcement, and the Drug Enforcement Administration.
The International Training Section of the Drug Enforcement Administration (DEA) conducts its International Asset Forfeiture and Money Laundering courses in concert with the Department of Justice (DOJ). In 2003, a total of 168 participants from Brazil, Malaysia, Costa Rica, France and Greece received this training. A wide range of DEA international courses contain training elements relating to countering money laundering and other financial crimes. DEA training division also provides training International Law Enforcement Academy (ILEAs) Hungary; Thailand and Botswana.
The basic course curriculum includes instruction addressing money laundering and its relation to Central Bank operations, asset identification, seizure and forfeiture techniques, financial investigations, document exploitation, and international banking. Overviews of U.S. asset forfeiture law, country forfeiture and customs law, and prosecutorial perspectives are also included.
In 2003, training specialists with the Federal Bureau of Investigation (FBI) through its Terrorist Finance Operations Section (TFOS) continued extensive training in various regions of the world covering basic and more advanced courses in terrorism financing and money laundering, financial fraud and the underpinning of terrorism, racketeering, enterprise investigations, complex financial crimes and countering international money laundering.
In concert with other U.S. and international trainers, the FBI conducted aspects of the full range of its training for a variety of countries on a regional basis through the International Law Enforcement Academies (ILEAs) in Bangkok, Thailand, and Budapest, Hungary. In other programs, FBI training reached numerous officials representing various levels of the judiciary and law enforcement as well as private sector banking and financial officials. Students participating in FBI training around the world—in several instances in concert with the U.S. Internal Revenue Service (IRS)—represented Bahrain, Oman, Qatar, Saudi Arabia, UAE, Turkey, Pakistan, India, Cambodia, China, Fiji, Indonesia, Japan, Kiribati, Korea, Laos, Malaysia, Philippines, Taiwan, Thailand, Brazil, Colombia, Paraguay and Kenya. Some 40 officials representing 17 Latin American countries traveled to the FBI Academy in Quantico, Virginia, to participate in the Latin-American Law enforcement Executive Development Seminar, which includes coursework in money laundering and other financial crimes.
The FDIC is working in partnership with several agencies to combat money laundering and the global flow of terrorist funds. Additionally, the agency participates in the planning and conduct of missions to assess vulnerabilities to terrorist financing activity worldwide, and to develop and implement plans to assist foreign governments in their efforts in this regard. To better achieve this end, the FDIC has 22 individuals available to participate in foreign missions.
A training session was held in June 2003 that provided FDIC foreign mission participants with background information on the international conventions related to money laundering and terrorist financing and other essential preparatory instruction. A multi-agency team of instructors brought varying perspectives and experience to the session.
The FDIC's Division of Supervision and Consumer Protection participated in the decision-making process of the Basel Committee in reviewing the "Know Your Customer" risk management report and evaluated the progress report on jurisdictions with cross-border banking impediments.
Periodically, FDIC staff meets with supervisory and law enforcement representatives from various countries to discuss anti-money laundering issues, including examination policies and procedures, the USA PATRIOT Act and its requirements, the FDIC's asset forfeiture programs, suspicious activity reporting requirements and interagency information sharing mechanisms. In 2003, such presentations were given to representatives from Anguilla, Antigua, Armenia, Aruba, Austria, the Bahamas, Barbados, Barbuda, Belize, British Virgin Islands, Brazil, Cayman Islands, Dominica, Estonia, Grenada, Guyana, Haiti, Italy, Jamaica, Monsterrat, Netherlands Antilles, Poland, Russian Agency for Restructuring Credit Organizations, St. Kitts and Nevis, St. Lucia, St. Vincent and the Grenadines, Suriname, Taiwan, Trinidad and Tobago, and the Turks and Caicos Islands.
FDIC provided assistance in an interagency Financial Systems Assessment Team (FSAT) to Bangladesh in April 2003. The group reviewed the country's existing AML law and training efforts. Additionally, the group discussed implementation of the law and recommendations related to constraints of computer technology available in the country.
The FDIC participated in an interagency anti-money laundering evaluation of the Republic of Palau from March 6-16, 2003. The review was sponsored by the Asia/Pacific Group on Money Laundering.
FDIC also provided staff to participate in two training sessions. The first session was held in coordination with the Office of the Comptroller of the Currency in March 2003 in Washington, D.C. Twenty-five students from Bahrain, Egypt, Jordan, Pakistan, Qatar, and Saudi Arabia participated. The second training session was held July 13-19, 2003 in Panama City, Panama, with supervisors and examiners from Brazil, Argentina, Paraguay, Venezuela and Panama. The training session addressed anti-money laundering and antiterrorism financing examination procedures.
In October 2003, FDIC staff participated in an anti-money laundering and antiterrorist financing workshop in Honolulu, Hawaii, for regulators from the Philippines, Thailand, Indonesia and Malaysia. Topics included the Bank Secrecy Act, the USA PATRIOT Act, components of anti-money laundering examination programs and procedures, and an effective bank anti-money laundering program.
FinCEN, the U.S. Financial Intelligence Unit (FIU), a bureau of the U.S. Department of the Treasury, coordinates and provides training and technical assistance to partner nations seeking to work against money laundering, terrorist financing, and other financial crimes. In particular, its efforts focus on the creation and improvement of the financial intelligence units (FIUs). FinCEN's international training program has two main components: (1) instruction to a broad range of government officials, financial regulators, law enforcement officers, and others, on the subject of money laundering and FinCEN's mission and operation; and (2) financial intelligence analysis training and the operational aspects of FIUs such as FinCEN.
For those FIUs that are fully functional, the goal is to help them achieve an improved level of cooperation with U.S. and other FIUs in the exchange of information and the achievement of a better understanding of money laundering phenomena. As a member of the Egmont Group of FIUs, FinCEN also works closely with other members of the Egmont Group to provide training and technical assistance to various jurisdictions in establishing and operating their own FIUs.
During 2003, FinCEN conducted training courses, both independently as well as with other agencies. In some instances, courses are developed jointly with other agencies to address specific needs of the jurisdictions. A number of these courses are provided abroad to maximize the utility to the FIU. Much of FinCEN's work also involves strengthening existing FIUs and reinforcing channels for communicating operational information in support of anti-money laundering investigations. This includes participation in personnel exchanges (from the foreign FIU to FinCEN and vice versa) and regional and operational workshops.
In an effort to reinforce the sharing of information between established FIUs, FinCEN conducted personnel exchanges with a number of Egmont Group allies, including the Baltic States (Estonia, Latvia and Lithuania), Bolivia, Turkey, South Korea, and Russia. The exchanges offer the opportunity for FIU personnel to see first-hand the working of another FIU with a view towards possible improvement in such areas as analytical tools, information flow, and information security.
For financial intelligence analysis training, a group of analysts from the country's financial intelligence unit spends up to one week at FinCEN. In some cases, FinCEN will coordinate such training in-country. This type of training provides analysts with basic skills in critical thinking, inference and analysis; data collection; report writing; research and sources of information; financial analysis (such as bank records and net worth analysis); and case presentation. Training topics such as regulatory issues, international case processing, technology infrastructure and security, terrorist financing and money laundering trends and typologies provide analysts with broader background knowledge of the money laundering realm. In addition, analysts also gain an extensive knowledge of the U.S. anti-money laundering regime by meeting with representatives from other U.S. agencies, such as the Department of Justice's Asset Forfeiture and Money Laundering section, the State Department's Bureau of International Narcotics and Law Enforcement Affairs, and the Bureau of Immigration and Customs Enforcement under the Department of Homeland Security.
In 2003, to more appropriately address the specific needs of countries, FinCEN co-hosted training workshops in Malaysia and Mauritius. In Mauritius FinCEN worked with the newly formed FIU to provide specialists to teach analytical and money laundering investigative methods to analysts from India, Mauritius, and South Africa. In Malaysia, FinCEN joined with the FIU to co-host a regional Basic Analysis and Suspicious Transaction Report training seminar. The focus was on how to collect, analyze, and share data supplied by covered institutions, as well as on the FIU's ability to gather and disseminate information on money laundering trends and techniques to financial institutions and competent authorities. Invited participants included investigators and analysts from the newly formed and/or established FIUs in Malaysia, Thailand, Philippines, Singapore, India, Pakistan, Brunei and Indonesia. The workshop was the first training course hosted under the auspices of the Southeast Asian Centre for Counter-Terrorism in Kuala Lumpur. In Bangkok, Thailand, FinCEN provided Suspicious Transaction Report analytical training to the Anti-Money Laundering Office (AMLO). The training concentrated on suspicious transaction reporting analysis and basic investigative techniques, using AMLO's currently active data.
FinCEN partnered with other U.S. agencies such as Treasury's Office of Technical Assistance (OTA) to coordinate and fashion training to address specialized needs of FIUs during weeklong programs in Bulgaria and Hungary. Efforts were undertaken to begin to gain a better understanding of the role of international organizations in training and technical assistance programs and to coordinate FinCEN's programs and objectives with organizations such as the Organization of American States, the IMF and World Bank.
During 2003, FinCEN hosted representatives in the U.S. from over 50 countries. The visits focus on new money laundering trends and patterns, the Bank Secrecy Act, details of the USA PATRIOT Act, communications systems and databases, international case processing, and the regulatory role of FinCEN. Representatives from foreign governments and their financial and law enforcement sectors generally spend a day at FinCEN learning more about money laundering, the U.S. regulatory regime and reporting requirements, the national and international roles of a financial intelligence unit, and various other topics. During the year, this type of orientation was offered to officials from a diverse number of countries ranging from Kazakhstan to Lebanon.
In 2003, FinCEN also hosted delegations for more intensive seminars in computer software programs, data mining, and case processing. Participants came from various jurisdictions of the Caribbean, the Middle East, Africa, Southeast Asia and the Pacific, Central and South America, the Gulf States, and Europe. FinCEN's communications personnel provide FIU technical analysis and support in two primary areas: analysis and development of FIU network infrastructures and systems implementation and ongoing technical support. During the year, FinCEN also provided communications support to Albania, Argentina, Bahrain, Brazil, Egypt, Georgia, Guatemala, Indonesia, Israel, Lebanon, Macau, Marshall Islands, Mauritius, Mexico, Montenegro, Panama, Philippines, Russia, Serbia, South Africa, Turkey, United Arab Emirates, and Ukraine.
During 2003, the Bureau of Immigration and Customs Enforcement (ICE), Financial Investigations Division, provided extensive money laundering, financial investigations and antiterrorist financing training to domestic and foreign law enforcement organizations, and to the regulatory, banking and trade communities. ICE money laundering and financial investigations training is based on the broad experience achieved while conducting international money laundering and traditional financial investigations techniques as part of the U.S. Customs Service (USCS) legacy. Additionally, ICE conducted antiterrorist financing training in 2003, which drew on similar expertise obtained during the USCS-led Operation Green Quest.
ICE conducted training at 56 domestic and international money laundering and financial investigations seminars which focused on the traditional patterns and trends identified on trade-based money laundering schemes, bulk-cash smuggling, Black Market Peso Exchange (BMPE) investigations, alternative money remittance systems and trafficking in humans. Under the ICE Cornerstone Program, training was also developed and designed to provide the private sector with the necessary skills to identify and develop methodologies to detect suspect transactions indicative of money laundering and criminal activity within the financial and trade sectors. Moreover, as part of Cornerstone, ICE has appointed field and headquarters agents who are dedicated to providing training to the financial and trade communities on identifying and preventing exploitation by criminal and terrorist groups. Through its partnership with private industries, Cornerstone has enlisted their participation in aggressive joint efforts to combat financial crime and strengthen money laundering laws and regulations.
ICE provided international training, technical assistance and instruction on conducting anti-money laundering, financial crimes and terrorist finance investigations to officials from over 160 countries worldwide. The ICE Financial Investigations Division participated in international training in coordination with the Department of State Bureau of International Narcotics and Law Enforcement Affairs (INL), the Department of Justice's Prosecutorial Development and Assistance and Training Program (OPDAT), and the International Law Enforcement Academy (ILEA) programs.
Additional financial investigations training of law enforcement officers from 11 Central and South American countries was conducted by ICE in support of the Organization of American States' Inter-American Drug Abuse Control Commission (OAS/CICAD) program. Other ICE international training in conjunction with the State Department and the Department of the Treasury was provided to countries of special interest to the U.S. regarding terrorist financing on anti-money laundering/antiterrorist financing. ICE provided courses on trade-based money laundering in Kuwait and Qatar.
In 2003, the IRS Criminal Investigation Division (IRS-CI) continued its commitment to international training, multi-agency training efforts and technical assistance programs to foreign law enforcement agencies. Training included financial investigative techniques, anti-money laundering/asset forfeiture, counterterrorism financing and the financial underpinnings of terrorism.
IRS-CI provides financial expertise in support of the International Law Enforcement Academies (ILEAs) in Bangkok, Thailand; Budapest, Hungary; and Gaborone, Botswana, by providing training in Financial Investigative Techniques/Anti-Money Laundering and Counter-Terrorism Financing. An IRS-CI special agent continues to serve as Deputy Director of the ILEA in Bangkok. The IRS-CI also serves as coordinator of the annual Complex Financial Investigations course, which is provided to a wide variety of foreign senior, mid-level, and first-line law enforcement supervisors, inspectors, investigators, prosecutors and customs officers.
IRS-CI delivered Anti-Money Laundering/Financial Investigative Techniques courses in Santiago, Chile, and Prague, Czech Republic. In Prague, the participants were ministerial financial investigators, supervisors and prosecutors, who are responsible for enforcing their country's money laundering laws. In Santiago, students included uniformed police, intelligence analysts, supervisors and prosecutors from the financial and organized crime unit. The overall goal of this training was to enhance anti-money laundering efforts and to foster exchange of information between these countries and the U.S. to combat global money laundering. IRS-CI presented a Financial Investigative Techniques course to participants from the Inland Revenue Board, Securities Board, Finance Ministry, Treasury and Customs in Kuala Lumpur, Malaysia. This class was also facilitated by the IRS's Tax Administration Advisory Services. In addition to teaching financial techniques for investigating tax and other financial crimes, this course helped to foster on-going exchange of information among the different government agencies represented during the three-week training session.
IRS-CI undertook several training commitments as part of the Plan Colombia initiative in the Southern Hemisphere. Anti-Money Laundering, Undercover Techniques and Financial Investigative Techniques courses were delivered to federal agents, military policy and intelligence officers, tax authority officials, judges and magistrates in the Colombian cities of Bogot�, Medellin and Paipa. The thrust of the training continues to stress the compelling need for the use of these techniques to destroy the financial underpinnings of Colombia's narcotics/terrorists threat. These courses allowed participants to establish relationships designed to improve joint investigations of money laundering and terrorist finance activities. In other activity, Colombian computer forensic investigators traveled to the United States to participate in a two-week Computer Forensic Investigation Specialists course at IRS-CI's new Electronic Crimes Development Center in Springfield, Virginia. The crux of the training involved recovery of seized computer data, its presentation and identification of Internet and other electronic issues relevant to financial investigations.
IRS-CI also assisted the FBI at a Financial Underpinnings of Terrorism course in Quantico, Virginia, presented to high-level prosecutors and national police from the Republic of Turkey. The participants in the course came from Turkish anti-money laundering and antiterrorism investigation units.
IRS-CI assisted during a one-week course on Counter-Terrorism Financing/Anti-Money Laundering in Abu Dhabi and Dubai, United Arab Emirates. Participants from the UAE Public Prosecutor's office, Department of Justice, Ministries of Interior, Justice, Economy and Finance, Bahrain, along with the Police and Central Bank, completed the course. Counter-Terrorism Financing/Money Laundering courses were also conducted in Brasilia, Bogot�, and in Kuala Lumpur. All of these IRS-CI training sessions were conducted in partnership with the FBI.
As a part of a larger Department of State initiative, IRS-CI has been instrumental in assisting the Government of Trinidad and Tobago (GOTT) as part of an agreement with the IRS's Tax Administration Advisory Services project for technical assistance. IRS-CI's role was to assist with the development of a Criminal Tax Investigation Unit within the Trinidadian Bureau of Inland Revenue. The newly formed unit was created primarily to improve the level of tax compliance through the development of modern criminal tax enforcement methods, techniques and programs. IRS-CI has assisted in the analysis of the current laws and statues over which the unit will have authority to investigate and has also recommended law changes to enhance the authority of the unit.
The Office of the Comptroller of the Currency (OCC) supported and sponsored several anti-money laundering training initiatives during 2003. These included:
Training and Technical Assistance
During 2003, the Justice Department's OPDAT and AFMLS continued to provide training to foreign prosecutors, judges and law enforcement, and assistance in drafting money laundering statutes compliant with international standards.
Money Laundering/Asset Forfeiture
The seminars provided by OPDAT and AFMLS enhance the ability of participating countries to prevent, detect, investigate, and prosecute money laundering, and to make appropriate and effective use of asset forfeiture. The content of individual seminars varies depending on the specific needs of the participants, but topics addressed in 2003 included developments in money laundering legislation and investigations, complying with international standards for an anti-money laundering/terrorist financing regime, illustrations of the methods and techniques to effectively investigate and prosecute money laundering, inter-agency cooperation and communication, criminal and civil forfeiture systems, the importance of international cooperation, and the role of prosecutors. In 2003, in-depth sessions on money laundering and international asset forfeiture were presented to representatives from Thailand, South Africa, Suriname, Argentina, Dominican Republic, Canada, Netherlands, Malaysia, Costa Rica, France, Greece, Bosnia, Hungary, Uzbekistan, and Kazakhstan An AFMLS attorney worked with the RLA in Kosovo to assist the government in drafting its first money laundering law. In 2003 the RLA worked as Chief of the Special Information and Operations Unit at DOJ/UNMIK to help implement the new law.
As part of Plan Colombia, in 2003 OPDAT continued to provide assistance to enhance the capability of Colombia's National Asset Forfeiture and Money Laundering Task Force to investigate and prosecute money laundering and other complex financial crimes, and to execute the forfeiture of profits from illegal narcotics trafficking and other crimes.
During 2003, OPDAT organized a number of seminars for foreign students on transnational or organized crime, which included such topics as corruption, money laundering, implementing complex financial investigations and special investigative techniques within a task force environment, international standards, legislation, mutual legal assistance, and effective investigation techniques.
In March 2003, a "Multi-disciplinary Workshop on the Courtroom Presentation of DNA/Forensic Evidence" was held in Belize to strengthen the country's ability to combat transnational organized crime.
In addition to its Resident Legal Advisor (RLA) in South Africa, OPDAT in 2003 assigned an Intermittent Legal Advisor (ILA) to assist the South African National Director of Public Prosecutions in implementing its new organized crime statute.
In Ukraine, OPDAT's grantee, the American University Transnational Crime Study and Corruption Centers, supported indigenous research and conducted training seminars on economic crimes and organized crime.
OPDAT RLAs continue to support Bosnia's Organized Crime Anti-Human Trafficking Strike Force and Serbia and Montenegro's judges, prosecutors and police through mentoring and training programs on investigating and developing organized crime case strategies.
In 2003, OPDAT organized a series of six training programs on anti-corruption in Mexico City to enhance law enforcement capabilities in investigating and prosecuting public corruption. The training covered organization of an anti-corruption unit, prosecutorial strategies, the role and techniques of financial and criminal fraud investigations and rules of conduct for police.
OPDAT sent teams of attorneys to Mozambique again in 2003 to provide assistance to its Prosecution Service on the skills needed in the investigation and prosecution of corruption cases. OPDAT has two major programs in Nigeria, including one exclusively focused on supporting Nigeria's nascent anti-corruption commission.
In 2003, OPDAT's RLA in Georgia continued to work closely with the Anti-Corruption Coordinating Council to implement recommendations for improving anti-corruption efforts. The RLA who arrived in Moldova in June 2003 completed a review of Moldova's current public corruption legislation to identify needed revisions. In 2003, OPDAT, through anti-corruption workshops and seminars, provided Estonian and Hungarian prosecutors with the team-building skills necessary to more effectively combat public corruption and financial crimes.
OPDAT and AFMLS have intensified their efforts since 2001 to assist countries in developing their legal infrastructure to combat terrorism and terrorist financing. OPDAT and AFMLS, with the assistance of the Counterterrorism Section and other Department of Justice (DOJ) components, play a central role in providing technical assistance to foreign counterparts both to attack the financial underpinnings of terrorism and to build legal infrastructures to combat it. In this effort OPDAT and AFMLS work as integral parts of the U.S. Interagency Working Group on Terrorist Financing, and in partnership with the Departments of State, Treasury and Commerce, and several other DOJ components.
In 2003, OPDAT assigned overseas the first of several Resident Legal Advisors supported by the Interagency Working Group on Terrorist Financing. RLAs are U.S. federal prosecutors who provide long-term technical assistance to improve the skills, efficiency and professionalism of foreign criminal justice systems. Typically, RLAs live in a country for one or two years to work with ministries of justice, prosecutors and the courts. To promote reforms in the criminal justice system, RLAs provide assistance in legislative drafting, modernizing institutional policies and practices, and training law enforcement personnel including prosecutors and judges, police and other investigative or court officials.
RLAs living in a country where terrorist cells may exist, or where terrorist activity or the financing of terrorists is suspected, focus on money laundering and financial crimes and developing antiterrorism legislation which criminalizes terrorist acts, terrorist financing, and the provision of material support to terrorist organizations. They also develop technical assistance programs for prosecutors, judges and, in collaboration with DOJ's International Criminal Investigative Training Assistance Program, police investigators to assist in the implementation of new money laundering and terrorist financing procedures.
In August 2003, OPDAT sent the first counter terrorism RLA to Paraguay to work on financial crimes and money laundering issues in the Tri-border area of Paraguay, Brazil, and Argentina. In October 2003, the RLA organized a number of conferences to finalize a draft anti-money laundering law, which was to be presented to the Paraguayan legislature in early 2004. Also in 2003, OPDAT's RLA in Azerbaijan assisted in drafting money laundering legislation and implementing programs aimed at deterring terrorist financing. OPDAT has specific plans to place RLAs in other key countries around the world.
In March 2003, OPDAT held a money laundering seminar for prosecutors, banking officials and investigators in Qatar and in December 2003 an asset forfeiture program was conducted in Malaysia.
During the period 2002 to mid-2003, OPDAT organized eight seminars aimed at strengthening counterterrorism laws abroad. Officials from Central Asia, the Middle East, the Caucasus and Russia, Southeast Asia, South Asia, Latin America and Africa, participated in seminars focused on counterterrorism legislation. AFMLS and other U.S. agencies provided instructors for each of the courses. Country groups worked with U.S. experts during the seminar to develop action plans to strengthen their countries' counterterrorism infrastructures. Training participants came from Angola, Armenia, Azerbaijan, Bangladesh, Botswana, Chile, Cote d'Ivoire, Cyprus, Democratic Republic of the Congo, Djibouti, El Salvador, Egypt, Georgia, Guatemala, Guyana, India, Indonesia, Jordan, Kazakhstan, Kenya, Kyrgyzstan, Laos, Lesotho, Malawi, Malaysia, Maldives, Mauritius, Morocco, Mozambique, Namibia, Nepal, Pakistan, Paraguay, Peru, Philippines, Russia, Sierra Leone, South Africa, Sri Lanka, Swaziland, Tajikistan, Tanzania, Thailand, Turkey, United Arab Emirates, Uzbekistan and Zambia.
With the assistance of attorneys from AFMLS and the Counterterrorism Section, OPDAT implemented "The Financial Underpinnings of Terrorism Program," which provides intensive seminars covering all aspects of identifying and prosecuting methods of financing terrorism. An initial session for senior policy officials is followed by a longer, more hands-on session for investigators, judges and prosecutors. Officials from the Philippines and Turkey have participated in these programs.
OPDAT organized three training programs at the International Law Enforcement Academy (ILEA) in Budapest in 2003: Criminal Procedure and Trial Advocacy; Money Laundering and Terrorism Financing; and Combating Transnational Organized Crime. For each course, one of OPDAT's RLAs in the region took the organizational lead, drawing on expert faculty from the U.S., Europe and Asia.
AFMLS provides technical assistance in connection with legislative drafting on all matters involving money laundering, asset forfeiture and the financing of terrorism. During 2003, AFMLS provided such assistance to 14 countries as well as actively participating in the drafting of the UN Convention on Corruption and the terrorist financing provision of the OAS/CICAD Model Regulations. AFMLS continues to participate in the UN Working Group to draft a model non-conviction based asset forfeiture law. In 2003, AFMLS provided technical assistance to Albania, Algeria, Armenia, Pakistan, Indonesia, Philippines, Paraguay, Kosovo, Chile, Turkey, Kenya, Republic of Korea, Thailand and Argentina.
During 2003, AFMLS and OPDAT participated in four Financial Systems Assessment Teams (FSAT) led by the Department of State's Coordinator for Counterterrorism Office and the Bureau of International Narcotics and Law Enforcement Affairs. These teams traveled to three countries at to assess the capacities and skills of prosecutors and judges, and the criminal justice system in general, to effectively address terrorist financing.
Treasury's OTA is located within the Office of the Assistant Secretary for International Affairs. The office delivers interactive, advisor-based assistance to senior level representatives in various ministries and Central Banks in the areas of tax reform, government debt issuance and management, budget policy and management, financial institution reform, and more recently, law enforcement reforms related to money laundering and other financial crimes.
In 1997, the Enforcement Program was added to Treasury's advisory office. It is a long-term, advisor-based program developed out of concern that financial crimes, corruption, organized criminal enterprises, and other criminal activities were undermining economic reforms promoted by the U. S. Government. The Enforcement Program focuses on the development of legal foundations, policies, and organizations in three areas: (1) money laundering, terrorist financing and other financial crimes, (2) organized crime and corruption, and (3) the reorganization of law enforcement and financial entities in developing economies to help them prevent, detect, investigate and prosecute complex international financial crime. The Enforcement Program relies on intermittent and resident advisors to deliver its technical assistance. It works with embassy staff and host country clients on long-term projects designed to promote systemic changes and new organizational structures. The program receives funding from the State Department's Bureau of International Narcotics and Law Enforcement Affairs (INL), the State Department Africa Bureau, USAID country missions and direct appropriations from the U.S. Congress.
The Enforcement Program is comprised of a group of experienced advisors with backgrounds in various areas of investigating, prosecuting or regulating financial and economic crimes, such as money laundering, terrorist financing, white-collar crime, organized crime, securities fraud, internal affairs and corruption, criminal law, and organization administration. In 2003, advisors provided assistance to the governments of Albania, Armenia, Azerbaijan, Bosnia, Bulgaria, El Salvador, Ethiopia, Georgia, Guatemala, Honduras, Hungary, Iraq, Macedonia, Moldova, Montenegro, Morocco, Paraguay, Poland, Peru, Romania, Russia, Sri Lanka, Tanzania, Thailand, Uganda, Ukraine, Serbia, Zambia and the Eastern Caribbean countries. OTA's Enforcement advisor in Iraq successfully completed examinations of all the commercial banks in the country and provided compliance guidelines for the Central Bank.
OTA conducted several assessments of anti-money laundering regimes in 2003, often working in concert with the U.S. Embassies, other U.S. Government agencies and/or international bodies. These assessments addressed legislative, regulatory, law enforcement and judicial components of the various programs. The assessments included the development of technical assistance plans to enhance a country's efforts to fight money laundering and terrorist financing. In 2003, such assessments were carried out in Argentina, Chile, Ecuador, Ethiopia, Sri Lanka, Zambia and Morocco.
The OTA Enforcement program has the ability to draw expertise from the other four "teams" in OTA. In Afghanistan, a Budget team advisor is resident with the Ministry of Finance to insure that a transparent budget is maintained for the donor funds flowing into the Afghanistan reconstruction. Financial Institution team advisors have been utilized in the Dominican Republic to assist in the bank resolution of a major bank, insolvent because of massive insider fraud. Tax advisors are employed in the creation of criminal investigation units within tax services in Croatia, and Government Debt advisors are used to design compliant stock exchanges and government securities in Uganda. This synergy within OTA's five teams allows for a macroeconomic approach to financial crimes enforcement.
In 2003 a variety of training was the primary focus of OTA efforts in a number of countries around the world. In Africa, OTA specialists tailored a special course for Ethiopia bank examiners, conducted two training sessions in Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) for Moroccan government, banking and private sector officials, and trained over 300 Ugandans in eight different seminars relating to financial crimes and corruption investigation techniques. In Europe, OTA taught basic principals of financial investigation techniques to specialized Bosnian police; in Bulgaria, the relevant task force learned fundamentals of investigating and prosecuting financial crimes, and in Armenia, OTA conducted a "train-the-trainer" program on auditing techniques for concerned officials. Elsewhere in Europe, working with FinCEN, OTA conducted a weeklong course in financial and business records analysis for analysts from the Hungarian Financial Intelligence Unit (FIU). In Poland, FIU employees and partner ministry officials received four AML/CFT courses, the new financial police unit in Macedonia was instructed in the basics of anti-money laundering techniques, and Romanian prosecutors, judges and bank examiners were trained in combating money laundering and bank fraud. Structured OTA training in South America included a "train-the-trainer" module for Honduran bank officials and special investigative techniques for Honduran police.
Support for Financial Intelligence Units (FIUs)
OTA continued its range of training and technical support for the refinement and establishment of Financial Intelligence Units (FIUs) in various regions of the world. In 2003, the primary focus was on Georgia, Bulgaria, Hungary, Montenego, Russia, Serbia, Thailand, Guatemala, Honduras and Ukraine. In Serbia, for example, OTA experts undertook a variety of initiatives, including training for relevant public and private entities, to help the country establish an FIU and get it operational prior to its eventual application for membership to the Egmont Group. Similar assistance was provided to the Russian FIU. In Ukraine, OTA continued efforts to help streamline the national FIU to include relevant improvements in its operation to help Ukraine reach its goal of removal from the FATF list of noncooperative countries. In Central America, additional training and technical assistance was provided to FIUs in Guatemala and Honduras, and a resident advisor was placed with the FIU's in Peru and Paraguay.
Resident Advisor Program