During 2008, a number of U.S. law enforcement and regulatory agencies provided training and technical assistance on money laundering countermeasures and financial investigations to their counterparts around the globe. These courses have been designed to give financial investigators, bank regulators, and prosecutors the necessary tools to recognize, investigate, and prosecute money laundering, financial crimes, terrorist financing, and related criminal activity. Courses have been provided in the United States as well as in the jurisdictions where the programs are targeted.
The U.S. Department of State’s Bureau of International Narcotics and Law Enforcement (INL) Crime Programs Division helps strengthen criminal justice systems and the abilities of law enforcement agencies around the world to combat transnational criminal threats before they extend beyond their borders and impact our homeland. Through its international programs, as well as in coordination with other INL offices and U.S. Government (USG) agencies, the INL Crime Programs Division addresses a broad cross-section of law enforcement and criminal justice sector areas including: counternarcotics; drug demand reduction; money laundering; financial crime; terrorist financing; smuggling of goods; illegal migration; trafficking in persons; domestic violence; border controls; document security; corruption; cyber-crime; intellectual property rights; law enforcement; police academy development; and assistance to judiciaries and prosecutors.
INL and the State Department’s Bureau of Counterterrorism (S/CT) co-chair the interagency Terrorist Finance Working Group (TFWG), and together are implementing a multi-million dollar training and technical assistance program designed to develop or enhance the capacity of a selected group of more than two dozen countries whose financial sectors have been used, or are vulnerable to being used, to finance terrorism. As is the case with the more than 100 other countries to which INL-funded training was delivered in 2008, the capacity to thwart the funding of terrorism is dependent on the development of a robust anti-money laundering regime. Supported by and in coordination with the U.S. Department of State, U.S. Department of Justice (DOJ), U.S. Department of Homeland Security (DHS), U.S. Department of the Treasury, the Federal Deposit Insurance Corporation, and various nongovernmental organizations, TFWG provided in 2008 a variety of law enforcement, regulatory and criminal justice programs worldwide. This integrated approach includes assistance with the drafting of legislation and regulations that comport with international standards, the training of law enforcement, the judiciary and bank regulators, as well as the development of financial intelligence units (FIUs) capable of collecting, analyzing, and disseminating financial information to foreign analogs. Courses have been provided in the United States as well as in the jurisdictions where the programs are targeted.
Nearly every federal law enforcement agency assisted in this effort by providing basic and advanced training courses in all aspects of financial criminal investigation. Likewise, bank regulatory agencies participated in providing advanced AML/CTF training to supervisory entities. In addition, INL made funds available for the intermittent or full-time posting of legal and financial mentors 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 to combat money laundering.
The State Department, in conjunction with DHS’ Immigration and Customs Enforcement (ICE) and the Department of Treasury, supports five trade transparency units (TTUs) in Latin America: three in the tri-border area of Brazil, Argentina, and Paraguay, one in Mexico, and one in Colombia. TTUs are entities designed to help identify significant disparities in import and export trade documentation and continue to enjoy success in combating money laundering and other trade-related financial crimes. The number of trade-based money laundering investigations emerging from TTU activity continues to grow. In 2008, Mexico’s TTUs investigated seven cases; Colombia, four; Paraguay, six; and Argentina, two. Similar to the Egmont Group of FIUs that examines and exchanges information gathered through financial transparency reporting requirements, an international network of TTUs would foster the sharing of disparities in trade data between countries and be a potent weapon in combating customs fraud and trade-based money laundering. Trade is the common denominator in most of the world’s alternative remittance systems and underground banking systems. Trade-based value transfer systems have also been used in terrorist finance.
The success of the Caribbean Anti-Money Laundering Program (CALP) convinced INL that a similar type of program for small Pacific island jurisdictions had the potential of developing viable AML/CTF regimes. Accordingly, INL funded the establishment of the Pacific Island Anti-Money Laundering Program (PALP) in 2005. The objectives of PALP are to reduce the laundering of the proceeds of all serious crime and the financing of terrorist financing by facilitating the prevention, investigation, and prosecution of money laundering. PALP’s staff of resident mentors provides regional and bilateral AML/CTF mentoring, training and technical assistance to the 14 Pacific Islands Forum countries that are not members of the Financial Action Task Force (FATF). The management of the program was transferred to the UN Global Program against Money Laundering from the Pacific Islands Forum in September 2008, as the PALP began its third year of operation. INL will provide a total of nearly $6 million for the four-year PALP project.
Including the $1.5 million for the management of the PALP, INL obligated $2.2 million to the UN Global Program against Money Laundering (GPML) in 2008. In addition to sponsoring money laundering conferences and providing short-term training courses, GPML instituted a unique longer-term technical assistance initiative through its mentoring program. The mentoring program provides advisors on a year-long basis to specific countries or regions. GPML mentors provided assistance to the Secretariat of the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG) and to Horn of Africa countries targeted by the U.S. East Africa Counterterrorism Initiative. GPML resident mentors provided country-specific assistance to the Philippines FIU and asset forfeiture assistance to Namibia, Botswana, and Zambia. The resident mentor based in Namibia provided legal inputs to amend relevant legislation in each country, and initiated and monitored the Prosecutor Placement Program, an initiative aimed at placing prosecutors from the region for a certain period of time within the asset forfeiture unit of South Africa’s national prosecuting authority. The GPML mentors in Central Asia and the Mekong Delta continued assisting the countries in those regions develop viable AML/CTF regimes. GPML continues to develop interactive computer-based programs, translated into several languages that are distributed to several regions globally.
INL continues to provide significant financial support for many of the anti-money laundering bodies around the globe. During 2008, INL supported FATF, the international AML/CTF standard setting organization. In addition to sharing mandatory membership dues to FATF and the Asia Pacific Group on Money Laundering (APG) with the U.S. Department of the Treasury and DOJ, INL is a financial supporter of FATF-style regional bodies (FSRBs) secretariats and training programs, including the Council of Europe’s MONEYVAL, the Caribbean Financial Action Task Force (CFATF), the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG) and the South American Financial Action Task Force, Grupo de Accion Financiera de Sudamerica Contra el Lavado de Activos (GAFISUD). In 2008, INL also provided funding to the secretariat of the West African FSRB, Groupe Intergovernmental d’Action contre le Blanchiment d’Argent en Afriique de l’Ouest (GIABA), and has provided funding to GPML to place a residential mentor in Dakar, Senegal, to assist those member states of GIABA that have enacted the necessary legislation to develop FIUs. INL also financially supported the Organization of American States (OAS) Inter-American Drug Abuse Control Commission (CICAD) Experts Group to Control Money Laundering and the OAS Counter-Terrorism Committee. In preparation for the April 2009 Summit of the Americas, INL provided funding to CICAD and CICTE to persuade and assist those Latin American countries that have yet to criminalize the financing of terrorism to do so.
As in previous years, INL training programs continue to focus on both interagency bilateral and multilateral efforts. When possible, we seek participation with our partner countries’ law enforcement, judicial and central bank authorities to design and provide training and technical assistance to countries with the political will to develop viable AML/CTF financing regimes. This allows for extensive synergistic dialogue and exchange of information. INL’s approach has been used successfully in Africa, Asia, the Pacific, Central and South America, the Newly Independent States 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.
International Law Enforcement Academies (ILEAs)
The mission of the regional International Law Enforcement Academies (ILEAs) is to support emerging democracies, help protect U.S. interests through international cooperation, and 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 fostered relationships between 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 the result of a united effort by all participants—government agencies and ministries, trainers, managers, and students—to achieve the common foreign policy goal of cohesive international law enforcement. This goal is to train professionals who will shape the future of the rule of law, human dignity, personal safety and global security.
The ILEAs are a progressive concept in the area of international assistance programs. Regional ILEAs offer three different types of programs. The core program, a series of 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 are comprised of about 30 participants and normally run one or two weeks long, often simultaneously with the core program. Lastly, there are regional seminars with different topics of interest, such as transnational crimes, financial crimes, and counterterrorism.
The ILEAs help to develop an extensive network of alumni who exchange information with their regional and U.S. counterparts and assist in transnational investigations. These graduates are also expected to be future leaders in their respective societies. The U.S. Department of State works with the U.S. Departments of Justice (DOJ), Homeland Security (DHS) and the Treasury, as well as with foreign governments to implement the ILEA programs. To date, the combined ILEAs have trained more than 28,000 officials from more than 75 countries in Africa, Asia, Europe and Latin America.
Africa. ILEA Gaborone (Botswana) opened in 2001. Its main feature is a six-week intensive personal and professional development program, the Law Enforcement Executive Development Program (LEEDP), designed for mid-level law enforcement managers. The LEEDP brings together approximately 40 participants from several nations for instruction in areas 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 counterparts to combat international criminal activities. These courses concentrate on specific methods and techniques in a variety of subjects, such as counterterrorism, anticorruption, 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, Zambia, Djibouti, Ethiopia, Kenya, Uganda, Nigeria, Cameroon, Comoros, Congo, the Democratic Republic of Congo, Gabon, Madagascar, Burundi, Rwanda, Sierra Leone, Ghana, Guinea, and Senegal.
U.S. and Botswana trainers provide instruction. ILEA Gaborone has offered specialized courses on money laundering and terrorist financing-related topics such as criminal investigation, presented by the Federal Bureau of Investigation (FBI) and international banking and financial forensics, presented by DHS and DHS’ Federal Law Enforcement Training Center (FLETC), and international money laundering schemes, presented by DHS’ Immigration and Customs Enforcement (ICE). ILEA Gaborone trains approximately 500 students annually.
Asia. ILEA Bangkok (Thailand) opened in March 1999. This ILEA focuses on enhancing 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 (SCIC), designed to strengthen management and technical skills for supervisory criminal investigators and other criminal justice managers. In addition, it also presents one senior executive-level program and about 18 specialized courses, each lasting one to two weeks, in a variety of criminal justice topics. The principal objectives of the ILEA are the development of effective law enforcement cooperation within the member countries of the Association of Southeast Asian Nations (ASEAN), East Timor, and China (including Hong Kong and Macau), and the strengthening of each country’s criminal justice institutions to increase its abilities to cooperate in the suppression of transnational crime.
Instruction is provided to participants from Brunei, Cambodia, East Timor, China, Hong Kong, Indonesia, Laos, Macau, Malaysia, Philippines, Singapore, Thailand, and Vietnam. Subject matter experts from the United States, Thailand, Japan, Netherlands, Philippines, and Hong Kong provide instruction. ILEA Bangkok has offered specialized courses on money laundering and terrorist financing-related topics such as computer crime investigations, presented by FBI and DHS, and complex financial investigations, presented by the Internal Revenue Service (IRS), FBI and, the Drug Enforcement Administration (DEA). ILEA Bangkok trains approximately 800 students annually.
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. 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, Georgia, Hungary, Kazakhstan, Kyrgyz Republic, Macedonia, Moldova, Montenegro, Romania, Russia, Serbia, Slovakia, Slovenia, Tajikistan, Turkmenistan, Ukraine, and Uzbekistan.
Trainers from 17 federal agencies and local jurisdictions from the United States, Hungary, Canada, Germany, United Kingdom, Netherlands, Ireland, Italy, Russia, Interpol, and the Council of Europe provide instruction. ILEA Budapest has offered specialized courses on money laundering and terrorist financing-related topics such as investigating and prosecuting organized crime and transnational money laundering, both presented by DOJ’s Office of Overseas Prosecutorial Development, Assistance, and Training (OPDAT). ILEA Budapest trains approximately 800 students annually.
Global. ILEA Roswell (New Mexico) opened in September 2001. It offers a curriculum comprised of courses similar to those provided at a typical criminal justice university or college. These three-week courses have been designed and are taught by academics for foreign law enforcement officials. This ILEA is unique in its format and composition with a strictly academic focus and a worldwide student body. The participants are middle- to senior-level law enforcement and criminal justice officials from Eastern Europe, Russia, the states of the former Soviet Union, 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 Caribbean, and Central and South American countries. The students are drawn from pools of ILEA graduates from the Academies in Bangkok, Budapest, Gaborone and San Salvador. ILEA Roswell trains approximately 350 students annually.
Latin America. ILEA San Salvador (El Salvador) opened in 2005. Its training program is similar to the ILEAs in Bangkok, Budapest and Gaborone. It offers a six-week Law Enforcement Management Development Program (LEMDP) for law enforcement and criminal justice officials as well as specialized courses for police, prosecutors, and judicial officials. In 2009, ILEA San Salvador will deliver four LEMDP sessions and approximately 20 specialized courses that will concentrate on attacking international terrorism, illegal trafficking in drugs, alien smuggling, terrorist financing, and financial crimes investigations. Segments of LEMDP focus on terrorist financing, presented by the FBI, and financial evidence and money laundering application, presented by FLETC and IRS. Instruction is provided to participants from: Antigua and Barbuda, Argentina, Barbados, Bahamas, Belize, Bolivia, Brazil, Chile, Colombia, Costa Rica, Dominica, Dominican Republic, Ecuador, El Salvador, Grenada, Guadeloupe, Guatemala, Guyana, Haiti, Honduras, Jamaica, Martinique, Mexico, Nicaragua, Panama, Paraguay, Peru, St. Kitts and Nevis, St. Vincent, St. Lucia, Suriname, Trinidad and Tobago, Uruguay, and Venezuela. ILEA San Salvador trains approximately 800 students per year
The ILEA Regional Training Center in Lima (Peru) opened in 2007 to complement the mission of ILEA San Salvador. The center augments the delivery of region-specific training for Latin America and concentrates on specialized courses on critical topics for countries in the southern cone and Andean regions. The RTC trains approximately 300 students per year.
An important component in the United States’ efforts to combat and deter money laundering and terrorist financing is to verify that supervised organizations comply with the Bank Secrecy Act (BSA) and have programs in place to comply with the Office of Foreign Assets Control (OFAC) sanctions. In 2008, the FRB conducted training and provided technical assistance to bank supervisors and law enforcement officials in anti-money laundering (AML) and counterterrorist financing (CTF) tactics in partnership with regional supervisory groups or multilateral institutions, including the Middle East and North Africa (MENA) Financial Regulator’s Training Initiative. The FRB also provided seminars in Anti-Money Laundering Examination and workshops in the Fundamentals of Fraud. Officials from Albania, Bahamas, Bolivia, Chile, Croatia, Czech Republic, Dominican Republic, Ecuador, Ghana, Guatemala, Haiti, Honduras, Hong Kong, India, Indonesia, Israel, Japan, Korea, Lebanon, Mexico, Morocco, Nigeria, Panama, Paraguay. Peru, Philippines, Qatar, Russia, Turkey, Venezuela, and Zambia attended one or both of these events.
Due to the importance that the FRB places on international standards, the FRB’s AML experts participate regularly in the U.S. delegation to the Financial Action Task Force (FATF) and the Basel Committee’s AML/CTF expert group. The FRB is also an active participant in the U.S. Treasury Department’s ongoing Private Sector Dialogue conferences, attending the Latin American session in Brazil and the Baltics meeting in Lithuania this year. Staff also meets frequently with industry groups and foreign supervisors to support industry best practices in this area.
The FRB presented training courses on ‘International Money Movement’ to domestic law enforcement agencies, including the Department of Homeland Security’s Bureau for Immigration and Customs Enforcement (DHS/ICE), as well as at the Federal Law Enforcement Training Center (FLETC) during 2008.
During 2008, with the assistance of U.S. Department of State (DOS) funding, the U.S. Federal Bureau of Investigation (FBI) continued its extensive international training in combating terrorist financing, money laundering, financial fraud, and complex financial crimes, as well as training in conducting racketeering enterprise investigations. One such training program is the FBI’s International Training and Assistance Unit (ITAU), located at the FBI Academy in Quantico, Virginia. ITAU coordinates with the Terrorist Financing and Operations Section (TFOS) of the FBI’s Counterterrorism Division (CTD), as well as other divisions at FBI headquarters and in the field, to provide instructors for these international initiatives. FBI instructors, who are most often intelligence analysts, operational Special Agents (SAs) or Supervisory Special Agents (SSAs), rely on their experience to relate to the international law enforcement students as peers and partners in the training courses.
The FBI regularly conducts training through the International Law Enforcement Academies (ILEA) in Bangkok, Thailand; Budapest, Hungary; Gaborone, Botswana; and San Salvador, El Salvador. In 2008, the FBI delivered training in white collar crime investigations to 216 students from 16 countries at ILEA Budapest. At ILEA Bangkok, the FBI provided training to 60 students from Thailand in the Supervisory Criminal Investigators Course (SCIC). At ILEA Gaborone, the FBI provided antiterrorist financing training to 161 students from 22 African countries. At ILEA San Salvador, the FBI provided antiterrorist financing training to 120 students from El Salvador, Brazil, Paraguay, Peru, Uruguay, Colombia, Ecuador, Costa Rica, Guatemala, and Honduras.
In 2008, the FBI also conducted trainings, in conjunction with other U.S. agencies, for officials from Serbia, Macedonia, Morocco, Philippines, Paraguay, Algeria, Tanzania and Senegal. One such training involved FBI participation in an anti-money laundering conference in Serbia that the U.S. Department of Justice’s Office of Overseas Prosecutorial Development (OPDAT) delivered to 100 students. Another involved FBI participation in an anti-money laundering workshop in Macedonia that OPDAT delivered to 35 students. Also in 2008, the FBI conducted, jointly with the Internal Revenue Service’s (IRS) Criminal Investigative Division (CID), a one-week course on combating terrorist financing and money laundering for 181 international students from Morocco, Philippines, Paraguay, Algeria, Tanzania, and Senegal.
At the FBI Academy, the FBI included blocks of instruction on combating terrorist financing and/or money laundering for 18 students participating in Session #12 of the Latin American Law Enforcement Executive Development Seminar (LALEEDS); the students were from Colombia, Ecuador, Paraguay, Argentina, Uruguay, Costa Rica, Nicaragua, Panama, Belize, El Salvador, Guatemala, Honduras, Chile, Bolivia, and the Dominican Republic. The FBI included similar blocks of instruction for 14 students participating in Session #3 of the Arabic Language Law Enforcement Executive Development Seminar (ALLEEDS); these students were from Djibouti, Egypt, Jordan, Morocco, Qatar, Sudan, the United Arab Emirates (UAE) and Yemen. As part of the FBI’s Pacific Training Initiative’s (PTI) Session #21, the FBI included terrorist financing instruction for 53 participants from 13 countries: Thailand, China, Australia, Hong Kong, Pakistan, Indonesia, Malaysia, Philippines, India, Korea, Singapore, Japan and the United States (Honolulu).
In 2008, the Federal Deposit Insurance Corporation (FDIC) continued to work in partnership with several federal agencies and international groups to combat money laundering and inhibit the flow of terrorist funding through training and outreach initiatives. In partnership with the U.S. Department of State, the FDIC hosted three anti-money laundering and counter financing of terrorism (AML/CTF) training sessions for 49 representatives from Jordan, Kuwait, Paraguay, Qatar, Saudi Arabia, Senegal, Thailand, and the West Africa Central Bank. The training sessions included discussions on the AML examination process, customer due diligence, and foreign correspondent banking risks and controls.
During the year, the FDIC also met with supervisory and law enforcement representatives from 15 countries to discuss AML issues, including examination policies and procedures, the USA PATRIOT Act, suspicious activity reporting requirements, and government information sharing mechanisms. Those countries included: Afghanistan, Chile, Ghana, Haiti, Japan, Laos, Madagascar, Malawi, Mongolia, Nigeria, Pakistan, Syria, Tanzania, Timor-Leste, and Ukraine.
Additionally, the FDIC traveled to Uruguay to provide AML/CTF training to approximately 40 regulators from the Banco Central del Uruguay. The session focused upon AML examination procedures and the AML risk assessment process expected of domestic depository institutions. Separately, an overview of the FDIC’s role as a regulator and supervisor was presented to approximately 100 Uruguayan bankers and government officials.
To compliment the FDIC’s strong AML/CTF training commitment, the FDIC participated in the second annual U.S.-Latin American Private Sector Dialogue in Miami, Florida. This U.S. Department of the Treasury initiative provides a forum for discussion among U.S. and Latin American banks about common issues related to money laundering and terrorist financing. The FDIC also participated in a seminar focusing on Islamic banking hosted by Perbadanan Insurans Deposit Malaysia (PIDM) in Kuala Lumpur, Malaysia.
The FDIC has eight full-time subject matter experts in the Washington, D.C., office dedicated to AML/CTF initiatives as well as a group of 28 individuals available to assist the U.S. Government (USG) with AML/CTF Financial System Assessments.
The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury and is the U.S. financial intelligence unit (FIU). It participates and promotes international collaboration and information sharing to detect and deter illicit financial activities and helps other countries develop their FIUs, which is a valuable component of a country’s anti-money laundering and counterterrorist financing (AML/CTF) regime. FinCEN coordinates and provides training and technical assistance to foreign nations seeking to improve their capabilities to combat money laundering, terrorist financing, and other financial crimes. FinCEN’s international training program has two primary focuses: (1) instruction and presentations to a broad range of government officials, financial regulators, law enforcement officers, and others on the subjects of money laundering, terrorist financing, financial crime, and on FinCEN’s mission and operation; and (2) individualized training to FIU counterparts regarding FIU operations, analytical training via personnel exchanges and FIU development seminars. Much of FinCEN’s work involves strengthening existing FIUs and the channels of communication used to share information to support anti-money laundering investigations. In support and assistance to other FIUs, FinCEN participates in personnel exchanges (from a foreign FIU to FinCEN and vice versa); supports delegation visits to foreign FIUs and other agencies from the intelligence, regulatory and law enforcement communities; and coordinates regional workshops.
In 2008, FinCEN hosted representatives from approximately 47 countries, including general orientations and consultations under the auspices of the U.S. Department of State’s International Visitor Leadership Program, International Law Institute’s Anti-Corruption Seminar, and the World Bank Program for Leadership in Financial Market Integrity. These visits, typically lasting one to three days, focused on topics such as money laundering trends and patterns, the Bank Secrecy Act, USA PATRIOT ACT, communications systems and databases, case processing, and the goals and mission of FinCEN. Representatives from foreign financial and law enforcement sectors generally spend one to two days at FinCEN learning about money laundering, the U.S. AML regime and reporting requirements, the national and international roles of an FIU, and various additional topics.
FinCEN gives assistance to new or developing FIUs that are not yet members of the Egmont Group of FIUs. The Egmont Group is comprised of FIUs that cooperatively agree to share financial intelligence and has become the standard-setting body for FIUs. FinCEN hosts FIU orientation visits and provides training and mentoring on FIU development. In 2008, FinCEN hosted representatives from Afghanistan, Tanzania, and Cameroon’s nascent FIUs for orientation visits. These visits included an overview on various aspects of developing an FIU such as the legal framework in which the FIU operates, an FIU’s international role and its cooperation with other FIUs, and an overview of Egmont Group request processing and information sharing.
For those FIUs that are fully operational, FinCEN’s goals are to assist the unit in increasing effectiveness, improve the unit’s information sharing capabilities, and expand the unit’s understanding of money laundering and terrorist financing. As a member of the Egmont Group, FinCEN works closely with other member FIUs to provide training and technical assistance to countries and jurisdictions interested in establishing their own FIUs and obtaining candidacy for membership in the Egmont Group. FinCEN is currently sponsoring FIUs from ten jurisdictions for Egmont Group membership: Afghanistan, China, Jordan, Kuwait, Oman, Pakistan, Saudi Arabia, Suriname, Tanzania, and Yemen. Additionally, FinCEN works multilaterally through its representative on the Egmont Training Working Group to design, implement, and co-teach Egmont-sponsored regional training programs for Egmont Group members as well as Egmont candidate FIUs.
In addition to hosting delegations for training on FinCEN premises, FinCEN conducts training courses and seminars abroad, both independently and in conjunction with other domestic and foreign agencies, counterpart FIUs, and international organizations. Occasionally, FinCEN’s training and technical assistance programming is developed jointly with these other agencies to address specific needs of the jurisdiction or country receiving assistance. Such trainings provide trainees with improved knowledge and understanding of topics related to money laundering and terrorist financing, which include topics such as: FIU primary and secondary functions, regulatory issues, international case processing procedures, technology infrastructure and security, and terrorist financing and money laundering trends and typologies. In 2008, FinCEN conducted training seminars in Nigeria, Kuwait, Kazakhstan, Uzbekistan, and Afghanistan. The training focused on enhancing the capacity and cooperation of FIUs to combat money laundering and the financing of terrorism.
FinCEN conducts core analytical training to counterpart FIUs, both at FinCEN and abroad, and often in conjunction with other U.S. agencies. FinCEN’s analytical training program, typically delivered over the course of one to two weeks, provides foreign analysts with basic skills in critical thinking and analysis; data collection; database research; suspicious transactions analysis; the intelligence cycle; charting; data mining; and case presentation. In 2008, FinCEN collaborated with Mexico’s FIU and provided training on basic analytical skills to FIUs from Mexico, Belize, Guatemala, El Salvador, Panama, Honduras, and Colombia. Over the past twelve months, in an effort to reinforce the sharing of information among established Egmont member FIUs, FinCEN conducted personnel exchanges with Egmont Group members from Latvia, Mexico, South Africa, Australia, Netherlands, the United Kingdom, Canada, and Korea. These exchanges offer the opportunity for FIU personnel to see first-hand how other FIUs operates; to develop joint analytical projects and other strategic initiatives; and also to work jointly on on-going financial crimes cases. The participants in these exchanges share ideas, innovations, and insights that lead to improvements in such areas as analysis, information flow, and information security at their home FIUs, in addition to deeper and more sustained operational collaboration.
During 2008, the U.S. Department of Homeland Security’s (DHS) Immigration and Customs Enforcement (ICE), Financial, Narcotics and Public Safety Division, in conjunction with the DHS Office of International Affairs, delivered training to law enforcement, regulatory, banking, and trade officials from more than 60 countries to combat money laundering, terrorist financing, and bulk cash smuggling, and to conduct financial investigations. The training was conducted in both bilateral and multilateral engagements. ICE money laundering and financial investigations training is based on the broad experience and expertise achieved by leading U.S. efforts in investigating international money laundering and financial crimes as part of the former U.S. Customs Service.
Bulk Cash Smuggling
Using primarily U.S. Department of State funding, ICE provided bilateral and multilateral training and technical assistance on the interdiction and investigation of bulk cash smuggling (BCS) for 390 officials from 30countries. Notably, ICE conducted two BCS training conferences in Iraq for more than 65 Iraqi security and police forces. ICE also provided basic BCS training in the Argentina, Malaysia, Indonesia, Thailand, Egypt, Nigeria, Mauritania, and Georgia.
ICE, with the participation of Australian officials, conducted a regional training program for three countries that had completed the basic and advanced BCS modules BCS: the Philippines, Malaysia, and Indonesia. This week-long regional program was intended to encourage participating countries to share information with counterpart agencies in neighboring countries. Thailand, which has received only the basic BCS course, participated in the training as an observer. ICE also conducted BCS training in Amman, Jordan, to officials from 11 member states of the Middle East and North Africa Financial Action Task Force (MENA-FATF), including Lebanon, Egypt, Kuwait, Yemen, Oman, Algeria, Qatar, Mauritania, Morocco, Tunisia, and Jordan. Officials from the Palestinian Authority also attended this conference.
Through the U.S. Department of State’s International Law Enforcement Academy (ILEA) programs, ICE conducted in 2008 more than 50 financial investigations and anti-money laundering training programs for more than 755 participants. The participants represented law enforcement personnel from 69 countries.
Trade Transparency Units (TTUs)
Trade Transparency Units (TTUs) identify anomalies related to cross-border trade that are indicative of international trade-based money laundering. TTUs generate, initiate, and support investigations and prosecutions related to trade-based money laundering, the illegal movement of criminal proceeds across international borders, alternative money remittance systems, and other financial crimes. By sharing trade data, ICE and participating foreign governments are able to see both sides of import and export transactions for commodities entering or exiting their countries, thus assisting in the investigation of international money laundering organizations
With funding from the U.S. Department of State’s Bureau of International Narcotics and Law Enforcement (INL), ICE worked to expand the network of operational TTUs beyond Colombia, Brazil, Argentina, and Paraguay by providing IT equipment and training to the newly established TTU in Mexico City, Mexico. As Mexico is a major trading partner with the United States, the Mexico unit is the largest TTU initiative to date.
In 2008, ICE updated the technical capabilities of existing TTUs and trained new TTU personnel in Colombia, Paraguay, and Mexico as well as members of their financial intelligence units. Additionally, ICE strengthened its relationship with its TTUs by deploying temporary and permanent personnel overseas to work onsite and provide hands on training to all five TTUs in the hemisphere. This action has continued to facilitate the information sharing between the U.S. Government and foreign TTUs in furtherance of ongoing joint criminal investigations.
Other ICE Programs
Additionally in 2008, ICE expanded Operation Firewall, a joint strategic bulk cash smuggling initiative with DHS’ U.S. Customs and Border Protection (CBP) to provide hands-on training and capacity building to law enforcement officials in Mexico, Honduras, El Salvador, Guatemala, Panama, Colombia, Ecuador, and Dominican Republic. Operation Firewall was initiated to address the threat posed by bulk cash smuggling via all modes of transportation at air and land ports of entry. In fiscal year (FY) 2008, Operation Firewall resulted in approximately 978 seizures totaling more than $51 million in U.S. currency and negotiable instruments.
Under the ICE Cornerstone initiative, training was developed and designed to provide the financial and trade sectors with the necessary skills to identify and develop methodologies to detect suspicious transactions indicative of money laundering and criminal activity. In furtherance 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 organizations. In FY 2008, ICE Cornerstone liaisons conducted 884 outreach meetings with more than 21,000 industry professionals in the U.S. and abroad.
In 2008, the U.S. Internal Revenue Service (IRS) Criminal Investigative Division (CID) continued their involvement in international training and technical assistance efforts designed to assist international law enforcement officers in detecting tax, money laundering, and terrorist financing crimes. With funding provided by the U.S. Department of State, IRS-CID delivered training through agency and multi-agency technical assistance programs to international law enforcement agencies. Training consisted of both basic and advanced financial investigative techniques.
IRS-CID participated in delivering State Department-funded courses to combat terrorism financing and money laundering, which were hosted by the Federal Bureau of Investigation (FBI) in Morocco, Paraguay, Algeria, Tanzania, and Senegal. IRS-CID conducted a financial investigative technical course in Asuncion, Paraguay, funded by an interagency agreement between the U.S. Department of State’s Bureau for International Narcotics and Law Enforcement Affairs (INL) and the U.S. Department of the Treasury’s Office of Technical Assistance (OTA). The training program was attended by 40 officials from the government of Paraguay, including the Ministry of Finance’s Tax Department, the Customs Office, the Prosecutors’ Office, the Secretary for the Prevention of Money Laundering, the Justice Department, and the Trademark Office. IRS-CID also conducted financial investigative techniques classes in Tirana and Durrës, Albania. The focus of the courses was money laundering relating to public corruption and the target audience was the newly formed Joint Investigative Unit for Economic Crimes and Corruption (JIU). The classes were comprised of both prosecutors and investigators from the JIU and also included non-JIU participants. Investigators and prosecutors from Albania’s many provincial areas were represented in the class.
IRS-CID provided instructor and course delivery support to the four International Law Enforcement Academies (ILEAs) run by the State Department in Bangkok, Thailand; Budapest, Hungary; Gaborone, Botswana; and San Salvador, El Salvador. At ILEA Bangkok, IRS-CID participated in one supervisory criminal investigator course and was the coordinating agency of the complex financial investigations course. These courses were provided to senior, mid-level, and first-line law enforcement supervisors and officers from Brunei, Cambodia, Hong Kong, Indonesia, Laos, Macau, Malaysia, Maldives, Philippines, Singapore, Thailand, Timor-Leste, and Vietnam. Also at ILEA Bangkok, IRS-CID conducted a complex financial investigations course sponsored by OPDAT. Various Thai government agencies attended this course, including the police, and officials involved in anti-money laundering, customs enforcement, consumer protection, counternarcotics, insurance regulation, and securities and exchange regulation.
At ILEA Budapest, IRS-CID participated in five sessions delivering financial investigative techniques training. IRS-CID also provided a class coordinator for a six-week ILEA course, the Core Program Session #65, for which the IRS-CID coordinator held the responsibility of coordinating and supervising the participant’s daily duties and activities. The countries that participated in these classes were Albania, Armenia, Azerbaijan, Bosnia and Herzegovina, Bulgaria, Croatia, Georgia, Hungary, Kazakhstan, Macedonia, Moldova, Romania, Russia, Serbia, and Ukraine. At ILEA Gaborone, IRS-CID participated in four Law Enforcement Executive Development programs, delivering financial investigative techniques training. Countries that participated in these classes were Angola, Botswana, Lesotho, Malawi, Mauritius, Mozambique, Namibia, South Africa, Swaziland, Tanzania, Zambia, Djibouti, Ethiopia, Kenya, Seychelles, Uganda, Nigeria, Cameroon, Comoros, the Republic of the Congo, Gabon, and Madagascar. At ILEA San Salvador, IRS-CID participated in three of the Law Enforcement Management Development Programs (LEMDP), delivering financial investigative techniques training. Countries that participated in these classes were Antigua and Barbuda, Argentina, Bahamas, Barbados, Belize, Chile, El Salvador, Grenada, Guatemala, Jamaica, Mexico, Paraguay, Peru, St. Kitts and Nevis, and Suriname. LEMDP stresses the importance of conducting a financial investigation to further develop a large scale, criminal investigation.
The U.S. Department of the Treasury’s Office of the Comptroller of the Currency (OCC) performs on-site examinations and provides Bank Secrecy Act (BSA) and anti-money laundering (AML) guidance to national banks and federal branches of foreign banking organizations. On-site examinations include reviewing compliance with BSA/AML laws and regulations at some of the largest financial institutions in the world. Working with other federal banking regulators through the Federal Financial Institution Examination Council (FFIEC), the OCC assists with developing and providing BSA/AML guidance and training to examiners and foreign banking supervisors. Such initiatives include maintaining the FFIEC BSA/AML examination manual, providing instructors for FFIEC AML compliance workshops, and providing speakers for the FFIEC advanced BSA/AML compliance conference.
The OCC conducted and sponsored a number of anti-money laundering initiatives for foreign banking supervisors during 2008. In June, the OCC sponsored its Anti-Money Laundering and Counter Financing of Terrorism (AML/CTF) School in Washington, D.C. The school was designed specifically for foreign banking supervisors to increase their knowledge of money laundering and terrorist financing activities and how these acts are perpetrated. The course provided a basic overview of AML examination techniques, tools, and case studies. Banking supervisors from 19 countries attended the school at the OCC’s Washington, D.C., headquarters, including Algeria, Argentina, Austria, Belize, India, Italy, Korea, Mexico, Netherlands, Nigeria, Panama, Philippines, St. Vincent and the Grenadines, and Turkey. The OCC also contributed personnel to a Middle East Northern Africa Regional AML Seminar in Casablanca, Morocco, during July that assisted government personnel from Morocco, Egypt, Lebanon, and Qatar. AML technical assistance was also provided to banking supervisors from Uruguay and Russia through participation on AML/CTF on-site examinations. Various OCC officials participated in international conferences on combating money laundering. In March and May of 2008, OCC officials were part of a body of U.S. regulators that presented at the Money Laundering Alert’s International Conference on Combating Money Laundering and the Institute of International Bankers 2008 Annual Anti-Money Laundering Seminar.
Training and Technical Assistance
The U.S. Department of Justice’s (DOJ) Office of Overseas Prosecutorial Development, Assistance, and Training (OPDAT) assesses, designs, and implements training and technical assistance programs for U.S. criminal justice sector counterparts overseas. OPDAT draws upon the anti-money laundering and counter financing of terrorism (AML/CTF) expertise within DOJ, including the Asset Forfeiture and Money Laundering Section (AFMLS), Counterterrorism Section (CTS), and U.S. Attorney’s Offices, to train and advise foreign AML/CTF partners. Much of the assistance provided by OPDAT and AFMLS is provided with funding from the U.S. Department of State.
In addition to training programs targeted to a country’s immediate needs, OPDAT also provides long-term, in-country assistance through Resident Legal Advisors (RLAs). RLAs are federal prosecutors who provide in-country technical assistance to improve capacity, efficiency, and professionalism within foreign criminal justice systems. RLAs are posted to U.S. Embassies for a period of one or two years to work directly with counterparts in legal and law enforcement agencies, including ministries of justice, prosecutor’s offices, and offices within the judiciary branch. To promote reforms within the criminal justice sector, RLAs provide assistance in legislative drafting, modernizing institutional structures, policies and practices, and training law enforcement personnel, including prosecutors, judges, police, and other investigative or court officials. For all programs, OPDAT draws upon expertise from DOJ’s Criminal Division, the National Security Division, AFMLS, and other DOJ components as needed.
Money Laundering/Asset Forfeiture/Fraud
In 2008, OPDAT and AFMLS provided training to foreign judges, prosecutors, and other law enforcement officials, and provided assistance in drafting anti-money laundering statutes compliant with international standards. Such assistance enhanced 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 technical assistance programs varied, depending on the participants’ specific needs, but topics addressed in 2008 included money laundering legislation development, international AML/CTF standards compliance, techniques and methods used for effective investigations, and prosecution of money laundering, including the role of prosecutors, criminal and civil forfeiture systems, and the importance of both international and inter-agency cooperation and communication.
AFMLS provides direct technical assistance in connection with legislative drafting on all matters involving money laundering, asset forfeiture, and the financing of terrorism. In 2008, AFMLS provided such assistance to nine countries, including Azerbaijan, Haiti, India, Indonesia, Kosovo, Kyrgyz Republic, Liberia, Turkey, and Vietnam. AFMLS provided training on money laundering issues in Albania, Armenia, Bangladesh, Bosnia, China, Colombia, Croatia, Georgia, Hungary, Kazakhstan, Kyrgyz Republic, Macedonia, Moldova, Montenegro, New Zealand, Serbia, Turkey, Ukraine, and Uzbekistan. In addition, AFMLS continued to participate in meetings of the Organization of American States (OAS) Inter-American Drug Abuse Control Commission (CICAD) Experts Group on Money Laundering to develop and promote best practices in money laundering and asset forfeiture. AFMLS also participated in the Camden Asset Recovery Inter-Agency Network (CARIN) Group on asset recovery.
In an effort to improve international cooperation, AFMLS, in conjunction with Poland’s ministry of justice, co-hosted a conference in April in Krakow, Poland, on international forfeiture cooperation among prosecutors and investigators. This conference brought practitioners, investigators, and international experts together to discuss experiences and provide practical tools to further international forfeiture cooperation. Officials from Bulgaria, Estonia, Latvia, Liechtenstein, Moldova, Poland, Romania, Switzerland, Ukraine, and the United States participated.
In April 2008, AFMLS conducted a conference on international issues in asset forfeiture that covered international asset sharing, obtaining evidence and assistance from foreign countries, black market peso exchanges, terrorist financing, and digital currency and e-gold investigations. More than 30 foreign prosecutors attended from Brazil, Canada, Georgia, Guernsey, Switzerland, Thailand, and the United Kingdom.
In October 2008, AFMLS developed an international conference that focused on AML/CTF and corruption issues. The conference was held in Budapest, Hungary, and was attended by the Prosecutors General and deputies of Albania, Armenia, Bosnia, China, Croatia, Georgia, Hungary, Kazakhstan, Kyrgyz Republic, Macedonia, Moldova, Montenegro, Serbia, Turkey, Ukraine, and Uzbekistan.
With U.S. Department of State funding, OPDAT provided training to government officials on money laundering and financial crime-related issues to officials from more than 20 countries, including Albania, Armenia, Azerbaijan, Bangladesh, Bosnia and Herzegovina, Brazil, Bulgaria, Georgia, Grenada, Indonesia, Jordan, Kosovo, Kuwait, Liberia, Macedonia, Paraguay, Russia, Serbia, Trinidad and Tobago, Ukraine, and the United Arab Emirates.
Training for Local Judiciary and Investigators in Serbia. OPDAT provided a series of trainings to enhance local judiciary and law enforcement capacity to investigate, prosecute, and adjudicate money laundering and terrorism financing cases. The objectives of these trainings were to build Serbian prosecutor and investigator capacity to conduct complex financial investigations, and to promote cooperation among prosecutors and investigators, as well as with different institutions providing assistance on financial matters.
New Money Laundering Law for Albania. OPDAT participated in a working group tasked with drafting a new AML/CTF law in Albania. In May 2008, the new law passed, lowering the reporting threshold for financial transactions and enhancing customer identification requirements.
Assistance to the Bangladesh FIU. OPDAT provides to the Bangladesh Financial Intelligence Unit (FIU) regular assistance to enable it to become the first South Asian nation admitted to the Egmont Group. To that end, OPDAT has sponsored several FIU advisors to work directly with the central bank of Bangladesh. In 2008, OPDAT sponsored two such advisors for three-week assignments each.
Money Laundering/Asset Forfeiture Training in Brazil. In 2008, OPDAT’s RLA to Brazil formed a working group that includes a federal money laundering judge, prosecutors, and law enforcement officials. This group meets regularly and plans to draft an “undercover manual” for money laundering investigations. In addition, the RLA is planning a national money laundering course for Brazil’s 27 federal money laundering judges, the prosecutors who work in their courts, and law enforcement personnel.
Money Laundering/Asset Forfeiture Program in Azerbaijan. OPDAT’s RLA to Azerbaijan held a one-day seminar for members of Parliament, the Ministry of Justice, nongovernmental organizations, and the press, to discuss pending draft legislation on the money laundering law. At the seminar, the 60 participants vigorously debated and ultimately voiced their support for the passage of a Financial Action Task Force (FATF) complaint money laundering law. This draft law recently passed in second reading in Azerbaijan’s parliament.
AML Training for Russian Police and Prosecutors. OPDAT’s RLA to Russia works on an ongoing basis with the Russian FIU, the FSFM, to plan training on AML and terrorism financing prevention and detection for the ministry of internal affairs. The RLA facilitates communication between DOJ’s Organized Crime and Racketeering Section and the FSFM on money laundering cases, works closely with the Department of the Treasury’s Office of Technical Assistance (OTA) representative to the FSFM on training and case cooperation issues, and represents DOJ at U.S. Embassy Moscow’s anti-money laundering working group.
Financial Crimes Trainings in Ukraine. In 2008, OPDAT conducted several half-day training modules on the investigation of complex financial crimes and money laundering. Between May and December, OPDAT conducted five of these training modules at the Ukraine Academy of Prosecutors for a total of 300 prosecutors enrolled in continuing education courses. In October, OPDAT conducted two of these training modules for the 250 future prosecutors enrolled in the master’s degree program at the Academy of Prosecutors. In November, OPDAT conducted three of these training modules for 200 undergraduate law students enrolled at the specialized Ministry of Interior University, the State Security Service Academy, and the National Law Academy in Lviv.
Asset Forfeiture Legislation and Workshops in Ukraine. Between May and September, OPDAT, in cooperation with AFMLS, worked with Ukraine’s ministry of justice on the drafting of a new law on asset forfeiture. That draft has since been forwarded to the cabinet of ministers for consideration. In 2008, OPDAT also presented a speech on asset forfeiture at an international roundtable that included representatives of Ukraine’s ministry of justice, prosecutor general’s office, and the academy of prosecutors.
Support for AML Reform and Specialization in Ukraine. OPDAT worked with Ukraine’s FIU and with the cabinet of ministers to improve Ukraine’s AML regime, and to develop an annual AML action plan, issued by the cabinet of ministers, which specifically calls for greater specialization of AML prosecutors and investigators. OPDAT participated in two international AML conferences, in April and June, speaking to approximately 70 lawyers and investigators from Ukraine’s procuracy, its FIU, and the ministry of justice. OPDAT also supported the participation of several Ukrainian prosecutors at those conferences.
AML Assistance to Georgia. In 2008, with OPDAT’s facilitation, U.S. agents from the U.S. Federal Bureau of Investigation (FBI) polygraphed members of Georgia’s new Anti-Money Laundering Unit (AMLU). The polygraphs protect the office of public prosecutions (OPP) from charges that they replaced a polygraphed unit with a nonpolygraphed unit. After completing the polygraphs, an OPDAT and a U.S. Department of the Treasury advisor conducted two seminars to improve the OPP’s ability to combat money laundering. In the first seminar, OPP, Georgia’s financial monitoring service (FMS), and the ministry of internal affairs (MOIA) investigative unit participated in a roundtable to improve communications between the various units.
AML Seminars in Georgia. OPDAT and the U.S. Department of the Treasury coordinated a series of seminars with the aim of increasing communications among the AMLU, FMS, and MOIA. One such roundtable sought to teach the three agencies to work as a single unit to prosecute money laundering cases. The roundtable prepared the agencies for an anti-money laundering seminar at which U.S. money laundering experts assisted the three agencies with improving and increasing their anti-money laundering prosecutions. OPDAT also sponsored a second seminar to discuss money laundering issues with representatives from the AMLU, FMS, and MOIA, as well as Armenian prosecutors and financial investigators.
Asset Forfeiture Assessment in Albania. In May, OPDAT brought two members of the Asset Forfeiture Division of the U.S. Marshals Service to Albania to conduct a preliminary assessment of the country’s asset forfeiture laws and administration. The assessment provided an excellent opportunity to highlight areas in need of improvement and plans for specialized asset forfeiture training. The visit also helped prompt some action by the Albanian government to physically secure seized terrorism-related assets.
Asset Forfeiture Legislation in Indonesia. OPDAT’s RLA to Indonesia has worked with an Indonesia interagency team to draft Indonesia’s first asset forfeiture law. In July, OPDAT organized a drafting workshop with the draft team and an AFMLS asset forfeiture expert. In addition to providing an overview of various countries’ asset forfeiture, asset sharing, and asset management regimes, the AFMLS expert provided for discussion by the team a section-by-section analysis of each of the 44 provisions in the draft Indonesia law.
Financial Crimes Program in Grenada. In January, OPDAT conducted the second phase of a financial crimes program in the St. George’s section of Grenada for approximately 20 prosecutors and law enforcement officials. During the prior phase in 2007, participants had developed a handbook, for both operational and training purposes, that standardized the processes involved in investigating and prosecuting financial crimes in Grenada. During this second phase, the emphasis was on practical exercises, such as conducting searches for financial records.
AML Program in Bangladesh. In January, OPDAT, AFMLS, and FBI conducted an anti-money laundering program in Dhaka. The program was twofold—to provide technical advice to the Bangladesh Corruption Task Force on cases that have monetary links to the United States and to meet with officials from the law ministry, attorney general’s office, and the Bank of Bangladesh about AML/CTF legislation that could help Bangladesh’s FIU to qualify for admission to the Egmont Group.
Police/Investigators/Prosecutors Training in Serbia. In February, OPDAT’s RLA to Serbia, in conjunction with the American Bar Association Central Europe and Eurasia Law Initiative and the Organization for Security and Cooperation in Europe (OSCE), conducted programs for prosecutors, police, and other investigators on combating financial crimes, in Pancevo and Belgrade, Serbia.
FIU Assistance in Kuwait. OPDAT’s RLA to the United Arab Emirates, in conjunction with AFMLS, OTA, and the Financial Crimes Enforcement Network (FinCEN), organized an FIU implementation program in Kuwait City, Kuwait. The U.S. Government (USG) representatives met with Kuwaiti officials to assist them in developing a blueprint to improve the effectiveness of their FIU and make it eligible for admission to the Egmont Group.
Money Laundering and Asset Forfeiture Workshops in Macedonia. In February, OPDAT’s RLA to Macedonia conducted two workshops in Skopje, Macedonia on investigating and prosecuting money laundering and asset forfeiture cases. The objective of these two workshops, which were presented to prosecutor and judge candidates at the National Training Academy, was to familiarize them with basic good practices and lessons learned in prosecuting money laundering offenses domestically and internationally.
Training on Financial Crimes Investigation and Prosecution Bosnia and Herzegovina. In March, OPDAT conducted training on investigation and prosecution of financial crimes for prosecutors as well as tax and police inspectors. Emphasis was placed on asset forfeiture and police-prosecutor cooperation.
Asset Seizure Legislation in Serbia. From March to June, OPDAT’s RLA to Serbia, in cooperation with the OSCE, participated in meetings of the Serbian asset seizure working group, and supported two working group retreats, at which the group finalized the asset seizure bill. This is the culmination of DOJ assistance to the working group, which has included programs on international best practices, examinations of asset forfeiture regimes from other countries, and a detailed review of the Serbian draft law on asset seizure. The Parliament adopted its first ever asset seizure law in October 2008.
Financial Crimes Workshop in Trinidad & Tobago. OPDAT, in partnership with OTA and the U.S. Embassy in Port-of-Spain, Trinidad & Tobago, conducted a workshop on combating financial crimes for approximately 25 representatives from the Government of Trinidad and private industry. The purpose was to enhance the ability of Trinidad’s prosecutors and investigators to investigate and prosecute financial crimes; to that end, the participants drafted a handbook of best practices for investigating and prosecuting financial crimes.
Financial Crimes Workshop in Bulgaria. In May, OPDAT and DOJ’s Organized Crime and Racketeering Section, in conjunction with Bulgaria’s prosecutorial training facility, the National Institute of Justice (NIJ), conducted a financial crimes workshop in Sofia for 35 Bulgarian prosecutors who specialize in money laundering and other financial crimes. The workshop covered money laundering investigations and prosecutions in the United States and how they compare to Bulgarian cases. The program will be adopted into the permanent curriculum of the NIJ.
U.S. Study Tour on AML Issues for a Delegation from Bangladesh. In July, OPDAT organized a week-long, U.S.-based study tour for Bangladesh’s Home Secretary and the Deputy Governor of the Bank of Bangladesh. The delegation learned about avenues of international cooperation and the ramifications of a positive or negative AML/CTF assessment by the Asia Pacific Group FATF-style regional body.
Intellectual Property and Financial Crimes Programs in Trinidad & Tobago. In September, OPDAT conducted two workshops in Port-of-Spain, Trinidad & Tobago, one to enhance the ability of Trinidad law enforcement officials to combat intellectual property rights (IPR) crimes, and the other to assist them in fighting financial crimes. The IPR program included practical exercises, such as conducting searches. The financial crimes program focused on developing strategies for combating financial and financially-motivated crimes, as well as enhancing collaboration with the financial sector. Participants to both workshops included police, prosecutors, and representatives of the financial sector.
Financial Investigative Techniques Training in Paraguay. In September, OPDAT, jointly with OTA and the Internal Revenue Service’s Criminal Investigative Division (IRS-CID), coordinated a week-long advanced money laundering course for 42 Paraguayans, including prosecutors from the financial crimes and anticorruption unit, judges, FIU investigators, and analysts from the tax and customs investigative units. The course focused on money laundering investigative techniques and instructors taught participants to analyze bank accounts and financial documents in several hypothetical money laundering cases.
Task Force Development Program in Jordan. In October, OPDAT, in collaboration with OTA, conducted a seminar in Amman, Jordan, on task force development for Jordanian prosecutors, investigators, and judges. The program focused on using the task force approach in the investigation and prosecution of organized crime. The agenda covered definitions and examples of international organized crime; enterprise theory of investigating and prosecuting organized crime; money laundering, racketeering, gang, and corruption offenses; specialized forensics and investigative techniques; and organizing a case involving complex financial crimes, including terrorism financing.
Financial Crimes Seminar in Liberia. In October, OPDAT’s RLA to Liberia conducted a financial crimes seminar in Monrovia, Liberia, for 50 Liberian criminal prosecutors and investigators. The primary objectives were to introduce the concept of long term investigations; encourage a working relationship between criminal investigators and prosecutors; present better practices in the areas of ethics and organization; and show how basic financial crimes investigative techniques can be used in corruption cases.
Suspicious Transaction Reporting Seminar in Armenia. In November, OPDAT, in coordination with the U.S. Department of State’s Bureau of International Narcotics and Law Enforcement (INL) and FinCEN, held a three-day training program on the generation and analysis of suspicious transaction reports. Thirty Armenian bankers, financial investigators, and prosecutors attended the seminar; the topics included various analytic tools such as data mining, the use of link analysis, and prioritizing suspicious targets.
Embedded Prosecutor within Bulgarian Prosecution Service. A prosecutor from DOJ’s Organized Crime and Racketeering Section began in 2008 to mentor Bulgarian prosecutors working on some of the country’s most sensitive organized crime and corruption cases, with special focus on two key money laundering cases. The prosecutor also provides advice to a U.S. Embassy team that is working with the Bulgarian Prosecution Service and Ministry of Interior to develop an organized crime task force that would target some of the country’s most elusive organized crime figures.
Tracing Illegal Proceeds in Brazil. OPDAT’s RLA to Brazil, in conjunction with FBI, developed a course on tracing illegal money used for criminal conduct. The course was held in August 2008 in Rio de Janeiro and more than 200 participants attended, including law enforcement, judges, and prosecutors.
Crimes Against the Credit System, Against Creditors, Fraud and Embezzlement. In July, OPDAT held a seminar for 25 Bulgarian prosecutors on crimes against the credit system, crimes against creditors, and fraud and embezzlement. This course will be adopted into the permanent curriculum of Bulgaria’s National Institute of Justice, the country’s official training institution for judges and prosecutors.
Financial Investigative Techniques Training to Combat Corruption in Albania. In April, OPDAT’s two RLAs to Albania, assisted by three IRS criminal investigative experts, conducted two week-long intensive seminars on effective financial investigative techniques for prosecutors and investigators. The trainings concentrated on practical exercises involving cases of money laundering, asset forfeiture, and public corruption. These seminars are part of a series of specialized training sessions, begun in December 2007, designed to increase the capacity of the newly-created Joint Investigative Unit to fight economic crime and corruption in the Tirana district prosecution office.
Third South Africa Judicial Colloquium on Racketeering and Asset Forfeiture. In May, OPDAT coordinated a three-day colloquium for South African judges on the subject of racketeering in Cape Town. The colloquium focused on racketeering, the use of crime participants as witnesses, and the use of asset forfeiture in combating criminal organizations. The colloquium was the third in an on-going series of such programs.
U.S. Study Tour for Macedonian Prosecutors. In May, OPDAT’s RLA to Macedonia hosted a nine-person delegation from Macedonia to visits to Madison, Wisconsin, and New York, New York. The delegation included prosecutors who specialized in organized crime and financial crimes. The focus of the study tour was to examine the prosecution of money laundering cases and the use of task force building.
Organized Crime and Fraud Training in China. In calendar year 2008, OPDAT’s RLA to China lectured on investigative techniques in organized crime prosecutions to ten different audiences throughout China, including prosecutors, judges, and law students. In September, the RLA facilitated a presentation by DOJ’s Fraud Section on best practices from the Katrina Fraud Task Force to the Chinese ministry of supervision and others in the Chinese government responsible for monitoring fraud in the use of relief funds for the Sichuan province earthquake.
Assistance in Combating Organized Crime in Serbia. In February, OPDAT’s RLA to Serbia, in conjunction with the UN Office on Drugs and Crime, conducted training for Serbia’s organized crime prosecutor’s office on analyst notebook software, which OPDAT donated to the prosecutor’s office. The office handles a high volume of complex corruption and economic crimes cases, including money laundering during the Milosevic era, judicial bribery cases, fraud and corruption of Serbian government officials, and international smuggling cases. The software, related equipment, and training will permit the organized crime units of prosecutors and police to work more effectively together in analyzing, organizing, and later presenting evidence in court.
U.S.-Bulgaria Mutual Legal Assistance and Extradition Treaties.In June, OPDAT organized with the Bulgarian Association of Prosecutors a two-and-a-half day training for 30 prosecutors and five officials from the ministry of justice on the new Mutual Legal Assistance Agreement and Extradition Treaties between the two countries. Presenters came from DOJ’s Office of International Assistance, the State Department’s Office of the Legal Advisor, and the International Department of the Bulgarian Supreme Cassation Prosecution Service.
Asset Management System Assessment in Macedonia. OPDAT, with the assistance of the U.S. Marshals Service, conducted an assessment of Macedonia’s current seized and forfeited assets management system. In a specialized workshop, OPDAT and the U.S. Marshals Service presented to the Macedonian government a set of recommendations for the government to consider on how to create an efficient and corruption-free assets management system.
OPDAT, CTS, and AFMLS, with the assistance of other 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, CTS, and AFMLS work as integral parts of the interagency U.S. Terrorist Financing Working Group (TFWG), co-chaired by the State Department’s INL bureau and the Bureau of Counterterrorism (S/CT).
The TFWG supports seven RLAs assigned overseas, located in Bangladesh, Indonesia, Kenya, Pakistan, Paraguay, Turkey, and the United Arab Emirates. Working in countries where governments are vulnerable to terrorist financing, RLAs focus on money laundering and financial crimes and developing counterterrorism legislation that criminalizes terrorist acts, terrorist financing, and the provision of material support or resources to terrorist organizations. The RLAs also develop technical assistance programs for prosecutors, judges, and, in collaboration with DOJ’s International Criminal Investigative Training Assistance Program (ICITAP), police investigators to assist in the implementation of new money laundering and terrorist financing procedures.
Also in 2008, OPDAT, AFMLS, and CTS met with and provided presentations to international visitors from more than 29 countries on AML/CTF topics. Presentations covered U.S. policies to combat terrorism, including legislation passed and pending at the time of the presentations, and issues raised in implementing new legislative tools, and the changing relationship of criminal and intelligence investigations. The USA PATRIOT Act, PATRIOT Improvement and Reauthorization Act, Intelligence Reform and Terrorism Prevention Act, Foreign Intelligence Surveillance Act, terrorist financing and material support statutes, and the Classified Information Procedures Act are among the significant pieces of legislation addressed. Of great interest to visitors is the balancing of civil liberties and national security issues, which is also addressed. When possible, CTS and U.S. Attorney’s Offices bring trial attorneys or Assistant U.S. Attorneys with case or investigation experience with the visitors’ countries to participate in the programs.
RLA Assistance in Bangladesh for CTF and to Develop a Career Prosecution Service. In March 2005, OPDAT placed its first RLA in South Asia at U.S. Embassy Dhaka with the goal of assisting the Government of Bangladesh in strengthening its AML/CTF regime, and improving the capability of its law enforcement agencies to investigate and prosecute complex financial and organized crimes. To assist in the development of a permanent career prosecution service in Bangladesh, OPDAT’s RLA to Bangladesh arranged a study-tour program in January 2008 for eight high-level Bangladesh government officials to meet with and receive guidance from their counterparts in the Singapore Attorney General’s Chambers in Singapore. This program is the first in a series of DOJ efforts designed to help Bangladesh develop a career prosecution service with a professionally selected and trained cadre of government prosecutors, similar to institutions like the U.S. Attorney’s Office or Crown Prosecution Service, where career prosecutors are chosen on merit rather than political connections.
RLA Assistance for CTF in Indonesia.The OPDAT RLA program in Indonesia began in June 2005. In 2008, the RLA continued to engage the Attorney General’s Terrorism and Transnational Crime Task Force (SATGAS), which OPDAT helped establish as an operational unit in 2006. The task force is responsible for prosecuting significant cases involving four key areas: terrorism, money laundering, trafficking in persons, and cyber crime. The SATGAS unit has yielded tangible results. In its first two years of operation, it successfully prosecuted 43 terrorists—including 26 Jamaah Islamiyah (JI) members and more than 40 trafficking-in-persons cases. The SATGAS unit has nationwide jurisdiction for such prosecutions, but also works with the local offices to promote such prosecutions. Over the course of 2008, the RLA conducted a number of regional training programs for SATGAS. These programs focused on providing substantive knowledge to local prosecutors concerning the task force’s priorities while building relationships between the members of the task force and the prosecutors in the field. The RLA engaged the experienced members of SATGAS as fellow presenters in the trainings. The use of experienced Indonesian SATGAS prosecutors as instructors elicited a high level of engagement on the part of the local prosecutors. Due to Indonesia’s physical size and SATGAS’ national mandate, regional training and outreach is a key element in USG support for SATGAS. On September 26, 2008, Ambassador Hume and Attorney General Supandji signed a two-year extension agreement for USG support of the SATGAS unit.
RLA Assistance for CTF in Turkey. The OPDAT program in Ankara, Turkey, began in September 2006 and includes three prongs—anti-money laundering, terrorist financing, and PKK issues. In May, OPDAT’s RLA to Turkey hosted a high level, three-person delegation from Turkey to Washington, D.C., to discuss extradition, mutual legal assistance, and counterterrorism. In June, OPDAT’s RLA to Turkey convened a conference on counterterrorism and extradition in Istanbul, Turkey. The purpose of the program was to exchange best practices on combating terrorism and discuss the basic legal requirements for extradition in terrorism and terrorism-related cases.
RLA Assistance for CTF in Kenya. OPDAT’s RLA program in Kenya began in 2004. In 2008, the RLA continued to engage Government of Kenya partners—such as the Department of Public Prosecutions, Kenya’s Anticorruption Commission, the Law Society of Kenya, and others—in a program that focuses on counterterrorist financing, anticorruption, and procedural reform.
RLA Assistance for CTF in Pakistan. Despite the difficult political climate in Pakistan, OPDAT launched its RLA program at U.S. Embassy Islamabad in September 2006. The RLA, to the extent possible, concentrated on assisting Pakistan in combating terrorist financing and money laundering, judicial reform, judicial security, and IPR violations. OPDAT deployed the current RLA to Islamabad in October 2008.
RLA Assistance for CTF in Paraguay. OPDAT’s RLA program in Paraguay began in 2003, and now carries regional responsibilities in the Tri-Border Area of Paraguay, Argentina, and Brazil. In 2008, the RLA continued to encourage Paraguayan legislators to pass a revised draft Criminal Procedure Code, which is pending before the lower chamber of the legislature. The Paraguayan legislature has already passed a revised Penal Code that contains new money laundering, IPR, and trafficking in persons statutes; the new Penal Code will go into effect in June 2009. The RLA also discussed Paraguay’s fulfillment of international commitments and passage of a CTF law. In addition, the RLA is working closely with the U.S. Agency for International Development (USAID) on plans to form, train, and coordinate the activities of a new Paraguayan money laundering task force. Specifically, USAID and the RLA are working on standardizing reports used by the various law enforcement agencies charged with investigating money laundering and financial crimes. The reports will be used by members of the task force to foster timely information sharing.
Counterterrorism/CTF Program in Azerbaijan. In conjunction with a visiting team, OPDAT held a four-day seminar for 18 prosecutors and police on detecting and fighting terrorism and its financing.
U.S. Study Tour for Romanian Delegation on Financial Investigations, Counterterrorism, and CTF. In November, OPDAT organized a series of meetings in Washington, D.C., for two officials from Romania’s FIU. The focus of the program was to aid the Romanians in meeting relevant USG counterparts with same or similar counterterrorism and CTF responsibilities.
AML/CTF Training Courses in Serbia. From May to October, OPDAT conducted four training courses for Serbian prosecutors, police, and trial judges on prosecution and adjudication of money laundering and terrorist financing cases. The training courses focused on improving participants’ knowledge of money laundering legislation, terrorist financing, available investigative techniques, and standards of proof. From May to September 2008, OPDAT conducted four additional training courses for prosecutors, police, and investigative judges on financial crimes investigations to enhance their capacity to detect and prosecute a variety of financial crimes.
The U.S. Department of the Treasury’s Office of Technical Assistance (OTA) is located within the Office of International Affairs. OTA has five training and technical assistance programs: revenue policy and revenue administration, government debt issuance and management, budget policy and management, banking and financial services, and economic crimes (formerly financial enforcement). The economic crimes program offers technical assistance to combat money laundering, terrorist financing, and other financial crimes.
Sixty experienced intermittent advisors (IAs) and resident advisors (RAs) comprise the Economic Crimes Team (ECT). These advisors provide diverse expertise in the development of regimes for anti-money laundering and combating the financing of terrorism (AML/CTF), and the investigation and prosecution of complex financial crimes. ECT is divided into three regional areas, each of which is managed by a full-time RA: Europe and Asia, Africa and the Middle East, and the Americas.
OTA receives funding from direct appropriations from the U.S. Congress, from the U.S. Department of State’s Bureau of International Narcotics and Law Enforcement (INL), the U.S. Department of Defense, U.S. Agency for International Development (USAID) country missions, and the Millennium Challenge Corporation (MCC).
Assessing Training and Technical Assistance Needs
The goal of OTA’s economic crimes program is to build the capacity of host countries to prevent, detect, investigate, and prosecute complex international financial crimes by providing technical assistance in three primary areas: combating money laundering, terrorist financing, and other financial crimes; fighting organized crime and corruption; and building capacity for financial law enforcement entities.
Before initiating any training or technical assistance to a host government, an OTA economic crimes advisors conduct a comprehensive assessment to identify needs and to formulate a responsive assistance program. These needs assessments examine the legislative, regulatory, law enforcement, and judicial components of the various regimes, and include the development of technical assistance work plans to enhance a country’s efforts to fight money laundering, terrorist financing, organized crime, and corruption. In 2008, OTA executed assessments in Oman, Algeria, West Bank, Lesotho, Egypt, Sao Tome and Principe, El Salvador, Guatemala, Honduras, Jamaica, Uruguay, Cambodia, Kyrgyzstan, Laos, and Turkmenistan.
OTA specialists delivered AML/CTF courses to government and private sector stakeholders in a number of countries. Course topics included money laundering and financial crimes investigations; identification and development of local and international sources of information; operations and regulation of banks and nonbank financial institutions, including record keeping; investigative techniques; financial analysis techniques; forensic evidence; computer assistance and criminal analysis; interviewing; case development, planning, and organization; report writing; and, with the assistance of local legal experts, rules of evidence, search, and seizure, and asset seizure and forfeiture procedures.
In Africa and the Middle East, OTA delivered the financial investigative techniques (FIT) course in Malawi, Jordan and Egypt, and conducted regional FIT training for members of the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG) and the Intergovernmental Action Group against Money Laundering in West Africa (GIABA). OTA partnered with the U.S. Department of Justice’s Office of Overseas Prosecutorial Development, Training and Assistance (OPDAT) to deliver seminars to investigators and prosecutors in Namibia and Jordan, promoting the use of the task force concept to investigate and prosecute complex financial crime cases. OTA presented a pilot analytical training course to Namibia’s financial intelligence unit (FIU) and law enforcement analysts. OTA provided specialized cross border cash smuggling, trade-based money laundering, and investigative techniques training to Jordanian Customs officials.
OTA also collaborated with the U.S. Department of Homeland Security’s (DHS) Immigration and Customs Enforcement (ICE) and Customs and Border Protection (CBP) to deliver regional bulk cash smuggling training to member countries of the Middle East and North Africa Financial Action Task Force (MENA-FATF) in Jordan. In collaboration with USAID, OTA provided training for Jordanian insurance industry personnel and regulators in AML/CTF compliance programs. OTA provided training to Namibian law enforcement officials, prosecutors, and casino regulators, and provided training and technical assistance to banking, securities and insurance regulators in Namibia, Jordan and Egypt as well as at a GIABA-sponsored banking regulator workshop in the Gambia.
OTA held a government executive AML/CTF seminar for officials in Sao Tome and Principe. In Lesotho, OTA provided a long-term IA to work with Lesotho’s revenue authority in establishing a criminal investigation and intelligence department to address tax evasion, much of which is related to trade-based money laundering. In Tunisia, OTA provided an RA to the African Development Bank (AfDB) to establish an antifraud and corruption department, mentor investigators, establish training programs, develop procedures for an antifraud hot line, and set up a case management system. The advisor also co-chaired an internal AfDB committee tasked with the development of the Bank’s AML/CTF strategy implementation plan.
Through the MCC, OTA placed an RA in Sao Tome and Principe to work with customs authorities to modernize operations. Work focuses on passing an internationally compliant customs code, installing a modern automated system to improve the processing, transparency, and security of goods moving through the seaport and airport, and improving infrastructure and capacity to execute customs operations, including inspection and countersmuggling. OTA also sponsored officials from Sao Tome and Principe to attend the regional FIT training course in Cote d’Ivoire.
In Asia, OTA conducted FIT training in Afghanistan, Cambodia, Laos, and Vietnam. OTA funded officials from Vietnamese law enforcement agencies and FIU for a study and orientation tour of the Philippines’ FIU and law enforcement agencies. OTA also conducted several training sessions for Philippine border control agencies on bulk cash smuggling. In Central Asia, OTA provided training and mentoring assistance to law enforcement agencies and banking institutions in Kyrgyzstan, and financial analysis techniques training to FIU staff from Kyrgyzstan and Kazakhstan.
In Europe, OTA teams delivered a variety of technical assistance products, including FIT training in the northern part of Cyprus and Georgia’s revenue service; financial analysis techniques training to the Armenian FIU; and training for Macedonian banking supervisors. OTA provided a regional cybercrime workshop in Poland for FIUs from ten countries in Eastern Europe and the Eurasian Group on Combating Money Laundering and the Financing of Terrorism (EAG). OTA also funded officials from law enforcement agencies and the Kyrgyz FIU for a study and orientation tour of Poland’s FIU and law enforcement agencies. OTA’s RA to the secretariat of the EAG in Moscow continued to assist that body to develop operational standards in strategically important areas related to the Financial Action Task Force (FATF) recommendations.
In the Americas, OTA delivered technical assistance in Chile, Ecuador, El Salvador, Guatemala, Haiti, Honduras, Mexico, Paraguay, and Uruguay during 2008. In Chile, OTA continued to provide technical assistance to the Chilean national gaming authority in the supervision of casinos and their risks related to money laundering and terrorist financing. OTA provided financial analysis techniques course (FATC) training to the analysts of Ecuador’s and Mexico’s FIUs. OTA also worked closely with the Ecuadorian FIU to plan in financial investigative techniques, and in gaming sector supervision for money laundering and terrorist financing risk. OTA provided four iterations of FIT training to Mexico’s FIU, and one at the International Law Enforcement Training Academy in El Salvador for participants from El Salvador and Guatemala. OTA also worked closely with the Mexican tax authority to provide AML/CTF training to its money service businesses supervisors.
OTA advisors presented its four-week criminal investigations training program for two newly established investigation units in Honduras, and provided assistance focused on developing capacity within each unit to conduct investigations and implement case management systems. In Haiti, OTA initiated technical assistance to develop a financial crimes unit and train its personnel, prosecutors and judges. OTA presented the FATC for staff of the FIU and continued technical assistance with drafting a new and revised criminal code, drafting criminal provisions of the Haitian tax code, and mentoring of active cases.
In Paraguay, OTA’s RA continued to work with the customs authority to stand up an internal investigations unit with MCC funding. In Uruguay, OTA provided an advisor who worked with the Uruguayan FIU to present a workshop on prevention and detection of money laundering and terrorist financing. OTA continued to offer a train-the-trainer course so that the basic skills taught in investigative courses can be passed on by the recipients to their agency colleagues.
Financial Intelligence Units
OTA placed a new RA in Kabul in late 2008 to continue to assist in the development of an operational FIU within the Da Afghanistan Bank, Afghanistan’s central bank, and the licensing of hawaladars in Afghanistan. In January 2008, OTA established a new resident technical assistance project to stand up an FIU in Kosovo. RAs in Montenegro and Serbia, and intermittent advisors in Armenia, Georgia, and Kyrgyzstan, delivered technical assistance to streamline and enhance host governments’ FIUs. In Georgia, this assistance included information technology (IT) development. In Paraguay, OTA continued to advise the FIU on its analytical and IT operational capacity.
In Namibia, Ethiopia, Algeria, Sao Tome and Principe, Malawi, and Jordan, advisors engaged with the respective central banks to establish and develop fully functional FIUs. In Malawi, OTA purchased IT equipment and software for the newly-established FIU, funded the training of FIU staff on the use of analytical and database software, and provided training to FIU staff. In Namibia, the RA assisted in drafting implementing regulations for the FIU, and funded UN officials to conduct an FIU IT assessment resulting in the acquisition of UN-developed software to support its database functions.
In Jordan, the OTA RA worked with the FIU director to prepare for a mutual evaluation and engagement in all OTA-sponsored training with FIU stakeholders. The RA also served as the coordinator for the expenditure of INL funds for the physical development of the FIU, including IT equipment, and database and IT system development. In Kuwait, OTA, with OPDAT and the U.S. FIU, Financial Crimes Enforcement Network (FinCEN), conducted an FIU workshop. In Sao Tome and Principe, OTA executed a terms of reference with the government to assist in the revision of its AML legislation, and to establish an FIU and an overall AML/CTF regime.
OTA continued its work with the FIUs of Guatemala, El Salvador, and Honduras by providing training seminars in the area of Financial Investigative Techniques and Financial Analysis. In Ecuador and Mexico, OTA provided a Financial Analysts Training Course for analysts of those nations’ FIUs. In addition, OTA continued its work in the IT area, assisting the Ecuador FIU in its efforts to streamline the process of receiving reports from obligated entities. In Uruguay, OTA collaborated with the FIU by providing a speaker for a seminar focused on AML/CTF issues.
Casinos and Gaming
In the casino gaming group (CGG), OTA experts from its economic crimes program has provided technical assistance to the international community in the areas of gaming industry regulation since 2000. The program provides assistance in the drafting of gaming legislation and implementing regulations. The CGG also includes training for gaming industry regulators, including FIU personnel, to develop the capacity for implementing AML programs, conducting pre-licensing investigations, and auditing and inspecting casino operations and all games of chance. In addition, The CGG organized and conducted two advanced technical workshops in Las Vegas involving Chilean regulators. In 2008, the CGG assessed the gaming regulatory systems and AML programs for the governments of Kosovo, Bosnia-Herzegovina, and Namibia, and assisted Kosovo in major revisions to its gaming laws. A member of the CGG presented on AML issues and the casino environment at a conference sponsored by Panama’s gaming commission.
In September, 40 regulators, analysts, and financial investigators from Mexico’s tax authority, FIU, and commission for banks and securities gathered in Mexico City for a two-day workshop on money service businesses oversight, regulation, and examination given by the tax authorities and OTA.
OTA provides technical assistance to foreign governments to protect insurance systems from money laundering, terrorist financing, and fraud. OTA initiated new projects in Egypt, Namibia, and Central America. Work with the Egyptian insurance regulatory authority concentrates on insurance sector compliance with AML/CTF laws requiring inspections by government regulators and will subsequently focus on antifraud measures. Insurance assistance provided to Namibia included inspection procedures to regulate insurance companies’ AML compliance. Training was provided to both government officials and the insurance industry. OTA presented on AML/CTF risks in the insurance sector at a regional conference hosted by Panama. In Paraguay, OTA continued to focus on curbing money laundering by assisting government regulators with regulatory review, training, and compliance inspections of insurance companies. The Paraguay project concluded with a regional conference in Asuncion devoted to the prevention and detection of money laundering risk in the insurance sector. The conference included participation from 11 countries and a presentation by the U.S. Internal Revenue Service.
Regional and Resident Advisors (RA)
OTA RAs continued international support in the areas of money laundering and terrorist financing. In February, OTA moved its Africa and Middle East Regional Advisor, previously based in Pretoria, South Africa, to Cairo, Egypt, resulting in increased support for programs in the Middle East and North Africa. An RA posted in Namibia continued assisting with FIU development. OTA upgraded its economic crimes advisor position in Sao Tome and Principe to a full-time residency to better implement a customs modernization project. Supported by long-term Advisors with customs and AML expertise, the RA provided technical assistance to strengthen core responsibilities and infrastructure. OTA extended the presence of a RA to work with Jordan’s law enforcement, regulatory, and customs authorities. OTA closed out its RA program in Zambia in August.
OTA’s Regional Advisor for Europe and Asia participated as one of two delegates from the United States at the Asia-Pacific Economic Cooperation (APEC) “Seminar on Securing Remittance and Cross Border Payment from Terrorist Use” held in Jakarta, Indonesia, in October. OTA continued its RA to the secretariat of the EAG, and RAs in Montenegro and Serbia focused on supporting national efforts against financial crimes.
OTA’s RA in Paraguay continued to provide assistance to develop the internal affairs unit within the customs administration, including assistance with the identification, vetting, and training of personnel, and the provision of workplaces. The customs unit has made significant progress in investigating matters under its jurisdiction. OTA closed out its resident economic crimes advisor program in Argentina in June.