Training and Technical Assistance
During 2009, 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.
Department of State
The U.S. Department of State’s Bureau of International Narcotics and Law Enforcement Affairs (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; transnational crime; 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 2009, 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, the TFWG provided in 2009 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 and training 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/CFT 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. 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 also have been used in terrorist finance.
The success of the Caribbean Anti-Money Laundering Program (CALP) led INL to develop a similar type of program for small Pacific island jurisdictions. 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 terrorists by facilitating the prevention, investigation, and prosecution of money laundering. PALP’s staff of resident mentors provides regional and bilateral AML/CFT 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 also provided support to the UN Global Program against Money Laundering (GPML) in 2009. In addition to sponsoring money laundering conferences and providing short-term training courses, GPML instituted its mentoring program to provide advisors on a year-long basis to specific countries or regions. GPML mentors provided assistance to Horn of Africa countries targeted by the U.S. East Africa Counterterrorism Initiative as well as country-specific assistance to the Philippines FIU and asset forfeiture assistance to Namibia, Botswana, and Zambia. The resident mentor based in Namibia 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 to develop viable AML/CFT regimes. GPML continues to develop interactive computer-based programs for distribution, translated into several languages.
INL continues to provide significant financial support for many of the anti-money laundering bodies around the globe. During 2009, INL supported FATF, the international AML/CFT 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 Intergovernmental Action Group against Money-Laundering in West Africa (GIABA), the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG) and the South American Financial Action Task Force (GAFISUD). In addition to providing 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 worked with the mentor to determine priorities and develop opportunities and programs. 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.
INL has supported anti-piracy efforts by substantively working with other bureaus within DOS as well as with international organizations and other countries, to look at the best way to address piracy through its financial levers–the assets assembled as a result of piracy activity, and the material support and instrumentalities of piracy–and the application of domestic and international instruments to thwart pirates as we do other criminals.
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/CFT 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 ILEAs has been 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 capabilities, and fostered relationships of American law enforcement agencies with their counterparts in each region. ILEAs have also encouraged strong partnerships among regional countries to address common problems associated with criminal activity.
The ILEA concept and philosophy is a united effort by all the participants - government agencies and ministries, trainers, managers, and students alike to achieve the common foreign policy goal of international law enforcement. The goal is to train professionals who will craft the future for the rule of law, human dignity, personal safety and global security.
The ILEAs are a progressive concept in the area of international assistance programs. The regional ILEAs offer three different types of programs. The core program, a series of specialized training courses and regional seminars tailored to region - specific needs and emerging global threats, typically includes 50 participants, normally from three or more countries. The specialized courses, comprised of about 30 participants, are normally one or two weeks long and often run simultaneously with the Core program. Topics of the regional seminars include transnational crimes, financial crimes, and counter-terrorism.
The ILEAs help develop an extensive network of alumni that exchange information with their U.S. counterparts and assist in transnational investigations. These graduates are also expected to become the leaders and decision-makers in their respective societies. The Department of State works with the Departments of Justice (DOJ), Homeland Security (DHS) and Treasury, and with foreign governments to implement the ILEA programs. To date, the combined ILEAs have trained over 30,000 officials from over 85 countries in Africa, Asia, Europe and Latin America.
Africa. ILEA Gaborone (Botswana) opened in 2001. The main feature of the ILEA is a six-week intensive personal and professional development program, called the Law Enforcement Executive Development Program (LEEDP), for law enforcement mid-level managers. The LEEDP brings together approximately 45 participants from several nations for training on topics such as combating transnational criminal activity, supporting democracy by stressing the rule of law in international and domestic police operations, and raising the professionalism of officers involved in the fight against crime. ILEA Gaborone also offers specialized courses for police and other criminal justice officials to enhance their capacity to work with U.S. and regional officials to combat international criminal activities. These courses concentrate on specific methods and techniques in a variety of subjects, such as counter-terrorism, anti-corruption, financial crimes, border security, drug enforcement, firearms and many others. Instruction is provided to participants from Angola, Botswana, Burundi, Cameroon, Comoros, Djibouti, Ethiopia, Gabon, Ghana, Kenya, Lesotho, Malawi, Mauritius, Mozambique, Namibia, Nigeria, Republic of Congo, Rwanda, Senegal, Seychelles, Sierra Leone, South Africa, Swaziland, Tanzania, Uganda and Zambia. Trainers from the United States and Botswana provide instruction. Gaborone has offered specialized courses on money laundering/terrorist financing-related topics such as Criminal Investigation and International Banking & Money Laundering Program. ILEA Gaborone trains approximately 500 students annually.
Asia. ILEA Bangkok (Thailand) opened in March 1999. The ILEA focuses on enhancing the effectiveness of regional cooperation against the principal transnational crime threats in Southeast Asia - illicit drug trafficking, financial crimes, and alien smuggling. The ILEA provides a core course (the Supervisory Criminal Investigator Course or SCIC) of management and technical instruction for supervisory criminal investigators and other criminal justice managers. In addition, these ILEA presents approximately 20 one-to-two-week specialized courses 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), Timor Leste and China (including Hong Kong and Macau), and the strengthening of each country’s criminal justice institutions to increase their abilities to cooperate in the suppression of transnational crime. Instruction is provided to participants from Brunei, Cambodia, China, Timor Leste, Hong Kong, Indonesia, Laos, Macau, Malaysia, Philippines, Singapore, Thailand and Vietnam. Subject matter experts from the United States, Australia, Hong Kong, Japan, Philippines, and Thailand provide instruction. ILEA Bangkok has offered specialized courses on money laundering/terrorist financing-related topics such as Computer Crime Investigations and Complex Financial Investigations. Approximately 800 students participate 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, Czech Republic, Georgia, Hungary, Kazakhstan, Kyrgyz Republic, Latvia, Lithuania, 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 and also from Hungary, Germany, United Kingdom, Netherlands, Ireland, Italy, Russia, Interpol and the Council of Europe provide instruction. ILEA Budapest has offered specialized courses on money laundering/terrorist financing-related topics such as Investigating/Prosecuting Organized Crime and Transnational Money Laundering. ILEA Budapest trains approximately 1,000 students annually.
Global. ILEA Roswell (New Mexico) opened in September 2001. This ILEA offers a curriculum comprised of courses similar to those provided at a typical criminal justice university/college. These three-week courses have been designed and are taught by academicians for foreign law enforcement officials. This Academy is unique in its format and composition with a strictly academic focus and a worldwide student body. The participants are mid-to-senior level law enforcement and criminal justice officials from Eastern Europe; Russia; the Newly Independent States (NIS); ASEAN member countries; the People’s Republic of China (including the Special Autonomous Regions of Hong Kong and Macau); member countries of the Southern African Development Community (SADC) plus other East and West African countries; the Caribbean, 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. ILEA San Salvador normally delivers four LEMDP sessions and approximately 20 specialized courses annually, concentrating on attacking international terrorism, illegal trafficking in drugs, alien smuggling, terrorist financing and financial crimes investigations. Segments of the LEMDP focus on terrorist financing and financial evidence/money laundering application. Instruction is provided to participants from: Antigua and Barbuda, Argentina, Bahamas, Barbados, Belize, Bolivia, Brazil, Chile, Colombia, Costa Rica, Dominica, Dominican Republic, Ecuador, El Salvador, Grenada, Guatemala, Guyana, Honduras, Jamaica, Mexico, Nicaragua, Panamá, Paraguay, Perú, St. Kitts and Nevis, St. Lucia, St. Vincent and the Grenadines, Suriname, Trinidad and Tobago, Uruguay and Venezuela. ILEA San Salvador trains approximately 500 students per year.
The ILEA Regional Training Center. The Regional Training Center (RTC) in Lima (Peru) opened in 2007 to complement the mission of ILEA San Salvador. The RTC, expected to be upgraded to a fully-operational ILEA in the future, 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.
Board of Governors of the Federal Reserve System (FRB)
The FRB conducted training and provided technical assistance to bank supervisors and law enforcement officials in AML and counter-terrorist financing (CTF) tactics in partnership with regional supervisory groups or multilateral institutions. Countries participating in these FRB initiatives in 2009 were Armenia, Bangladesh, Bhutan, Bolivia, Brazil, Peoples Republic of China, Croatia, Czech Republic, Ghana, Hong Kong SAR, India, Indonesia, Japan, Kazakhstan, Korea, Kuwait, Lebanon, Lithuania, Macau SAR, Malaysia, Mexico, Moldova, Nigeria, Paraguay, Philippines, Portugal, Russia, Taiwan, Turkey, Ukraine, Vietnam, and Zambia.
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/CFT expert group. The FRB is also an active participant in the U.S. Treasury Department’s ongoing Private Sector Dialogue conferences. 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, as well as at the Federal Law Enforcement Training Center.
Federal Bureau of Investigation (FBI), Department of Justice
During 2009, with the assistance of 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 conducted by 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 financial analysts, intelligence analysts, staff operation specialists, operational Special Agents or Supervisory Special Agents, 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 2009, the FBI delivered training to 235 students from 14 countries at ILEA Budapest. At ILEA Bangkok, the FBI provided training to 60 students from 11 countries in the Supervisory Criminal Investigators Course (SCIC). At ILEA Gaborone, the FBI provided training to 156 students from 15 African countries. At ILEA San Salvador, the FBI provided training to 98 students from 11 countries.
Also in 2009, the FBI conducted, jointly with the Internal Revenue Service, Criminal Investigative Division (IRS-CID), a one-week course on combating money laundering and terrorist financing for 564 international students from Saudi Arabia, South Africa, Pakistan, Indonesia, Kenya, Paraguay, Bahrain, the United Arab Emirates, and Turkey.
At the FBI Academy, the FBI included blocks of instruction on combating money laundering and/or terrorist financing for 37 students participating in Session #12 of the Latin American Law Enforcement Executive Development Seminar; the students were from Argentina, Belize, Brazil, Chile, Colombia, Costa Rica, Dominican Republic, El Salvador, Guatemala, Mexico, Nicaragua, Panama, Paraguay, Peru, Spain and Uruguay. The FBI included similar blocks of instruction for 23 students participating in Session #4 of the Arabic Language Law Enforcement Executive Development Seminar; these students were from Bahrain, Egypt, Iraq, Jordan, Kuwait, Libya, Morocco, Palestine, Qatar, Saudi Arabia, Sudan, United Arab Emirates and Yemen. As part of the FBI’s Pacific Training Initiative’s Session #22, the FBI included terrorist financing instruction for 50 participants from 12 countries: Thailand, China, Australia, Hong Kong, Indonesia, Malaysia, Philippines, India, Korea, Singapore, Japan and United States.
Federal Deposit Insurance Corporation (FDIC)
In 2009, 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. These efforts were focused primarily on training and outreach initiatives. In partnership with the U.S. Department of State, the FDIC hosted three anti‑money laundering and counter terrorist financing (AML/CFT) training sessions for 59 representatives from Bangladesh, Egypt, Ghana, Indonesia, Jordan, Kuwait, Mali, Nigeria, Pakistan, Saudi Arabia, Thailand, United Arab Emirates, and Yemen. The training sessions addressed the AML examination process, suspicious activity monitoring, customer due diligence, and foreign correspondent banking risks and controls.
During the year, the FDIC met with 30 supervisory and law enforcement representatives from Russia and Kazakhstan to discuss AML issues. Topics included examination policies and procedures, the USA PATRIOT Act, suspicious activity reporting requirements, and government information sharing mechanisms.
Financial Crimes Enforcement Network (FinCEN), Department of Treasury
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). Overall, FinCEN hosted representatives from 31 countries in 2009, including general orientations and consultations under the auspices of the U.S. Department of State’s International Visitor Leadership Program. These visits involved a variety of foreign government agencies and focused on topics such as money laundering trends and patterns, the Bank Secrecy Act, the USA PATRIOT ACT, communications systems and databases, and case processing.
FinCEN assists new or developing FIUs that it is co-sponsoring for membership in 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 is currently co-sponsoring FIUs from nine jurisdictions for Egmont Group membership: Afghanistan, China, Dominican Republic, Jordan, Kuwait, Oman, Pakistan, Tanzania, and Yemen. As a member of the Egmont Group, FinCEN also works multilaterally through its representative on the Egmont Training Working Group to design, implement, and instruct at Egmont-sponsored regional training programs for Egmont Group members as well as Egmont candidate FIUs.
FinCEN regularly hosts delegations from foreign FIUs in order to exchange information on operational practices and issues of mutual concern. 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. In 2009, FinCEN hosted representatives from Armenia, Kazakhstan, Moldova, and Turkey for week-long exchanges. In addition to hosting these delegations, FinCEN conducted training courses and seminars on analytical topics for the FIUs in the Philippines and South Africa.
Immigration and Customs Enforcement, Department of Homeland Security (DHS)
During Fiscal Year 2009, the Department of Homeland Security’s U.S. Immigration and Customs Enforcement (DHS/ICE), Financial, Narcotics and Public Safety Division, in conjunction with the ICE Office of International Affairs, delivered training to law enforcement, regulatory, banking, and trade officials from more than 26 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 946 officials from 26 countries. Notably, ICE provided basic BCS training in Senegal, Tanzania, Poland, China, Bosnia, Macau and Bangladesh.
Through the U.S. Department of State’s International Law Enforcement Academy (ILEA) programs, ICE conducted more than 19 financial investigations and anti-money laundering training programs for more than 505 participants. The participants represented law enforcement personnel from 69 countries.
ICE also has engaged in a partnership with the Organization of American States (OAS) and United Nations. This partnership provides ICE with a unique international and multi agency environment. Through this partnership ICE has conducted and participated in several Financial Crimes Workshops in Mexico and Peru. During these training seminars a total of 70 foreign officials, including police & customs officers, prosecutors and judges have been trained.
Trade Transparency Units (TTUs)
Trade Transparency Units (TTUs) are designed to help identify significant disparities in import and export trade documentation and identify anomalies related to cross-border trade that are indicative of international 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 financing. TTUs generate, initiate, and support investigations and prosecutions related to trade-based money laundering, the illegal movement of criminal proceeds across international borders, the abuse of alternative 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. The number of trade-based money laundering investigations emerging from TTU activity continues to grow.
The United States established a TTU within DHS/ICE that generates both domestic and international investigations. With funding from the U.S. Department of State’s Bureau of International Narcotics and Law Enforcement Affairs (INL), ICE worked to expand the network of operational TTUs beyond Colombia, Brazil, Argentina, Paraguay and Mexico. In 2010, Panama will officially become the newest member of the TTU network. ICE will be providing IT equipment and training as well as increased support to this newly established TTU to ensure its successful development.
In 2009, ICE updated the technical capabilities of existing TTUs and trained new and existing TTU personnel from Brazil, Colombia, Paraguay, Argentina, Mexico, and Panama, as well as members of their financial intelligence units. Additionally, ICE strengthened its relationship with the TTUs by deploying temporary and permanent personnel overseas to work onsite and provide hands-on training. These actions have continued to facilitate information sharing between the USG and foreign TTUs in furtherance of ongoing joint criminal investigations.
Other ICE Programs
Additionally in 2009, 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 Taiwan and Thailand. 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) 2009, Operation Firewall resulted in approximately 1,070 seizures totaling more than $74 million in U.S. currency and negotiable instruments.
Under the ICE Cornerstone initiative, training was designed and developed 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 2009, ICE Cornerstone liaisons conducted 949 outreach meetings with more than 12,401 industry professionals in the U.S. and abroad.
Internal Revenue Service (IRS), Criminal Investigative Division (CID), Department of Treasury
In 2009, the U.S. Internal Revenue Service Criminal Investigation Division (IRS-CID) continued its 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 Pretoria, South Africa; Jakarta, Indonesia; Nairobi, Kenya; Asuncion, Paraguay; Manama, Bahrain; Riyadh, Saudi Arabia; Abu Dhabi, U.A.E.; and Ankara, Turkey.
IRS-CID conducted Financial Investigative Techniques courses funded by an interagency agreement between the Bureau of International Narcotics and Law Enforcement Affairs (INL), Department of State, and the IRS-CID in the following locations:
Ankara, Turkey - the training program was attended by 24 Government of Turkey employees from the Turkish National Police, MASAK (Turkey’s FIU) and the Prosecutor’s Office.
Panama City, Panama - 36 Panamanian police and prosecutors attended this course.
Dar Es Salaam, Tanzania - 25 officials from the Tanzania Revenue Authority, the Public Prosecutions Office, the Prevention and Combating of Corruption Bureau, the Tanzania Police Force, and the Zanzibar Attorney General’s office attended the course.
IRS-CID conducted four Advanced Financial Investigative Techniques courses. Three courses were held in Hong Kong, China, and Macau, China. The first course, lasting two weeks, was presented to 24 members of the Hong Kong Independent Commission Against Corruption (ICAC). The other two courses, each lasting one-week, were presented to 26 investigators from the Hong Kong Police Force and 29 investigators from the Macau Judicial Police, Financial Intelligence Office, Customs, and the Prosecutor’s Office, respectively. The fourth course was in Seoul, South Korea - 50 investigators from the Korean National Tax Service attended a course hosted by that agency.
IRS-CID also conducted a Financial Investigative Techniques course in Mexico City, Mexico for 30 new police officers of the Mexican National Police, hosted by NCITA and the Department of Treasury, Office of Technical Assistance (OTA).
IRS-CID provided instructor and course delivery support to the State Department International Law Enforcement Academies (ILEA) located in Bangkok, Thailand; Budapest, Hungary; Gaborone, Botswana; and San Salvador, El Salvador.
At ILEA Bangkok:
IRS-CID participated in one supervisory criminal investigator course.
IRS-CID was the coordinating agency of four Complex Financial Investigation courses presented to over 175 participants from Brunei, Cambodia, China, China’s Special Administrative Regions of Hong Kong and Macau, Indonesia, Japan, Laos, Malaysia, Philippines, Singapore, Timor-Leste, and Vietnam. One of these courses was presented to 53 participants from the following Thai agencies: Office of Narcotics Control Board, Office of the National Counter Corruption Commission, Royal Thai Police, Police Coordination Center, Royal Thai Police Academy, Securities and Exchange Commission, the Revenue Department, Royal Thai Police Center for Police Forensic Science, Anti-Money Laundering Office, Bank of Thailand, Customs Department, Department of Special Investigation, Economic and Cyber Crime Division, Royal Thai Police – Narcotics Division, Office of the Consumer Protection Board, Office of Election Commission, Office of Insurance Commission, Anti Corruption Commission, Ministry of Justice, Office of the Attorney General, and the Office of the Auditor General.
At ILEA Budapest:
IRS-CID participated in delivering five sessions of Financial Investigative Techniques training. Hungary, Croatia, Macedonia, Romania, Albania, Ukraine, Kazakhstan, Armenia, and Tajikistan participated in these classes.
At ILEA Gaborone:
IRS-CID participated in four Law Enforcement Executive Development programs, and provided Financial Investigative Techniques training. Botswana, Ghana, Nigeria, Sierra Leone, Kenya, Tanzania, Mauritius, Seychelles, Namibia, Lesotho, Malawi, Rwanda, and Swaziland participated in these classes.
IRS-CID also conducted a two-week Money Laundering, Currency Crimes, and Financial Investigative Techniques course. The course focused on practical exercises that require participants to use the financial investigative concepts presented in class. This course was delivered to 36 participants representing eight countries: Kenya, Tanzania, Sierra Leone, Botswana, Ghana, Mauritius, Seychelles, and Namibia.
At ILEA San Salvador:
El Salvador, Guatemala, Dominican Republic, Honduras, Panama, Costa Rica, Nicaragua, Guyana, Colombia, Ecuador, Suriname, Argentina, Brazil, Chile, Paraguay, and Peru participated in the following courses:
Four Financial Investigative Techniques training courses offered for the Law Enforcement Management Development Programs (LEMDP). LEMDP stresses the importance of conducting a financial investigation to further develop a large scale criminal investigation.
IRS-CID also provided a class coordinator for the six-week ILEA-LEMDP 14, and was responsible for coordinating and supervising the participants’ daily duties and activities. IRS-CID also provided the key note speaker for the graduation of LEMDP 14.
Training assessments were completed for the following countries during this reporting period: Panama, South Africa, and Indonesia.
Office of the Comptroller of the Currency (OCC), Department of Treasury
The U.S. Department of the Treasury’s Office of the Comptroller of the Currency (OCC) conducts on-site anti-money laundering/counter–terrorist financing (AML/CFT) compliance examinations of national banks, federal branches, and agencies of foreign banking organizations. The OCC also works with other federal banking agencies to provide training to foreign banking supervisors.
The OCC sponsored several initiatives to provide AML/CFT training to foreign banking supervisors in 2009. The OCC organized and conducted its annual AML/CFT School in Washington, D.C. The school is designed specifically for foreign banking supervisors to increase their knowledge of money laundering and terrorist financing typologies and improve their ability to detect these activities, thus strengthening their national AML/CFT regimes. Banking supervisors from 11 countries, including Algeria, Austria, Brazil, India, Italy, Korea, Indonesia, Netherlands, Philippines, Thailand and Turkey, attended the school held at the OCC’s Washington, D.C., headquarters. OCC officials also met with a delegation of Russian supervisors who visited Washington. Discussions focused on the U.S. bank supervision system, the OCC’s risk based supervisory approach, and AML enforcement. The OCC also provided instructors for a workshop organized by the Association of Banking Supervisors of the Americas (ASBA) and hosted by the Central Bank of Jamaica that was attended by 27 supervisors from Jamaica, Barbados, Turks and Caicos, and the Cayman Islands. As part of the OCC’s industry outreach efforts, OCC officials delivered AML/CFT presentations at several conferences focused on the Latin American banking community, including the 8th Annual Puerto Rican AML Symposium, the Annual Florida Bankers Association (FIBA) conference, and the 4th Annual U.S.-Latin American Private Sector Dialogue. The OCC was also represented at the 2009 International Institute of Bankers Annual AML Seminar.
Office of Overseas Prosecutorial Development, Assistance and Training, the Asset Forfeiture and Money Laundering Section, & Counterterrorism Section (OPDAT, AFMLS, and CTS), Department of Justice
Training and Technical Assistance
The U.S. Department of Justice’s (DOJ) Office of Overseas Prosecutorial Development, Assistance, and Training (OPDAT), established in 1991, assesses, designs, and implements training and technical assistance programs for U.S. criminal justice sector counterparts overseas. OPDAT draws upon the anti-money laundering/counter-terrorist financing (AML/CFT) expertise within DOJ, including that of the Asset Forfeiture and Money Laundering Section of DOJ’s Criminal Division (AFMLS/Criminal Division), the Counterterrorism Section of the National Security Division (CTS/NSD), and U.S. Attorney’s Offices to train and advise foreign AML/CFT partners. Much of the assistance provided by OPDAT and AFMLS is provided with funding from the U.S. Department of State; funds are also provided by the U.S. Agency for International Development and the Millennium Challenge Corporation.
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, and – in collaboration with DOJ’s International Criminal Investigative Training Assistance Program (ICITAP) – police and other investigative officials as well as with other donors and multilateral organizations. For all programs, OPDAT draws upon expertise from DOJ’s Criminal Division, the National Security Division, AFMLS, and other DOJ components as needed.
In 2009, OPDAT, AFMLS, and CTS met with and provided presentations to more than 110 international visitors from more than 20 countries on AML and/or CFT topics. Presentations covered U.S. policies to combat terrorism, U.S. legislation, and issues raised in implementing new legislative tools, and the changing relationship of criminal and intelligence investigations. The meetings also covered money laundering and material support statutes, and the Classified Information Procedures Act. Of great interest to visitors is the balancing of civil liberties and national security issues, which is also addressed.
Money Laundering/Asset Forfeiture/Fraud
In 2009, OPDAT and AFMLS provided training to foreign judges; prosecutors; other law enforcement officials; legislators; customs, supervisory, and FIU personnel; and private sector participants, 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 2009 include the investigation and prosecution of complex financial crimes, economic crimes, money laundering, and corruption; the use of asset forfeiture as a law enforcement tool; counterfeiting; health care fraud; and international mutual legal assistance.
AFMLS-provided Training and Technical Assistance
AFMLS provides direct technical assistance in connection with legislative drafting on all matters involving money laundering, asset forfeiture, and the financing of terrorism. In 2009, AFMLS provided such assistance to eight countries, including Afghanistan, Azerbaijan, Bulgaria, Haiti, Indonesia, Iraq, Mexico and Turkmenistan. AFMLS provided in-country training on money laundering, forfeiture and financial investigation issues in Bangladesh, Denmark, Egypt, Japan, Kuwait, Saudi Arabia, Tanzania, Thailand and St. Kitts. Training was also provided in the United States to visiting delegations from Albania, Canada, Croatia, Estonia, Kazakhstan, Malaysia, Moldova, Mongolia, Iraq, Russia, Senegal, Turkey and Ukraine.
In April, AFMLS, accompanied by OPDAT RLA and Office of International Affairs (OIA) attorneys, participated in a high level asset recovery workshop for government cabinet members in Bangladesh. 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. In May, in an effort to improve international cooperation, AFMLS, in conjunction with the Japanese Ministry of Justice, co-hosted a conference in Tokyo, Japan, focused on “Forfeiting the Proceeds of International Organized Crime”. This conference brought together about 80 attorneys and prosecutors from Singapore, Korea, Hong Kong (SAR), Japan, and the United States to discuss experiences and provide practical tools to further international forfeiture cooperation.
In July, AFMLS conducted a conference on international issues in asset forfeiture covering joint international investigation; obtaining legal assistance from foreign countries; effective prosecution strategies for cases involving alien trafficking, arms trafficking and currency smuggling; recovering the proceeds of foreign corruption; and international asset sharing. Prosecutors from the United States and 12 other nations including Argentina, Barbados, Brazil, Colombia, Costa Rica, the Dominican Republic, Ecuador, Grenada, Mexico, Panama, Paraguay and St. Kitts were in attendance. In 2009, the United States held the presidency of the Camden Asset Recovery Inter-Agency Network (CARIN) Group on asset recovery, and represented by AFMLS, hosted the network’s annual meeting at the Bolger Center in Potomac, Maryland in September.
Additionally, AFMLS and OPDAT, with funding provided by INL, placed a short term asset recovery advisor from the OIA in Bangladesh to assist the government in establishing a central authority.
OPDAT-provided Training and Technical Assistance
In 2009, OPDAT led or participated in training programs and seminars addressing the following topics, all tailored to the region or individual country: asset forfeiture seminars in Albania, Bangladesh, Cambodia, Kosovo, Laos, Macedonia and Serbia; complex financial crime investigation and prosecution in Albania, Bosnia and Herzegovina, Jordan, Kosovo, Macedonia, Mozambique, Serbia, Turkey and Ukraine; anti-corruption programs for Albania, Cameroon, Liberia, Rwanda, Serbia, Tanzania and Uganda; mutual legal assistance for Bangladesh and Moldova; and, AML/CFT-related seminars for Argentina, Brazil, Costa Rica, Indonesia, Jordan, Middle Eastern/Gulf region countries, Mexico, Panama, Paraguay, Saudi Arabia, Ukraine and Uruguay.
Albanian, Indonesian and Malaysian officials participated in study tours to the United States to observe how the U.S. investigates and prosecutes complex financial crimes and corruption. Additionally, In October 2009, OPDAT and the Bulgarian National Institute for Justice co-sponsored a workshop on Health Care Fraud.
In February and July, 2009, OPDAT organized and chaired the third and fourth meetings of the Economic Crime Working Group whose participants include prosecutors and police officers who are members of the Joint Investigative Unit to Fight Economic Crime and Corruption (JIU), Financial Intelligence Unit inspectors and bank compliance officers.
In August 2009, OPDAT conducted a series of seminars in South Africa to explain the use of racketeering charges in money laundering and financial fraud cases. In Montenegro, the RLA office hosted an asset forfeiture roundtable, led by U.S. Marshals Service officials, to discuss implementation of Montenegro’s new law on asset forfeiture. In addition, OPDAT hosted a seminar to introduce judges, prosecutors, police and lawyers to the secret surveillance measures and asset forfeiture provisions of a draft Criminal Procedure Code for Montenegro.
In November 2009, the Deputy Chief of the U.S. Department of Justice Asset Forfeiture and Money Laundering Section (AFMLS) traveled to Indonesia to work with the OPDAT RLA, the Indonesia Financial Investigation Unit (PPATK), and an inter-agency drafting team on new Non-Conviction Based (NCB) Asset Forfeiture Legislation for Indonesia.
OPDAT, AFMLS, and CTS/NSD, with the assistance of other DOJ components, play a central role in providing technical assistance to foreign counterparts to attack the financial underpinnings of terrorism and to build legal infrastructures to combat it. In this effort, OPDAT, CTS/NSD, 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).
CTS- provided Training and Technical Assistance
In February 2009, a prosecutor from CTS/NSD gave a presentation on the American perspective on terrorist financing at the Organization of American States’ four-day "Terrorism Financing Sub Regional Workshop" in San Jose, Costa Rica. Among the participants were prosecutors and law enforcement agents from throughout South America. The workshop focused on terrorist financing, counter-terrorism legislation, asset forfeiture and anti-money laundering efforts.
In addition, in November 2009, a CTS prosecutor discussed the U.S. experience in investigating the financing of terrorist acts at the United Nations Office on Drugs and Crime’s "Specialized Workshop in the Prevention and Fight against Terrorism and its Financing,” in the Bahamas.
OPDAT- provided Training and Technical Assistance
The TFWG supports six RLAs assigned overseas, located in Bangladesh, Indonesia, Kenya, Pakistan, Turkey, and the United Arab Emirates (UAE). The RLA for the UAE and the Middle East is stationed at the U. S. embassy in Abu Dhabi, UAE, and is responsible for OPDAT program activities in the UAE, Saudi Arabia, Kuwait, Qatar, Jordan, Yemen, Oman, and Bahrain. The activities of the RLAs consist not only of capacity-building with host country justice sectors. Working in countries deemed to be vulnerable to terrorist financing, RLAs focus on money laundering and financial crimes and developing counter-terrorism legislation that criminalizes terrorist acts, terrorist financing, and the provision of material support or resources to terrorist organizations. The RLAs implement these programs by providing training, assistance in legislative drafting and support for the countries’ AML/CFT efforts. Some highlights of the RLAs’ efforts in 2009 include:
In Bangladesh, following RLA and U.S. embassy sponsored anti-counterfeiting seminars by agents of the United States Secret Service (USSS), the agents carried on consultations with U.S. and Bangladeshi officials focusing on currency counterfeiting activity in South Asia.
In Indonesia, 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. In 2009, OPDAT conducted two courses as part of a new regional training initiative sponsored by OPDAT under the Aegis of the SATGAS for local prosecutors At this program, the Task Force provided substantive knowledge to local prosecutors concerning the Task Force’s main priorities, including terrorism and money laundering, while at the same time building relationships between the members of the Task Force and the prosecutors in the field. Additionally, OPDAT sponsored two legislative drafting conferences for an Indonesian inter-agency drafting team to write a new terrorism financing statute to replace the widely criticized 2003 law.
The RLA in Kenya spent much of the year providing support to the Kenyan government, U.S. authorities, and the international community for the prosecutions of Somali pirates, assisting in drafting the memorandum of understanding between the U.S. and Kenya on the hand-over of captured suspects, and the standard operating procedures used by international naval personnel undertaking counter-piracy operations in the region.
In 2009, in addition to the programs listed under the Money Laundering/Asset Forfeiture/Fraud section, the RLAs conducted or participated in the following training programs and seminars: terrorist financing investigations and prosecutions in Indonesia and Jordan; piracy seminars in Kenya and Tanzania; and counterfeiting in Bangladesh. Officials from Indonesia and Turkey participated in study tours to the U.S.; and Pakistani officials accompanied the RLA to India to attend the South Asia Regional Conference on Countering Terrorist Financing in the Charitable Sector.
In addition to the RLAs, OPDAT has an Intermittent Legal Advisor (ILA) program designed to mentor the Bosnia and Herzegovina Prosecutor’s Office on complex prosecutions including terrorism investigations. The ILA mentors on evidence, methodology for witness interviews, and charging analysis, and has established a working group structure that combines law enforcement agents with prosecutors.
Office of Technical Assistance (OTA), Treasury Department
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.
Fifty-four experienced Resident Advisors and Intermittent Advisors comprise the Economic Crimes Team (ECT). These advisors provide diverse expertise in the development of anti-money laundering/counter-terrorist financing (AML/CFT) regimes, and the investigation and prosecution of complex financial crimes. The ECT is divided into three geographic areas, each of which is managed by a full-time Regional Advisor: Europe and Asia, Africa and the Middle East, and the Americas.
OTA receives direct appropriations from the U.S. Congress and funding from the U.S. Department of State’s Bureau of International Narcotics and Law Enforcement Affairs (INL), the U.S. Department of Defense, U.S. Agency for International Development (USAID) country missions, and the Millennium Challenge Corporation (MCC).
Regional and Resident Advisors (RA)
OTA Regional Advisors and Resident Advisors (RAs) continued international support in the areas of money laundering and terrorist financing through conducting bilateral assessments; organizing and participating in regional training events and international workshops and seminars; working collaboratively with international donors; and supporting FATF-style regional bodies in the delivery of technical assistance and other direct and indirect TA activities. The Regional Advisor, Africa and Middle East serves as the U.S representative for the MENAFATF Technical Assistance and Typology Working Group and is a member of U.S. delegations to three FATF-style regional bodies in his region. OTA’s Regional Advisor for Europe and Asia participated as a delegate from the United States at the U.S.-India FATF AML/CFT Workshop, where he assessed India’s AML/CFT TA needs.
The OTA residency program with the Eurasian Group on Money Laundering (EAG), based in Moscow, was concluded in mid-2009 after a successful two-year engagement that saw the development of regional operational standards for anti-money laundering, as well as direct technical assistance to many EAG members. In Tunisia, OTA successfully concluded assistance to the African Development Bank, establishing an anti-fraud and corruption department, training and mentoring investigators, establishing training programs, developing procedures for an anti-fraud hot line, setting up a case management system and co-chairing the Bank’s AML/CFT Strategy Implementation Group.
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. OTA received approval from the US Embassy in Mexico for the installation of a Resident Advisor in Mexico as part of its continuing technical assistance program in that country.
In Namibia, the RA assisted in drafting implementing regulations for the financial intelligence unit (FIU); facilitated the purchase and installation of a United Nations-developed IT data base software to receive, process and analyze suspicious and cash transaction reports; and drafted delegation orders and guidance notes to reporting entities. The RA also conducted research, recommended courses of action to establish monetary thresholds for reports and cross-border declarations, and drafted procedures for the exemption process for reporting entities. In Jordan, the OTA RA worked with the new FIU director to provide orientation and training to new employees, and advised on the acquisition of office space, equipment, and IT systems. The RA serves as the U.S. Embassy coordinator for the expenditure of INL funds for the physical development of the FIU, including IT equipment, and database and IT system development.
OTA placed a new RA in Kabul in January 2009 to continue to assist in the development of an operational FIU within the Afghanistan Bank, Afghanistan’s central bank, and the licensing and regulation of hawaladars and other financial sector participants in Afghanistan. The RA provides mentoring, advice, and other development assistance to FIU management, analysts, and other staff.
OTA plans to place an additional RA in Afghanistan and will place a resident Banking AML/CFT Specialist in Kabul in early 2010. OTA plans to place an Economic Crimes RA in Hanoi in early 2010. OTA also plans to place a new resident advisor in Kosovo in early 2010 to assist in standing up the FIU.
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 training or technical assistance, OTA Economic Crimes Advisors conduct comprehensive assessments to identify needs and to formulate responsive assistance programs. These needs assessments examine legislative, regulatory, law enforcement, and judicial components, 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. During 2009, OTA conducted assessments in Libya, Saudi Arabia, Palestine, Morocco, Botswana, Mozambique, Ghana, El Salvador, Guatemala, Honduras, Jamaica, Costa Rica, Mexico, Peru, Uruguay, Georgia, Armenia, Kosovo, India and Pakistan.
Additionally, targeted assessments of a particular sector may be undertaken. In 2009, OTA participated in the Pakistan civilian assistance strategy review. Gaming assessments were conducted in Costa Rica, Guatemala and Peru. In Laos, OTA conducted a legislative assessment with the Laotian Anti-Money Laundering Intelligence Unit. In Laos and Cambodia, OTA conducted an AML-related IT assessment and has began providing assistance in development of financial intelligence reporting systems. OTA provided for basic IT assessments of Paraguay’s and Uruguay’s current FIU IT systems.
In addition to the support and training provided by the RAs, OTA specialists delivered AML/CFT courses and other advice-based services 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, non-bank financial institutions and the gaming sector, 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, mutual legal assistance and cooperation, search and seizure, and asset seizure and forfeiture procedures. OTA continued to offer train-the-trainer courses throughout its programs so that the basic skills taught in investigative courses can be passed on by the recipients to their agency colleagues. To complement its independent programs, OTA partnered with several USG and multilateral organizations, including agencies and offices of the U.S. Departments of State, Justice, Treasury and Homeland Security; the UN; the Asia/Pacific Group on Money Laundering (APG), a FATF-style regional body; the Association of Southeast Asian States (ASEAN); and the Millennium Challenge Corporation to deliver a variety of training.
In 2009, OTA led or participated in the following training programs delivered to FIU and supervisory personnel, police, prosecutors, judges, customs officers and/or private sector entities: Financial Investigative Techniques (FIT) courses in Cambodia, El Salvador, Guatemala, Haiti, Honduras, Jordan, Lesotho, Mexico, Pakistan, Palestine, and Uruguay; Financial Analysts Training in Afghanistan, Algeria, Ecuador, Honduras, Lesotho, Mexico, Palestine, Uruguay, and a regional course for members of the Middle East and North Africa Financial Action Task Force (MENAFATF); bulk cash smuggling training for Afghanistan, Gulf Region members of the MENAFATF, Laos, Namibia and Vietnam; AML/CFT seminars for Argentina, Mexico, Namibia and Philippines; and an anti-corruption seminar for Bahrain, Jordan, Morocco, and Yemen; a seminar on trade-based money laundering in Namibia; and, an asset forfeiture workshop for Laos and Cambodia. OTA also conducted a regional FIU workshop in Warsaw, Poland for FIUs from ten countries of Eastern Europe and the Eurasian Group on Money Laundering (EAG).
In Lesotho, OTA continues its collaboration 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. Through the MCC, OTA continues to work with customs authorities in Sao Tome and Principe to modernize operations. Efforts have led to the passage of a modern and internationally compliant customs law; and work is progressing on 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 counter–smuggling activities. OTA assisted Laos in preparing for its APG mutual evaluation, funding translation of the mutual evaluation questionnaire and other key documents, and participating in preparatory training for completion of the questionnaire. In Georgia, OTA completed preparation of an Operations Manual for the Investigations Department, which is in the early stages of its development. In Haiti, OTA continued its technical assistance program to develop a financial crimes unit and a companion investigative unit and to train its personnel, prosecutors and judges. OTA continued its technical assistance to the government of Haiti by assisting with drafting a new and revised criminal code, drafting criminal provisions of the Haitian tax code, and mentoring of active cases.
Financial Intelligence Units
Resident and intermittent advisors in Armenia, Georgia, Kosovo, Poland, and the Mekong region delivered technical assistance to streamline and enhance host governments’ FIUs. In Georgia and Armenia, this assistance included information technology (IT) development. OTA continued to deliver intermittent TA to Mekong region countries (Vietnam, Cambodia, and Laos) according to assessed needs in each jurisdiction. In Vietnam, OTA signed a Terms of Reference (TOR) with the State Bank of Vietnam that will lead to a residency program there. In Pakistan, OTA established a TOR for intermittent assistance to the FIU, as well as other Pakistani institutions involved with preventative, analytic, and enforcement aspects of the AML/CFT regime. This assistance is expected to transition to a resident advisor project in 2010. In Paraguay, OTA continued to advise the FIU on its analytical and IT operational capacities. OTA also worked closely with the Ecuadorian FIU to plan technical assistance in financial investigative techniques, and in gaming sector supervision for money laundering and terrorist financing risk.
In Namibia, Algeria, Palestine and Jordan, advisors provided technical assistance to enhance the operational capacity of FIUs. In Lesotho, assistance is being provided to the newly authorized FIU in acquiring and configuring office space, acquiring office equipment and IT systems, hiring personnel, and drafting regulations. In Algeria and Palestine, training was provided on the analysis of suspicious transaction reports. In addition, OTA continued its work in the IT area, assisting the Haiti FIU in its efforts to obtain appropriate IT systems to receive reports from obligated entities. In Uruguay, OTA collaborated with the FIU by providing a speaker for a seminar focused on AML/CFT issues. OTA provided for basic IT assessments of Paraguay’s and Uruguay’s current IT system.
Casinos and Gaming
The Casino Gaming Group (CGG) experts have provided technical assistance to the international community in the area of gaming industry regulation since 2000. The program provides assistance in the drafting of gaming legislation and implementing regulations. The CGG also provides training for gaming industry regulators, including FIU personnel, to develop the capacity to implement AML programs, conduct pre-licensing investigations, and audit and inspect casino operations and all games of chance.
In 2009, the CGG provided technical assistance to the government of Kosovo in drafting its casino gaming law. In Costa Rica and Guatemala, OTA provided guidance on the drafting of legislation to regulate the gaming industry and provide for its taxation. The CGG also worked with the Panama Gaming Board to provide a three-week program for new staff, to enhance audit and inspection techniques, and on a program to review and strengthen internal control standards throughout the casinos. In Peru, the CGG provided a basic training program and assessment for the Peruvian Gaming Commission. The Group also worked with Peru in reviewing licensing and audit procedures, along with recommendations for changes to the Peruvian law to strengthen enforcement and licensing capacity. The CGG also assisted the casino regulatory authority (SCJ) in Chile, providing guidance in the implementation of SCJ’s regulatory regime.
In 2009, OTA provided technical assistance to protect insurance systems from money laundering, terrorist financing, and fraud. OTA provided training in AML/CFT compliance programs to Jordanian and Egyptian insurance industry personnel and regulators. Work with the Egyptian insurance regulatory authority concentrated on insurance sector compliance with AML/CFT laws requiring inspections by government regulators and will subsequently focus on antifraud measures. OTA’s expert insurance advisors mentored the insurance regulator in Egypt during an onsite AML/CFT inspection of a large private insurance company, and assisted in drafting the final inspection report. In Argentina, OTA provided a five-day seminar to the staff of the Superintendent of Insurance on AML/CFT compliance, including inspection procedures. In Paraguay, OTA provided four days of training to the insurance regulators on detecting wrongdoing by inside company officials during compliance inspections, and on risk-based inspection procedures, and provided a two-day anti-fraud workshop for both the industry and regulators. In addition, OTA made a presentation at the regional Annual Insurance Law Congress, hosted in Paraguay, on issues relating to the reporting of suspicious transactions.