Training and Technical Assistance
During 2010, 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, regulators and supervisors, 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 2010, 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 2010 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. The PALP is nearing completion following its successful program, as evidenced by the new laws, increased capacity and successful investigations completed by participant jurisdictions.
INL also provided support to the UN Global Program against Money Laundering (GPML) in 2010. 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 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 2010, 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)
In addition to its domestic programs to combat and deter money laundering and terrorist financing, internationally, the Board of Governors of the Federal Reserve System (FRB) conducted training and provided technical assistance to banking supervisors in anti-money laundering (AML) and counter-terrorist financing (CFT) tactics in partnership with regional supervisory groups or multilateral institutions. Countries participating in these FRB initiatives in 2010 were Armenia, Aruba, Colombia, Croatia, Czech Republic, Ghana, Hong Kong, India, Indonesia, Italy, Japan, Kenya, Kuwait, Lebanon, Mexico, New Zealand, Nigeria, Peru, Philippines, Portugal, Russia, and Turkey.
Due to the importance 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 (AMLEG). The FRB also is 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 communicate U.S. supervisory expectations and 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), the Federal Bureau of Investigation, and the Internal Revenue Service-Criminal Investigation Division.
Federal Bureau of Investigation (FBI), Department of Justice
During 2010, with the assistance of Department of State funding, the U.S. Federal Bureau of Investigation (FBI) continued its extensive international training in combating money laundering, terrorist financing, 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 of the FBI’s Counterterrorism Division, 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 2010, the FBI delivered training to 245 students from 14 countries at ILEA Budapest. At ILEA Bangkok, the FBI provided training to 55 students from ten countries in the Supervisory Criminal Investigators Course. At ILEA Gaborone, the FBI provided training to 69 students from eight African countries. At ILEA San Salvador, the FBI provided training to 140 students from 17 countries.
Also in 2010, the FBI conducted jointly with the Internal Revenue Service Criminal Investigative Division a one-week course on combating terrorist financing and money laundering for 483 international students from Algeria, Bahrain, Bosnia and Herzegovina, Burkina Faso, Cape Verde, Egypt, Gabon, Guinea-Bissau, Iraq, Jordan, Morocco, Nigeria, Republic of Congo, Saudi Arabia, Senegal, and United Arab Emirates.
At the FBI Academy, the FBI included blocks of instruction on combating terrorist financing and/or money laundering for 37 students participating in Session #14 of the Latin American Law Enforcement Executive Development Seminar; the students were from Argentina, Belize, Brazil, Chile, Costa Rica, Dominican Republic, El Salvador, Honduras, Mexico, Nicaragua, Panama, Paraguay, Peru, Spain, Uruguay and Venezuela. The FBI included similar blocks of instruction for 18 students participating in Session #5 of the Arabic Language Law Enforcement Executive Development Seminar; the students were from Bahrain, Egypt, Iraq, Jordan, Palestine, Qatar, Saudi Arabia, and Sudan.
Also during 2010, the FBI Academy hosted the first session of the Afghan Law Enforcement Executive Development Seminar and provided blocks of instruction on terrorist financing to 23 students from Afghanistan. In addition, the FBI Academy hosted the first session of the Mexican Law Enforcement Executive Development Seminar and provided blocks of instruction on terrorist financing to 32 students from Mexico. In addition, as part of the FBI’s Pacific Training Initiative Session #23, the FBI included terrorist financing instruction for 50 participants from 13 countries; the students were from Australia, Cambodia, China, Hong Kong, India, Indonesia, Japan, Malaysia, the Philippines, Singapore, South Korea, Thailand, and the United States.
Federal Deposit Insurance Corporation (FDIC)
In 2010, 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 65 representatives from Afghanistan, Argentina, Ghana, Iraq, Jordan, Kuwait, Mali, Mauritania, Morocco, Nigeria, Pakistan, Paraguay, Qatar, Senegal, and Turkey. 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 23 supervisory and law enforcement representatives from Bosnia and Herzegovina, Bulgaria, Estonia, Finland, Hungary, Italy, Kosovo, Lithuania, Namibia, Poland, Romania, Slovenia, Spain, Sweden, Ukraine and Zambia 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). In 2010, FinCEN hosted representatives from a variety of foreign government agencies, focusing on topics such as money laundering trends and patterns, the Bank Secrecy Act, the USA PATRIOT ACT, communications systems and databases, and case processing. A number of these visitors were participants in the U.S. Department of State’s International Visitor Leadership Program.
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: China, Dominican Republic, Ghana, 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 engages with 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 2010, FinCEN conducted analyst exchanges with the FIUs of Afghanistan, Brazil, Paraguay, the Philippines, and Senegal.
Immigration and Customs Enforcement, Department of Homeland Security (DHS)
During Fiscal Year 2010, ICE-Homeland Security Investigations (HSI), the investigative arm of the U.S. Department of Homeland Security (DHS), continued its commitment to providing financial investigative training to countries around the world. The HSI Financial, Narcotics, and Special Operations Division, in conjunction with the HSI Office of International Affairs conducted and/or participated in training to foreign law enforcement, regulatory agencies, and bank and trade officials in 13 foreign countries. Utilizing their broad experience and expertise in conducting international financial investigations, HSI designed the training to provide the attendee with the critical skills necessary to successfully identify and investigate financial crimes and included such topics as an introduction to money laundering, bulk cash smuggling, asset forfeiture, unlicensed money services business/informal value transfer systems, prepaid access devices, and interviewing techniques.
Bulk Cash Smuggling
Using primarily U.S. Department of State funding, HSI provided bilateral and multilateral training and technical assistance to host nations which consisted of blocks of training detailing the various aspects of money laundering and the interdiction and investigation of bulk cash smuggling (BCS) for over 591 representatives from 13 countries. Notably, Nigeria, Saudi Arabia, Egypt, Indonesia, Algeria, India, Morocco, the Dominican Republic and HSI personnel participated in one of the first money laundering training seminars ever conducted in Sana’a, Yemen.
Through the U.S. Department of State’s International Law Enforcement Academy (ILEA) programs, HSI conducted 16 financial investigations and anti-money laundering training programs for over 700 participants at various ILEA Training Centers located in Peru, Botswana, El Salvador, and Thailand.
In FY10, HSI continued its partnership with the Organization of American States (OAS) and the United Nations Office on Drugs and Crime (UNODC). HSI participated in a sub-regional workshop in Lima, Peru dedicated to the interdiction and investigation of cross border bulk cash smuggling. More than 40 financial intelligence analysts from financial intelligence units, immigration and customs officials, and prosecutors from Argentina, Bolivia, Brazil, Chile, Colombia, Ecuador, Paraguay, Peru and Uruguay participated in the workshop.
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, HSI 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/HSI 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), HSI worked to expand the network of operational TTUs beyond Colombia, Brazil, Argentina, Paraguay and Mexico. In 2010, Panama officially became the newest member of the TTU network. As part of this new TTU initiative, HSI provided IT equipment and training as well as increased support to this newly established TTU to ensure its successful development.
In 2010, HIS 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, HSI 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 HSI Programs
In 2010, HSI expanded its highly successful Operation Firewall, a joint strategic bulk cash smuggling initiative with U.S. Customs and Border Protection (CBP) to provide hands-on training and capacity building to law enforcement officials around the globe. Operation Firewall was designed to address the threat posed by the bulk cash smuggling via the key facets of transportation to include movement within the continental United States and cross-border smuggling through the various air, sea, and land ports of entry. In FY 2010, Operation Firewall resulted in 1,367 seizures totaling in excess of $133 million in U.S. currency and negotiable instruments and to date has resulted in the seizure of more than $411 million dollars.
Under the HSI 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 the Cornerstone initiative, HSI has dedicated field and headquarters agents who are charged with providing training to the financial and trade communities on identifying and preventing exploitation by criminal and terrorist organizations. In FY 2010, HSI Cornerstone liaisons conducted 2,419 outreach presentations for more than 45,179 industry professionals in the U.S. and abroad.
Internal Revenue Service (IRS), Criminal Investigative Division (CID), Department of Treasury
In 2010, the U.S. Internal Revenue Service (IRS) Criminal Investigation Division 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. To complement its independent programs, IRS-CID partnered with several USG and multilateral organizations, including agencies and offices of the U.S. Departments of State, Justice, Treasury and Defense; INTERPOL; the Organization for Economic Co-operation and Development (OECD); and the governments of Greece, Norway and South Korea to deliver a variety of programs. Training consisted of Basic and Advanced Financial Investigative Techniques, and topics addressing the detection and deterrence of money laundering and terrorist financing. Each course was tailored to meet the needs of the relevant participating countries, with varying emphasis on drug trafficking, corruption, methods of proof, tax crimes, customs violations and mock investigations.
Financial Investigative Techniques Training
IRS-CID conducted Financial Investigative Techniques (FIT) courses in the following locations:
Bosnia and Herzegovina –Participants included 57 representatives from the Prosecutor’s Office, Financial Intelligence Department, State Investigative and Protection Agency, Financial Police, Tax Authorities and other police organizations.
Indonesia –Seventy-two participants from the Indonesia National Police, Attorney General’s Office, Financial Transaction Reports and Analysis Center, Immigration, and Corruption Commission attended this training. Additionally, prosecutors from Timor-Leste participated.
South Africa – Ninety-two participants from the South African Revenue Service received training in Pretoria, Capetown and Johannesburg.
Albania –Attendees included 34 participants assigned to the Albanian Joint Investigative Units. Another course included 30 members of the newly formed Criminal Investigations section of the Albanian Tax Authority.
Colombia –The 29 participants included investigators from the Colombian National Police, members of the Attorney General’s investigative body and analysts from the Colombian Financial Investigative Unit.
Cambodia –Approximately 35 members of the National Police Counter Drugs Force, Financial Institutions, Financial Investigative units and Anti-Corruption units from Cambodia received training.
Mexico – The training was presented to 53 Mexican Federal Police officers, investigators, prosecutors, and investigative analysts. The course is part of the Merida initiative which supports bilateral cooperation between the US and Mexico. Also, two advanced FIT classes were delivered to 52 Mexican prosecutors, accountants, investigative analysts and federal agents.
Estonia – A modified FIT training course was delivered to investigators from the Estonia Tax and Customs Board and prosecutors. The training was provided at the request of the Estonian Tax and Customs Board.
Norway – A course funded by the government of Norway was presented to 24 participants, including police investigators, customs officers, and investigators/advisers to the Norwegian Tax Directorate that specialized in economic crimes, customs violations, and/or tax crimes.
Greece – Approximately 60 participants from the Hellenic National Police and the SDOE, a Special Financial Investigative Unit, participated in FIT courses based on a direct agreement with the government of Greece.
South Korea – IRS-CID trained 30 participants from the National Tax Service in cooperation with the South Korean government.
Other Training Initiatives
Various non-FIT training initiatives were delivered by IRS-CID in conjunction with other agencies. These include:
Thailand –The Transnational Crime Affairs Section sponsored three Complex Financial Investigations (CFI) courses given to a total of 159 participants. Participants included members of the Anti-Money Laundering Office (AMLO), bank examiners, the Royal Thai Police, and Thailand Border Patrol.
Mexico – The International Money Laundering/Criminal Organizations and Illicit Financing course introduced 215 Mexican federal prosecutors, accountants, and law enforcement officials to various aspects of the U.S. judicial system including: money laundering, direct examination, Ponzi schemes, and forfeiture.
Two sessions of Evidence Seizure and Chain of Custody introduced Mexican law enforcement officials to the U.S. based legal system for executing search warrants, seizing evidence, and preserving the chain of custody. The goal is to help prepare Mexican federal officials to investigate and prosecute criminal cases using the accusatorial system.
An Electronic Crimes and Financial Crime Scene presentation was given to money laundering investigators of the Federal Police Anti-Money Laundering Unit and Ministry of Justice Judicial Police.
IRS-CID participated in delivering training to combat terrorist financing and money laundering in Algeria, Bosnia and Herzegovina, Egypt, Iraq, Jordan, Morocco, Nigeria, Philippines, Senegal, and United Arab Emirates.
International Law Enforcement Academy Training
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 also participated in three sessions of Complex Financial Investigations. The 159 participants represented various law enforcement agencies from the following countries: Brunei, Cambodia, China, Hong Kong, Indonesia, Laos, Macau, Malaysia, Philippines, Singapore, Thailand, Timor-Leste and Vietnam.
At ILEA Budapest: IRS-CID participated in delivering five sessions of Financial Investigative Techniques training. Participating countries included: Albania, Bosnia and Herzevonia, Bulgaria, Croatia, Georgia, Hungary, Kazakhstan, Kosovo, Macedonia, Moldova, Montenegro, Serbia, Slovenia, Tajikistan and Ukraine. IRS-CID provided a class coordinator for ILEA 78 who was responsible for coordinating and supervising the participants’ daily duties and activities. IRS-CID also provided the key note speaker for the graduation of ILEA 78.
At ILEA Gaborone: IRS-CID participated in four Law Enforcement Executive Development programs. Countries that participated were Angola, Botswana, Cameroon, Djibouti, Ethiopia, Ghana, Guinea, Mauritius, Mozambique, Republic of Congo, Seychelles, South Africa, Uganda and Zambia.
At ILEA San Salvador: IRS-CID assisted in the delivery of four FIT courses for the Law Enforcement Management Development Programs (LEMDP). Participating countries were Antigua and Barbuda, Argentina, Bahamas, Barbados, Brazil, Chile, Colombia, Costa Rica, Dominica, El Salvador, Grenada, Guatemala, Mexico, Paraguay, Peru, St. Kitts and Nevis, St. Lucia, St. Vincent and the Grenadines, and Uruguay.
IRS-CID led a Financial Investigative Techniques/Money Laundering course funded by the ILEA at the Regional Training Center in Lima, Peru. The 33 participants from Argentina, Brazil, Chile, and Peru were members of their respective national police agencies and prosecutors’ offices.
Non-routine Training Events
Employees of IRS-CID International Operations also completed several non�'routine training events.
Members from IRS-CID International Operations attended a joint Mexico-US workshop that focused on arms trafficking and money laundering by Mexican narcotics cartels. The conference sponsored by the U.S. Ambassador to Mexico, brought together high ranking law enforcement, prosecutorial and regulatory officials from both countries.
In conjunction with the Office of Economic Development and Cooperation (OECD) and the Treasury Executive Office for Asset Forfeiture, IRS�'CID led a multi-national training team to develop and present a three-day training symposium in Washington D.C. The symposium consisted of money laundering and bribery awareness for tax examiners. The course was attended by 58 examiners and auditors of 20 countries. IRS-CID also attended an OECD meeting in Paris, France.
Members of International Operations participated in meetings with the International Criminal Police Organization (INTERPOL) and with a delegation from South Korea. INTERPOL’s working group on Money Laundering and Terrorist Financing met to provide advice on developing INTERPOL’s ability to facilitate money laundering and terrorist financing investigations through effective information sharing. The meeting with officials from South Korea culminated in the signing of a Simultaneous Criminal Investigation Program between the IRS and the National Tax Service of South Korea.
IRS-CID Narcotics and Counterterrorism (NCT) participated in the South Asia Regional Workshop held in Kathmandu, Nepal. NCT discussed domestic/international coordination of investigations and how IRS-CID can add value to terrorism investigations.
A tax and fraud training session organized by the U.S. Department of Justice’s Office of Overseas Prosecutorial Development, Assistance and Training Resident Legal Advisor together with the Georgian Ministry of Justice Prosecutor’s Service was held in the Republic of Georgia. The training, presented to 120 Ministration of Finance prosecutors and investigators, focused on case development, case assessment and evidence gathering.
IRS-CID attaché in Australia participated in two training sessions. A seminar for the International Association of Financial Crime Investigators focused on the IRS investigative mission and the benefits of law enforcement working together on a global level. Attendees included 130 participants from various Australian agencies and other fraud investigative entities. Another session presented to the Australian Taxation Office (ATO) provided an overview of the IRS and CID’s international mission. This training included approximately 50 participants from several sections within ATO.
Training assessments for Bosnia and Herzegovina, Cambodia and the Philippines were completed during 2010.
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) works with other federal banking agencies to provide training to foreign banking supervisors. The OCC sponsored several initiatives to provide anti-money laundering/counter–terrorist financing (AML/CFT) training to foreign banking supervisors in 2010. 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 12 countries, including Australia, Brazil, China, India, Indonesia, Italy, Malaysia, Netherlands, Philippines, South Korea, Sri Lanka, Turkey, and Uruguay attended the school held at the OCC’s Washington, D.C., headquarters. OCC officials also met with a delegation of South Korean FIU 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 hosted two foreign bank regulators from Uruguay and Argentina to participate in a three week OCC AML examination.
OCC continued its industry outreach efforts to the International banking community. OCC officials delivered AML/CFT presentations at the MoneyLaundering.com 15th Annual Anti-Money Laundering Conference, attended by more than 1,000 AML professionals from 50 countries; and the institute of International Bankers Annual Anti-Money Laundering Seminar, hosting attendees from 30 countries. OCC also participated in an AML/CFT presentation and conducted a separate workshop at the Kuwait Anti-Money Laundering Conference. The OCC also provided instructors for a workshop organized by the Association of Banking Supervisors of the Americas (ASBA) and hosted by the Superintendencia de Banca y Seguros, Peru that was attended by 29 supervisors from Argentina, Bolivia, Brazil, Ecuador, Paraguay, and Peru.
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), 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 (CTS) and the Office of Law and Policy of the National Security Division (collectively, “NSD”) , and U.S. Attorney’s Offices to train and advise foreign AML/CFT partners. Much of the assistance provided by OPDAT, AFMLS, NSD and other DOJ components 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 to work directly with counterparts in foreign 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, and judges. RLAs also work in collaboration with DOJ’s International Criminal Investigative Training Assistance Program (ICITAP) to train police and other investigative officials. OPDAT’s work is coordinated closely with that of other donors and multilateral organizations. For all programs, OPDAT draws upon expertise from DOJ’s Criminal Division, NSD, AFMLS, and other DOJ components as needed.
In 2010, OPDAT, AFMLS, and CTS met with and provided presentations to more than 244 international visitors from more than 20 countries on AML and/or CFT topics. Presentations covered U.S. policies to combat terrorism, U.S. legislation, 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 2010, OPDAT organized training for 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 2010 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.
OPDAT-provided Training and Technical Assistance
In 2010, OPDAT led or participated in training programs and seminars addressing the following topics, all tailored to the region or individual country: asset forfeiture seminars for Southeast Europe, Indonesia, Cameroon, Moldova, Montenegro, and Mexico; complex financial crime investigation and prosecution programs for Jordan, Bangladesh, Turkey, Indonesia, Ukraine, Kosovo, Albania and Mexico; anti-corruption programs for Indonesia, Georgia, Kyrgyzstan, Albania, Montenegro, Armenia, Kazakhstan, Ukraine, Serbia, Tajikistan, Yemen, Liberia, Cameroon, Rwanda, Uganda, Tanzania, and Sierra Leone; mutual legal assistance programs for Ukraine and Southeast Europe, Indonesia, and Mexico; and AML/CFT-related seminars for Saudi Arabia, Jordan, Uganda, Bangladesh, Indonesia, Kuwait and Turkey. Additionally, Turkish, Bangladeshi and Indonesian officials participated in study tours to the United States to observe how the U.S. investigates and prosecutes complex financial crimes and corruption.
In February and September 2010, with support from NSD, OPDAT organized conferences in Turkey designed to promote regional counter-terrorism cooperation. The first conference consisted of representatives from Albania, Bulgaria, Greece, Macedonia, and Turkey, while the second conference included representatives from Egypt, Jordan, Lebanon, and Turkey.
In March, OPDAT , again with the support of NSD, hosted a study visit to Washington for Turkish Ministry of Justice and financial crimes agency officials charged with drafting and refining legislation related to criminalizing terrorist financing, freezing terrorist assets, and designating terrorist organizations.
In May, OPDAT hosted a Southeast Asia Regional Asset Forfeiture Conference in Jakarta for representatives from twelve Southeast Asian Countries (Vietnam, Laos, Thailand, Bangladesh, Malaysia, Indonesia, Hong Kong, Taiwan, Timor Leste, France, United States and Australia). The conference focused on encouraging countries in the region to enact asset forfeiture legislation and use it effectively through international cooperation.
In June, OPDAT co-sponsored a bulk cash smuggling training program for Turkish law enforcement officers in Istanbul, Turkey. The training focused on the interdiction and investigation of cross-border bulk cash smuggling, with emphasis on money laundering and terrorist financing.
In July, OPDAT co-sponsored two sessions of a workshop focusing on enforcement measures against money laundering, terrorist finance, and other financial crimes for Jordanian officials in Amman, Jordan. The program emphasized the respective roles of financial crimes analysts, investigators, prosecutors and judges in addressing financial crimes.
In September, OPDAT co-sponsored with the Treasury Department a regional workshop examining the roles of the financial intelligence unit, law enforcement officers, and prosecutors in Amman, Jordan for officials from Jordan, Egypt, Saudi Arabia, Iraq, Lebanon, Yemen, and the Palestinian Authority. The program provided a framework for discussion of stakeholder roles in money laundering efforts, financial investigative techniques, and international cooperation.
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).
OPDAT-Provided Training and Technical Assistance
The TFWG supports four RLAs assigned overseas, located in Bangladesh, Kenya, Turkey, and the United Arab Emirates (UAE). The RLA for the UAE 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 TFWG also supports OPDAT implemented projects in Indonesia, working through the INL-funded RLA posted there. 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 country’s AML/CFT efforts. Some highlights of the RLAs’ efforts in 2010 include:
In Bangladesh, OPDAT organized a U.S.-based study visit for senior members of Bangladesh’s law enforcement community and provided technical assistance to the Bangladeshi National Coordinating Committee formed to combat financial crimes by reviewing Bangladesh’s AML/CFT legislation. The US visit helped to facilitate a better understanding between the US and Bangladesh of their respective anti-terror efforts, enhanced multi-lateral counter-terrorism ties, and stimulated possible future actions related to anti-money laundering; combating terrorism and terrorist financing; and asset recovery and mutual legal assistance.
In Indonesia, the RLA continued to engage the Attorney General’s Terrorism and Transnational Crime Task Force, which OPDAT has supported since its establishment 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 Turkey, the RLA hosted regional conferences designed to promote regional counter-terrorism cooperation. In this ongoing project, the RLA continues to focus on regional, pro-active strategies to fight terrorism and its related crimes. This project is designed to foster mentoring relationships among law enforcement of the respective participating countries.
In Kenya, the RLA provided support to the Kenyan government, U.S. authorities, and the international community in the prosecutions of Somali pirates. The RLA addressed Kenya’s piracy law, criminal elements of piracy, best practices in these cases, and the need for modernizing evidence practice in Kenya through multiple training sessions delivered in Kenya. The RLA also delivered counter-piracy training programs to officials from the Seychelles and Mauritius.
In the UAE and Gulf Region, the RLA focused on initiatives involving enforcement measures against money laundering and financial crimes in Jordan, and assistance to regulators, customs personnel and prosecutors to combat bulk cash smuggling in the UAE. These efforts are part of a region-wide initiative to address threat finance and money laundering.
In 2010, 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: international cooperation in combating terrorism in Uganda, terrorist financing investigations and prosecutions in Qatar, Saudi Arabia, Bangladesh, and Indonesia; and counter-piracy seminars in Kenya, Mauritius, Seychelles and Tanzania.
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. The economic crimes program offers technical assistance to combat money laundering, terrorist financing, and other financial crimes.
Fifty-three 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 funding from the U.S. Congress, and funding from the U.S. Department of State’s Bureau for International Narcotics and Law Enforcement Affairs, 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 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. In 2010, OTA conducted assessments and/or developed new technical assistance plans in Bosnia and Herzegovina, Costa Rica, El Salvador, Georgia, Guatemala, Guyana, Honduras, and Uruguay.
Regional and Resident Advisors
OTA Regional Advisors and Resident Advisors 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 technical assistance activities.
Africa and Middle East: The Regional Advisor serves as the U.S representative for the MENA FATF Technical Assistance and Topology Working Group and is a member of U.S. delegations to three FATF-style regional bodies in his region. The region has resident advisors in Botswana, Jordan, Iraq, Ghana and Morocco and intermittent projects in Sao Tome and Principe, Lesotho, Palestine, Algeria and Saudi Arabia.
In Eastern and Southern Africa, OTA placed a resident advisor in Botswana to work with the newly established financial intelligence unit (FIU) and to also provide assistance on an intermittent basis to Lesotho as that country implements its AML/CFT legislation and establishes an FIU. In Lesotho, OTA provided assistance in identifying required amendments to AML/CFT legislation, drafted implementing AML/CFT regulations, drafted a position description for the FIU Director’s position, reviewed the proposed FIU budget, and assisted in planning outreach activities for public and private institutions. In Botswana the OTA resident has finalized an AML/CFT technical assistance work plan, trained FIU staff, assisted in the development of a 2011 budget for the FIU, and played a key role in getting an interim FIU Director appointed.
In West Africa, a resident advisor was placed in Ghana and is co-located in the FIU, providing assistance to bring it to an operational level and to address deficiencies in the country’s AML/CFT regime. In 2010, the advisor focused on assisting the FIU with the FATF International Cooperation Review Group (ICRG) monitoring process, assisted in the 2011 budget development, improved the FIU data management process, assisted in the development of a currency declaration form, and coordinated an OTA Information Technology (IT) assessment to initiate the IT development process for the FIU.
In North Africa, a resident advisor was placed in Morocco in December 2010 to provide technical assistance to the FIU, Central Bank and other AML/CFT stakeholders. Technical assistance to Algeria will continue and focus on AML/CFT gaps identified in its recently adopted mutual evaluation report.
In the Middle East, a resident advisor was placed in Iraq with a focus to work with Iraq’s Money Laundering Reporting Office (MLRO) and other AML/CFT stakeholders in passing new legislation and improving regulatory, investigative and prosecutorial capacity to combat serious financial crimes. OTA participated in anti-money laundering and anti-corruption workshops for Iraqi officials and mentored investigators and prosecutors on complex money laundering and terrorist financing cases.
Europe and Asia: OTA’s Regional Advisor for is a member of the US delegation to the Asia Pacific Group on Money Laundering (APG) and actively participates in the activities of the APG’s Technical Assistance and Training group. In early 2010, OTA placed two additional resident advisors in Afghanistan: one with the Major Crimes Task Force (MCTF); and one banking AML/CFT specialist to work with the AML/CFT section of the supervisory section of the Central Bank. OTA also placed Economic Crimes RAs in Vietnam and Kosovo in early 2010.
The RA in Afghanistan continued to focus on development of the Afghan FIU. OTA placed a second advisor with the Afghan MCTF to teach financial investigative techniques, mentor investigation of economic crimes, mentor processes associated with asset seizure, and orient investigative conduct toward prosecution. The MCTF’s responsibility for economic crimes investigations was expanded in 2010 to include tax evasion by individual and commercial entities in which the FIU occupies a critically supportive role. Two one week bulk cash smuggling & money laundering training courses were developed and conducted for the MCTF as part of joint OTA/DHS Immigration and Customs Enforcement-Homeland Security Investigations training endeavors. Significant improvement, regarding the extent and quality of routine coordination occurring between the MCTF and FIU, was achieved in 2010. OTA also helped prepare the Afghan Government for the IMF mutual evaluation of its AML/CFT regime. OTA placed a third advisor in the supervision department of Afghanistan’s Central Bank (DAB) to provide mentoring on hawala licensing and bank and hawala examination procedures. This advisor has developed and conducted training on bank AML/CFT inspection procedures for DAB staff.
OTA placed a new resident advisor in Kosovo in early 2010. The OTA resident advisor provided assistance in the drafting and reviewing of Kosovo’s Law on the Prevention of Money Laundering and Terrorist Financing, which was passed by Parliament and subsequently signed by the President in November 2010. OTA continues to provide mentoring, advice, and other development assistance to FIU management, analysts and other staff. OTA initiated a working group to develop a Suspicious Activities Report awareness training program that will be delivered to Kosovo’s financial institutions.
The resident advisor in the Mekong Region continued to deliver resident-based TA to Vietnam, Cambodia, and Laos according to assessed needs in each jurisdiction.
Western Hemisphere: During 2010 OTA substantially increased its presence in the Western Hemisphere, placing resident advisors in Mexico (March), Costa Rica (June), Guatemala (August), and Honduras (September). In Mexico, OTA continued its work with that country’s law enforcement community providing Financial Investigative Techniques as well as workshops to foment interagency coordination in advanced money laundering investigations. Additionally, OTA began work in earnest with Mexico’s Tax and National Bank authorities in the development of a supervisory regime for money remitters. OTA continued its work with the FIUs of Mexico and Uruguay by providing training seminars and mentoring.
OTA’s resident advisor in Paraguay continued work with Customs to enhance its capacity to fight smuggling and tax evasion, and the undervaluation and under-registration of goods, improve its internal control and investigation capability and, as a result, reduce corruption in the customs sector. Controls over the importation and exportation of goods have been substantially enhanced; opportunities for corruption substantially decreased; and, customs revenues have increased. OTA also continued work in Paraguay to help that country’s FIU renew and stand up its IT system.
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 and 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.
In Sao Tome and Principe OTA continues implementation of an MCC-funded project with customs authorities 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.
In Algeria, Palestine, and Saudi Arabia advisors provided technical assistance to enhance the operational capacity of FIUs. This assistance involved institutional building, analytical training, IT assessments, budget and facilities development, strategy development, legislative review, regulation drafting, mentoring, cross border monitoring and outreach to public and private institutions on AML/CFT responsibilities. During 2010, OTA worked with prosecutors from the Palestinian Attorney General’s office providing mentoring in complex financial crimes cases. A Financial Investigative Techniques Course (FIT) was conducted for the Saudi Arabia FIU and other officials in September 2010. A regional FIU workshop focusing on the FIU relationship with law enforcement and international cooperation was conducted for officials from Jordan, Saudi Arabia, Egypt, Palestine Authority, Yemen, and Iraq in September 2010. A study tour visit was organized for Jordanian FIU officials to visit the Lebanese Special Investigation Commission (SIC), Lebanon’s FIU.
A regional Middle East North Africa AML/CFT training project, initiated in 2007 and funded by USAID, concluded in September 2010 after conducting eight major regional events covering topics such as corruption, bulk cash smuggling, task force investigations, financial analysis, financial investigations, targeted economic sanctions, FIU operations and international cooperation. Approximately 235 individuals participated in these training events.
In Vietnam, suspicious activity reporting training was delivered to compliance and executive staff of all 84 licensed banks, AML examination training was delivered to the State Bank of Vietnam, and mentoring was delivered to FIU staff. Development of internal financial investigation training curricula commenced with OTA assistance at the Ministry of Public Security’s Police Academy, as well as at the State Customs Academy. In Cambodia, OTA is assisting with development of an electronic reporting system for suspicious activity and large cash transaction reports. In Laos, OTA conducted a legislative assessment with the Laotian Anti-Money Laundering Intelligence Unit (AMLIU). OTA assisted Laos in preparing for its APG mutual evaluation, funding translation of the mutual evaluation questionnaire and other key documents, and delivering preparatory training for completion of the questionnaire in conjunction with APG and UNODC.
In Georgia, OTA conducted a FIT course for law enforcement investigators and prosecutors. Due to the high level of interest, OTA delivered three separate FIT courses and two separate Advanced Money Laundering Analysis courses to Kosovo’s enforcement and regulatory agencies. Technical assistance was provided to the Kosovo Tax Administration in drafting the criminal tax amendment and OTA is also assisting in drafting the new criminal tax procedures manual.
In the Americas during 2010, OTA delivered technical assistance in Argentina, Costa Rica, El Salvador, Guatemala, Haiti, Honduras, Mexico, Paraguay, and Uruguay. In Argentina, OTA delivered a workshop focused on money laundering through the Securities Sector to staff of the National Banking and Securities Commission, Argentine prosecutors, financial crimes investigators and FIU staff members plus Uruguayan officials. In Uruguay, OTA led a workshop focused on the Enterprise Theory of Investigation for Organized Crime; there were participants from Paraguay. OTA also continued to work closely with the Mexican tax authority and the Mexican banking securities supervisor to assist their efforts to develop a regulatory and supervisory regime for money service businesses. In Haiti, OTA continued its program to assist the Government of Haiti draft reforms for its outdated Criminal and Criminal Procedural and Tax Codes, as well provide continued training and mentoring for analysts at its financial intelligence unit and analysts, investigators and prosecutors in a companion financial crimes investigative task force unit. Finally, 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.
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.
Financial Analysis Techniques Training
Globally, OTA delivered the Financial Analysis Training Course (FATC) to analysts in the financial intelligence units of Georgia, Jordan, Kosovo, Mexico, Pakistan, Singapore, Uruguay, and Vietnam. Regional training co-sponsored with the IMF in Singapore included participants from Cambodia, Indonesia, Laos, Malaysia, Nepal, Pakistan, Thailand, and Vietnam.
Looking forward, and in response to a demand for advanced training, OTA continued development of its Advanced FATC, adding modules on: corruption; international cooperation; the black market peso exchange system; advanced transactional analysis and targeting. In anticipation of using these and other FATC modules in Central America, the foregoing materials have been translated into Spanish. OTA is working on translating these same materials into French for use in francophone Africa. This course was presented to analysts from Jordan, Kosovo, Palestine and Vietnam.
Casinos and Gaming
In 2010 the Casino Gaming Group (CGG) experts from OTA’s Economic Crimes program provided technical assistance to the international community in the area of gaming industry regulation. The CGG provides assistance in the drafting of gaming legislation and implementing regulations, and trains gaming regulators and FIU personnel to develop the capacity for implementing AML programs, conduct pre-licensing investigations, and audit and inspect casino operations and all games of chance.
In 2010 the CGG followed up on assistance provided in 2009 to both Costa Rica and Guatemala in the creation of draft gaming laws. In both countries the draft laws are before the National Assemblies and, in 2010, CGG advisors worked with both governments and legislators resolving issues and answering questions. It is anticipated that both laws will be enacted in 2011. In the current form both laws would meet international standards. Additionally, meetings have been held with regulators in Argentina, Ecuador and Mexico to work toward enhancing gaming regulations.
The draft Kosovo Law on Games of Chance was submitted to the Minister, Ministry of Economy and Finance in February 2010. The CGG worked extensively with the Ministry in the creation of this law. Following subsequent submission and review of alternative proposals, a meeting between OTA and Kosovar authorities is scheduled for January 2011 to finalize the law for presentation to the Minister.
CGG conducted assessments of the casino regulatory systems and gaming laws in Armenia and Georgia.
In 2010 OTA in conjunction with the New York Insurance Commission provided separate week long insurance fraud training courses to insurance regulators in Egypt and Jordan. This followed assistance to the Egypt Insurance Supervisory Authority (EISA) in planning and conducting its first insurance AML/CFT examination.
 The mission of the National Security Division is to combat terrorism and other threats to national security.