The Drug Enforcement Administration’s (DEA’s) Office of Financial Operations (FO) provides expert guidance to DEA’s domestic and foreign offices, as well as international law enforcement agencies, on issues relating to all aspects of financial investigations. FO works in conjunction with DEA offices, foreign counterparts and other agencies to effectively identify the financial infrastructure supporting drug trafficking organizations and provide its financial expertise to fully dismantle and disrupt all aspects of these criminal organizations. Additionally, FO facilitates cooperation among countries, resulting in the identification and prosecution of drug money laundering organizations as well as the seizure of assets and denial of revenue. FO regularly briefs and educates United States diplomats, foreign governmental officials, and military and law enforcement counterparts regarding the latest trends in money laundering, narco-terrorism financing, international banking, offshore corporations, international wire transfers of funds, and financial investigations.
During 2012, FO conducted numerous international seminars for hundreds of foreign law enforcement and military counterparts to strategize regarding effective techniques to be utilized in financial investigations. Some of the foreign officials briefed by FO include representatives from Bulgaria, Colombia, Hong Kong, Italy, Kazakhstan, Macau, Mexico, Nigeria, Peru, Russia, Saudi Arabia, Tajikistan, Turkey and the United Kingdom. Additionally, FO briefed Ambassadors from Costa Rica and Malaysia. During 2012, FO conducted seminars in Costa Rica, Mexico, the Philippines, Trinidad and Tobago, Turkey, and Uruguay. FO also hosted an International Money Laundering Symposium in Ft. Lauderdale, Florida. This symposium was attended by over 120 law enforcement money laundering investigators from 32 countries. These investigators discussed the money laundering trends they were observing in their jurisdictions and effective law enforcement techniques to counter these trends. There were also several presentations concerning emerging money laundering trends being used by criminal organizations around the world.
During 2012, with the assistance of Department of State funding, the Federal Bureau of Investigation (FBI) continued extensive international training in combating terrorist financing, money laundering, financial fraud and complex financial crimes, as well as training in conducting racketeering enterprise investigations. One such training program is the FBI’s International Training and Assistance Unit (ITAU), located at the FBI Academy in Quantico, Virginia. ITAU coordinates with the Terrorist Financing and Operations Section 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 2012, the FBI delivered training to 237 students from 15 countries at ILEA Budapest. At ILEA Bangkok, the FBI provided training to 50 students from nine countries in the Supervisory Criminal Investigators Course. At ILEA Gaborone, the FBI provided training to 164 students from 19 African countries. At ILEA San Salvador, the FBI provided training to 144 students from 19 Latin American countries.
Also in 2012, the FBI and the Internal Revenue Service, Criminal Investigative Division, conducted a one-week course on combating terrorist financing and money laundering for 364 international students from Brazil, Indonesia, Iraq, Jordan, Kenya, Morocco, Paraguay, Qatar, and Turkey.
At the FBI Academy, the FBI included blocks of instruction on combating terrorist financing and/or money laundering for 36 students participating in the Latin American Law Enforcement Executive Development Seminar; the students were from Argentina, Brazil, Chile, Colombia, Costa Rica, Dominican Republic, El Salvador, Panama, and Spain. The FBI included similar blocks of instruction for 23 students participating in the Arabic Language Law Enforcement Executive Development Seminar; the students were from Bahrain, Egypt, Jordon, Kuwait, Lebanon, Libya, Morocco, Palestinian Authority, Saudi Arabia, Tunisia, the United Arab Emirates, and Yemen. In addition, the FBI trained 35 Saudi Arabian students who participated in the first session of the Saudi Arabia Law Enforcement Executive Development Seminar held at the FBI Academy.
In addition, as part of the FBI’s Pacific Training Initiative, the FBI included terrorist financing instruction for 50 participants from Cambodia, Hong Kong, India, Indonesia, Japan, Malaysia, the Philippines, Singapore, South Korea, and Thailand.
Office of Overseas Prosecutorial Development, Assistance and Training’s (OPDAT) Training and Technical Assistance Program
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 the Department of Justice (DOJ), including the Criminal Division’s Asset Forfeiture and Money Laundering Section (AFMLS), the National Security Division’s Counterterrorism Section (CTS), and U.S. Attorney’s Offices to train and advise foreign AML/CFT partners. The training and technical assistance provided by OPDAT is funded through the U.S. Department of State, 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 work directly with counterparts in legal and law enforcement agencies to provide in-country technical assistance to improve capacity, efficiency, and professionalism within foreign criminal justice systems. 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. OPDAT often works with other donors and multilateral organizations as well.
In 2012, OPDAT, AFMLS, and CTS met with and provided presentations to more than 150 international visitors from more than 17 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.
Anti-Money Laundering/Asset Forfeiture/Fraud
In 2012, OPDAT and AFMLS provided assistance in drafting AML statutes compliant with international standards and provided training to foreign judges, prosecutors, and law enforcement officials; legislators; customs, supervisory, and financial intelligence unit personnel; and private sector participants. The content of individual technical assistance programs varied depending on the participants’ specific needs, but topics addressed in 2012 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; real estate fraud; and international mutual legal assistance.
AFMLS experts participated in a variety of conferences and seminars around the world including in Brazil, China, Malaysia, Taiwan, the United Arab Emirates (UAE) and Vietnam. Of note, OPDAT and AFMLS delivered an AML and asset forfeiture training program for an interagency audience of Pakistani government officials in Dubai, UAE. The program focused on identifying, investigating and prosecuting money laundering crimes and managing seized assets. AFMLS was instrumental in designing a core financial investigation and asset recovery program tailored to Pakistan’s law and practice.
AFMLS, an RLA, and co-organizer the People’s Republic of China (PRC) Ministry of Justice, conducted an Asset Recovery Workshop focusing on non-conviction based forfeiture in Beijing, PRC, for approximately 100 participants. The workshop provided the PRC attendees, in particular officials from its legislative committee, an understanding of the operation of a civil forfeiture system, setting the foundation for PRC-requested U.S. assistance on its drafting of proposed domestic civil forfeiture legislation.
In 2012, OPDAT, often in conjunction with other DOJ entities, hosted a number of U.S.-based programs and seminars on international law enforcement cooperation and judicial capacity. An example is AFMLS’ participation in a judicial money laundering seminar organized by the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA), and attended by judges from Superior Courts of common law jurisdictions in West Africa. The seminar was targeted at those at the highest level of decision making in their jurisdictions, and aimed to improve the skills and knowledge of judges concerning economic and financial crimes.
Other 2012 international initiatives include seminars on corruption investigation and prosecution for members of Pakistan’s National Accountability Bureau (NAB) in Islamabad, Lahore, and Karachi, Pakistan. The primary goal of the program was to demonstrate the interagency task force approach to the investigation and prosecution of public corruption.
OPDAT, drawing on the expertise and assistance of other DOJ components, plays 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, AFMLS, and CTS work as integral parts of the U.S. Interagency Terrorist Financing Working Group (TFWG), chaired by the State Department.
In 2012, the TFWG supported five RLAs, located in Bangladesh, Iraq, Kenya, Turkey, and the UAE. The RLA for the UAE is responsible for OPDAT program activities in the UAE, Bahrain, Jordan, Kuwait, Oman, Qatar, Saudi Arabia, and Yemen. Working in countries deemed to be vulnerable to terrorist financing, RLAs focus on money laundering and financial crimes and developing counter-terrorism legislation that comports with international standards. 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 2012 include an AML roundtable in Kenya and assistance to the Government of Kenya on the development of landmark counter-terrorism legislation; and assistance to the Government of Bangladesh on the development of key AML/CFT laws. Additionally, OPDAT organized workshops and seminars for the Turkish Ministry of Justice’s Justice Academy, National Police and Financial Crimes Investigation Board on combating terror financing and prosecutorial approaches/tools to fighting terrorism. The programs presented the participants with investigative tools and techniques with the aim of increasing their capacity to disrupt, dismantle, and prosecute terror financing schemes.
Additional OPDAT conferences were held in Bangladesh, Indonesia, Jordan, the Philippines, and the UAE.