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 2012, FinCEN hosted representatives from a variety of foreign government agencies, focusing on topics such as money laundering trends and patterns, U.S. anti-money laundering legislation, 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 it is co-sponsoring for membership in the Egmont Group of FIUs. The Egmont Group is comprised of FIUs that agree to share financial intelligence, and has become a key standard-setting body for FIUs. FinCEN is currently co-sponsoring FIUs from eight jurisdictions for Egmont Group membership: China, Dominican Republic, Ghana, Kuwait, Oman, Pakistan, Tanzania, and Yemen. As a member of the Egmont Group, FinCEN also works multilaterally through its participation in the Egmont Training Working Group to design, implement, and instruct Egmont-sponsored training programs for Egmont Group members as well as Egmont candidate FIUs.
FinCEN regularly engages with foreign FIUs 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 2012, FinCEN conducted orientation sessions for the FIUs of Algeria and Tanzania as well as analyst exchanges with the FIUs of Azerbaijan, India, Indonesia, Kazakhstan, Nigeria, Pakistan, Qatar, Saudi Arabia, South Africa, and Thailand.
For calendar year 2012, the Internal Revenue Service, Criminal Investigation (IRS-CI) continued 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 and other sources, IRS-CI delivered training through agency and multi-agency technical assistance programs to international law enforcement agencies. Training consisted of Basic and Intermediate Financial Investigative Techniques, Money Laundering, Public Corruption, Special Investigative Techniques, Bribery Awareness and Terrorist Financing.
Financial Investigative Techniques Training
IRS-CI conducted Financial Investigative Techniques (FIT) courses funded by an interagency agreement between the Department of State and IRS-CI in Algeria, Bosnia and Herzegovina, Cambodia, Egypt, Honduras, Hong Kong, Hungary, Indonesia, Mexico, Montenegro, Nigeria, Singapore, South Korea, and Thailand.
Other Training Initiatives
IRS-CI delivered multiple training programs that were funded through various sources.
Bribery Awareness/Money Laundering training was conducted in cooperation with the Organization for Economic Cooperation and Development. Sessions were held in Korea, Mexico, South Africa, and Turkey. IRS-CI assisted the Department of Justice Office of Overseas Prosecutorial Development, Assistance and Training in delivering training to Mexican government officials on the topics of Financial Intelligence Analysis in Money Laundering Investigations. The Transnational Crimes Affairs Section sponsored a one week Fraud and Public Corruption course that was delivered to 46 participants. This curriculum included an extensive case study which stressed the numerous methods of bribery and corruption.
IRS-CI also assisted the Federal Bureau of Investigation in delivering Terrorist Financing/Money Laundering sessions to over 256 law enforcement officials in Indonesia, Jordan, Kenya, Morocco, Paraguay, Qatar, and Thailand.
International Law Enforcement Academy Training
IRS-CI provided instructor support at the International Law Enforcement Academies (ILEA) located in Bangkok, Thailand; Budapest, Hungary; Gaborone, Botswana; San Salvador, El Salvador; and the satellite office in Lima, Peru.
ILEA Bangkok: IRS-CI participated in one Supervisory Criminal Investigator Course which included 49 law enforcement officials from eight countries. A one-week Fraud and Public Corruption course was presented to 41 participants from nine countries. A FIT course was presented to 49 students from Cambodia, China, Hong Kong, Indonesia, Korea, Laos, Macau, Malaysia, Philippines, Singapore, Thailand, and Vietnam.
ILEA Budapest: IRS-CI participated in delivering five sessions of the ILEA core program. Participating countries include: Albania, Bosnia and Herzegovina, Bulgaria, Croatia, Georgia, Hungary, Kazakhstan, Kosovo, Macedonia, Moldova, Montenegro, Romania, Serbia, and Ukraine. A FIT course was presented to 29 law enforcement officials from Georgia, Moldova, and Serbia.
ILEA Gaborone: IRS-CI provided instructor support for four Law Enforcement Executive Development programs. Countries participating were Benin, Botswana, Burkina Faso, Gambia, Ghana, Guinea, Kenya, Lesotho, Liberia, Mauritius, Namibia, Nigeria, South Africa, Seychelles, Swaziland, Tanzania, Togo, Uganda, and Zambia.
ILEA San Salvador: IRS-CI assisted in the delivery of four sessions of the Law Enforcement Management Development Program (LEMDP). LEMDP stresses the importance of conducting a financial investigation to further develop a large scale criminal investigation. Participants from Antigua and Barbuda, Argentina, Bahamas, Belize, Colombia, Costa Rica, Dominica, El Salvador, Guatemala, Honduras, Jamaica, Panama, St. Kitts and Nevis, St. Vincent and the Grenadines, and Uruguay attended. IRS-CI also led two week-long FIT courses. One session was held at the El Salvador training facility and the other in Lima, Peru. The 78 participants were members of their respective national police agencies and prosecutors’ offices. The FIT course provided an overview of global and regional investigative issues using a highly interactive simulated investigation.
Non-routine Training Events
IRS-CI completed several non-routine training events including sessions in Barbados, Cambodia, and Lithuania. IRS-CI personnel also served as guest instructors for foreign law enforcement training sessions at the Canadian financial intelligence unit. Training needs assessments were completed in China, Honduras and Nigeria.
The U.S. Department of Treasury’s Office of the Comptroller of the Currency (OCC) charters, regulates and supervises all national banks and federal savings associations in the U.S. Its goal is to ensure these institutions operate in a safe and sound manner and comply with all consumer protection and anti-money laundering laws and implementing regulations. In 2012, the OCC sponsored several initiatives to provide anti-money laundering/counter-financing of terrorism (AML/CFT) training to foreign banking supervisors. These initiatives include its annual AML/CFT School, which is designed specifically for foreign banking supervisors to increase their knowledge of money laundering and terrorist financing typologies and improve their ability to examine for and enforce compliance with national laws. The 2012 school was attended by foreign supervisors from Australia, Brazil, Canada, China, Columbia, Ghana, India, Indonesia, Netherlands, Philippines, Singapore, South Korea, and Turkey. The OCC also conducted an AML/CFT School for the Association of Banking Supervisors of the Americas in San Salvador, El Salvador. The school was attended by foreign supervisors from Brazil, Chile, Columbia, Costa Rica, the Dominican Republic, El Salvador, Honduras, Mexico, Nicaragua and Panama. In addition to organizing and conducting schools, OCC officials also met individually, both in the U.S. and overseas, with representatives from foreign law enforcement authorities, financial intelligence units and AML/CFT supervisory agencies to discuss the U.S. AML/CFT regime, the agencies’ risk-based approach to AML/CFT supervision, examination techniques and procedures, and enforcement actions.
The OCC continued its industry outreach efforts to the international banking community during 2012 by participating with other federal banking agencies in regulator panels at the Association of Certified Anti-Money Laundering Specialists’ 11th Annual International Anti-Money Laundering Conference. The focus of the regulator panels was keeping pace with global regulatory changes.
The OCC also participated in a series of Financial Action Task Force (FATF) working group and plenary meetings held in February, June, and October 2012, as well as the Basel Committee on Banking Supervision Anti-Money Laundering Expert Group. On an ad hoc basis, OCC meets with delegations from various countries to discuss the U.S. AML regime and approach to conducting supervisory examinations. In 2012, OCC met with a delegation from China and Columbia.
OTA is part of the Treasury Department and is comprised of five subject-matter teams focused on technical assistance to governments to promote financial sector development. OTA receives direct appropriations funding from the U.S. Congress. Additional funding sources include the U.S. State Department, Bureau of International Narcotics and Law Enforcement Affairs; the U.S. Agency for International Development; U.S. embassies; and the Millennium Challenge Corporation, among others.
The mission of the Economic Crimes Team (ECT) is to provide technical assistance in the development of anti-money laundering/counter-terrorist financing (AML/CFT) regimes. In that context, the ECT also addresses other financial and predicate crimes, including corruption and organized crime. The ECT mission entails a comprehensive approach to technical assistance, and its engagements are predicated on express requests by foreign government counterparts. ECT management conducts an on-site assessment of the jurisdiction, to consider not only non-compliance with international standards and the corresponding need for technical assistance, but also willingness by the counterpart to engage in a partnership with the ECT to address those deficiencies.
An ECT engagement, tailored to the specific conditions of the jurisdiction, may involve placement of a resident advisor (RA) or utilize intermittent advisors, under the coordination of a team leader. The nature of ECT technical assistance is broad and can include awareness-raising aimed at the full range of AML/CFT stakeholders and efforts to improve the legal framework and/or the technical competence of stakeholders. The range of training provided by the ECT is equally broad and includes financial investigative techniques; forensic accounting; financial analytic techniques; cross-border currency movement and trade-based money laundering; supervisory techniques; electronic evidence collection; the use of interagency task forces; and measures to address corruption as well as organized crime.
In 2012, the ECT delivered technical assistance programs in 23 jurisdictions. In the Western Hemisphere, the ECT operated RA programs in Costa Rica, Guatemala, and Honduras, as well as intermittent advisor programs in El Salvador, Guyana, Haiti, Jamaica, Suriname, and Trinidad and Tobago. Highlights for 2012 include an ongoing regional initiative in Central America aimed at cross border movements; a regional law enforcement working group; designated non-financial businesses and professions; money laundering prosecutions; asset management; and AML supervision in the insurance, securities and pension sectors. The ECT also laid the groundwork for program expansion in the Eastern Caribbean in 2013.
In Africa and the Middle East in 2012, the ECT operated RA programs in Botswana, Iraq, Morocco, the Palestinian Authority and Saudi Arabia, as well as an intermittent advisor program in Ghana. Program highlights include support for the development of financial intelligence units in each of those jurisdictions. In Iraq, the ECT program focused its partnership on the Iraqi Commission on Integrity and the interplay among corruption, money laundering and asset recovery.
Likewise, in Europe and Asia in 2012, the ECT operated RA programs in Afghanistan, Kosovo and the Mekong Region (Cambodia and Vietnam) and intermittent programs in Armenia, Azerbaijan, Georgia, Moldova and Turkmenistan. Particular attention was focused on financial analytical and investigative skills development.