Training and Technical Assistance
During 2011, 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.
Board of Governors of the Federal Reserve System (FRB)
An important component in the United States’ efforts to combat and deter money laundering and terrorist financing is to verify that supervised financial organizations comply with the U.S. anti-money laundering/combating the financing of terrorism (AML/CFT) laws and have programs in place to comply with the Office of Foreign Assets Control (OFAC) sanctions.
Internationally, the FRB conducted training and provided technical assistance to banking supervisors in AML/CFT tactics in partnership with regional supervisory groups or multilateral institutions in Aruba, India, and Colombia, as well as in Washington, D.C. Countries participating in these FRB initiatives in 2011 were Argentina, Armenia, Aruba, Bahamas, Brazil, British Virgin Islands, Colombia, Curacao, Czech Republic, Ghana, Hong Kong, India, Indonesia, Jamaica, Kuwait, Lebanon, Malaysia, Mauritius, Mongolia, Nigeria, Paraguay, Philippines, Russia, Saudi Arabia, Singapore, Slovakia, Thailand, Trinidad, and Zambia.
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 is also an active participant in the U.S. Treasury Department’s ongoing Private Sector Dialogue conferences. Staff also meets frequently with industry groups and foreign supervisors to communicate U.S. supervisory expectations and support industry best practices in this area.
Department of Homeland Security (DHS)
Immigration and Customs Enforcement (ICE)
During Fiscal Year 2011, 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 Illicit Finance and Proceeds of Crime Unit conducted and/or participated in training provided to over 900 members of foreign law enforcement, regulatory agencies, and bank and trade officials from over 25 nations around the world. Utilizing their broad experience and expertise in conducting international financial investigations, HSI designed the training to provide the attendees with the critical skills necessary to successfully identify and investigate financial crimes. The programs included such topics as an introduction to money laundering, investigating bulk cash smuggling, asset forfeiture, an overview of unlicensed money services business/informal value transfer systems, prepaid access devices, and interviewing techniques.
Cross Border Financial Investigations Training Seminar
The Cross Border Financial Investigation Training (CBFIT) program provides specialized training, technical assistance and best practices related to cross-border financial investigations to foreign law enforcement personnel, intelligence and administrative agencies, and judicial authorities.
CBFIT provides foreign partners with the capability to effectively implement international standards, with special emphasis on new technologies, dissuasive actions, competent authorities, international cooperation, alternative remittance, and cash couriers, among others.
Using primarily U.S. Department of State funding, HSI provided to host nations bilateral and multilateral training and technical assistance which consisted of blocks of training detailing the various aspects of money laundering and sharing of best practices on how to initiate multi-jurisdictional investigations from interdiction incidents. These countries included: Afghanistan, Bolivia, Brazil, Colombia, Dominican Republic, Egypt, Ethiopia, Indonesia, Mexico, Morocco, Panama, Paraguay, Peru, and Saudi Arabia, among others.
Through the U.S. Department of State’s International Law Enforcement Academy (ILEA) programs, HSI conducted financial investigations and anti-money laundering training programs at various ILEA Training Centers.
Resident Cross Border Financial Investigations Advisor
HSI Special Agents and Intelligence Analysts have been deployed for extended periods of time to foreign posts to serve as Resident Cross Border Financial Investigations Advisors (R/CBFIA). The R/CBFIA acts as the point of contact to host nation authorities for the coordination of training sessions. Once training is completed, the R/CBFIA remains available for in–person and/or telephone mentoring of host nation partners related to incidents involving the discovery/interdiction of currency or other financial instruments. This provides the host nation participants the opportunity to employ the material, tactics and technology learned in the classroom in a real world setting, while at the same time having the benefit of the experience, guidance and investigative resources of the R/CBFIA. The R/CBFIA utilizes this knowledge to update training aids/material by incorporating lessons learned from these incidents. In FY 2011, R/CBFIAs were deployed to the Philippines, Paraguay and Argentina.
Trade Transparency Units
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, HSI worked to expand the network of operational TTUs beyond Colombia, Brazil, Argentina, Paraguay, Mexico and Panama. In 2011, Ecuador 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 2011, HSI updated the technical capabilities of existing TTUs and trained new and existing TTU personnel from Brazil, Colombia, Paraguay, Argentina, Mexico, Panama and Ecuador, 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 U.S. Government and foreign TTUs in furtherance of ongoing joint criminal investigations.
USG and Non-USG Partners
In FY11, HSI expanded its partnership and collaboration with a number of U.S. Government and non-U.S. Government agencies. HSI collaborated with the Department of Justice (DOJ) Asset Forfeiture and Money Laundering Section as well as DOJ Office of Overseas Prosecutorial Development and Training, the International Judicial Relations Committee, Treasury Office of Technical Assistance and the U.S. Army Western Hemisphere Institute for Security Cooperation. HSI contributed or partnered with these entities to deliver financial investigations best practices to members of the law enforcement community.
HSI maintains a robust relationship with international organizations like the Organization of American States, the United Nations Office on Drugs and Crime and the South America Financial Action Task Force. HSI provided subject matter expertise during sub-regional workshops held in Costa Rica, Antigua, Ethiopia, Bolivia and Moldova. The workshops addressed best practices in the implementation of anti-money laundering and counter-financing of terrorism regimes.
Department of Justice
Drug Enforcement Agency (DEA)
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 regarding issues related to all aspects of financial investigations. FO works with DEA offices, foreign counterparts and other agencies to identify the financial infrastructure supporting drug trafficking organizations and provides the financial expertise to fully dismantle and disrupt all aspects of these criminal organizations. FO facilitates cooperation between countries, resulting in the identification and prosecution of drug money laundering organizations as well as the seizure of assets and the denial of revenue. FO regularly briefs and educates United States diplomats, foreign governmental officials, 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 2011, FO conducted numerous international symposiums 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 Afghanistan, Australia, Brazil, Dominican Republic, Ecuador, El Salvador, Germany, Italy, Kazakhstan, Netherlands, Nicaragua, Paraguay, Peru, The Philippines, Romania, Saudi Arabia, Sierra Leone, Turkey, United Kingdom, and Uzbekistan. During 2011, FO conducted seminars in Albania, Bahamas, Belgium, Colombia, Costa Rica, Dominican Republic, Guatemala, Iceland, Kazakhstan, Mexico, Paraguay, Poland, Qatar, Romania, Russia, Sweden, Thailand, Turkey, and Uzbekistan. In 2011, FO and the Dutch National Police hosted an International Money Laundering Symposium in The Hague, Netherlands. This symposium was attended by over 110 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.
Federal Bureau of Investigation (FBI)
During 2011, with the assistance of the Department of State funding, the U.S. Federal Bureau of Investigation (FBI) continued its extensive international training in combating terrorist financing, money laundering, financial fraud and complex financial crimes, as well as training in conducting racketeering enterprise investigations. One such training program is the FBI’s International Training And Assistance Unit (ITAU), located at the FBI academy in Quantico, Virginia. ITAU coordinates with the terrorist financing and operations section 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 2011, the FBI delivered training to 192 students from ten countries at ILEA Budapest. At ILEA Bangkok, the FBI provided training to 47 students from nine countries in the supervisory criminal investigators course. At ILEA Gaborone, the FBI provided training to 161 students from 18 African countries. At ILEA San Salvador, the FBI provided training to 137 students from 19 countries.
Also in 2011, the FBI conducted, jointly with the internal revenue service criminal investigative division, a one-week course on combating terrorist financing and money laundering for 135 international students from Algeria, Pakistan, and Yemen. In addition, the FBI did terrorism investigation training in Thailand, financial crimes training in Trinidad and Tobago, and money laundering training in Serbia and Mexico for 241 international students.
At the FBI academy, the FBI included blocks of instruction on combating terrorist financing and/or money laundering for 29 students participating in the Latin American Law Enforcement Executive Development Seminar; the students were from Chile, Colombia, Costa Rica, Dominican Republic, Guatemala, Nicaragua, Panama, Paraguay, Peru, Spain, Uruguay, and Venezuela. The FBI included similar blocks of instruction for 21 students participating in the Arabic Language Law Enforcement Executive Development Seminar; the students were from Algeria, Egypt, Iraq, Jordan, Kuwait, Morocco, Saudi Arabia, Tunisia and The United Arab Emirates.
In addition, as part of the FBI’s pacific training initiative, 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, Philippines, Singapore, South Korea, Thailand, and The United States.
Office of Overseas Prosecutorial Development, Assistance and Training, the Asset Forfeiture and Money Laundering Section, & Counterterrorism Section (OPDAT, AFMLS, and CTS)
The U.S. Department of Justice’s (DOJ) Asset Forfeiture and Money Laundering Section (AFMLS) of the Criminal Division and the Office of Overseas Prosecutorial Development, Assistance, and Training (OPDAT) continued to join forces in providing Financial Investigations and Prosecutions and Money Laundering and Asset Forfeiture technical assistance programs. The programs also draw upon expertise within DOJ, including from AFMLS, the Counterterrorism Section of the National Security Division (CTS), and U.S. Attorney’s Offices. Much of the assistance provided by OPDAT and AFMLS is provided with funding from the U.S. Department of State. Funds are also provided by the U.S. Agency for International Development and the Millennium Challenge Corporation.
An important component in this cooperation is OPDAT’s Resident Legal Assistance program. Resident Legal Advisors (RLAs) are federal prosecutors who provide in-country technical assistance to improve capacity, efficiency, and professionalism within foreign criminal justice systems. RLAs are posted to U.S. embassies for a period of one or two years to work directly with counterparts in legal and law enforcement agencies, including ministries of justice, prosecutor’s offices, and offices within the judiciary branch. RLAs provide assistance in legislative drafting, modernizing policies and practices, and training law enforcement personnel, including prosecutors and judges. RLAs also work with DOJ’s International Criminal Investigative Training Assistance Program (ICITAP), other DOJ components, other donors, and multilateral organizations to provide assistance to police and other investigative officials.
In 2011, OPDAT, AFMLS, and CTS met with more than 195 international visitors from more than 17 countries and provided presentations on anti-money laundering (AML) and/or counter-terrorist finance (CFT) topics. Presentations covered U.S. policies to combat terrorism, U.S. legislation and issues raised in implementing new legislative tools, and the changing relationship of criminal and intelligence investigations. The meetings also covered money laundering and material support statutes, and the Classified Information Procedures Act. Of great interest to visitors is the balancing of civil liberties and national security issues, which is also addressed.
Money Laundering/Asset Forfeiture/Fraud
In 2011, OPDAT and AFMLS provided training to foreign judges; prosecutors; other law enforcement officials; legislators; customs, supervisory, and financial intelligence unit (FIU) personnel, and private sector participants, and provided assistance in drafting AML statutes compliant with international standards. Topics addressed 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; international mutual legal assistance, and recovering and managing assets from crime and corruption. Training programs addressing some or all of these topics were held for participants from Egypt, Indonesia, Jordan, Kenya, the Philippines, Turkey, and the United Arab Emirates. Additional programs include the following:
OPDAT and AFMLS co-sponsored the Second Southeast Asia Asset Forfeiture and Financial Investigations Conference, which had 125 participants from 20 countries. In addition, OPDAT and AFMLS co-sponsored a seminar on the investigation and prosecution of financial crimes in Bangladesh that covered such topics as non-conviction based forfeiture, NGO/charities, hawala/hundi, cash bulk smuggling, and mobile banking.
In Indonesia, OPDAT co-sponsored training to familiarize law enforcement agencies with the provisions of the new anti-money laundering law. With RLA support, the first of three anti-money laundering centers opened at the University of Indonesia in Jakarta.
In Kenya, the RLA formed an anti-money laundering roundtable to encourage the Kenyan government and its key partners to coordinate efforts among the various entities working on AML issues in Kenya.
OPDAT and AFMLS hosted training for Bosnian judges that provided instruction on Bosnian asset forfeiture law and procedure with a view to increasing the utilization of asset forfeiture by Bosnian judges in criminal proceedings. AFMLS also met with officials who are forming an asset recovery fund and will provide them an asset tracking software funded by AFMLS and developed in Thailand.
OPDAT, AFMLS, and CTS, with the assistance of other DOJ components, play central roles 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, 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 for Counterterrorism.
In 2011, the TFWG supported five RLAs assigned overseas in Bangladesh, Iraq, Kenya, Turkey, and the UAE. The RLA for the UAE is also responsible for OPDAT program activities in Saudi Arabia, Kuwait, Qatar, Jordan, Yemen, Oman, and Bahrain. 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. In 2011, OPDAT conducted CFT, counter-terrorism and designation training for participants from Indonesia and Thailand.
Additionally, OPDAT co-sponsored U.S.-based training for Turkish government officials on the benefits of interagency cooperation in counter-terrorism and counter-narcotics to lay the groundwork for a Department of Defense-sponsored, Joint Inter-Agency Counter-Trafficking Center (JICTC) in Turkey and to promote sharing of terrorist and law enforcement data among U.S., Turkish and international law enforcement partners. OPDAT also sponsored a conference in Turkey designed to promote cross-border cooperation between Turkey and Iraq that focused on counter-terror financing and money laundering.
Department of State
The U.S. Department of State’s Bureau of International Narcotics and Law Enforcement Affairs (INL) Office of Anti-Crime Programs 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 agencies, the INL Office of Anti-Crime Programs 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 for 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 2011, 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 2011 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, counter-terrorist financing 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 seven trade transparency units (TTUs) in Latin America: three in the tri-border area of Brazil, Argentina, and Paraguay, and others in Colombia, Ecuador, Mexico, and Panama. 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 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 completed its work in 2011, 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 2011. 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 2011, 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’ 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, and Eastern Europe. INL also provides funding for many of the regional training and technical assistance programs offered by the various law enforcement agencies, including assistance to the International Law Enforcement Academies.
International Law Enforcement Academies (ILEAs)
The mission of the regional International Law Enforcement Academies (ILEAs) is to support emerging democracies, help protect U.S. interests through international cooperation, and promote social, political and economic stability by combating crime. To achieve these goals, the ILEA program provides high-quality training and technical assistance, supports institution building and enforcement capability development, and fosters relationships of American law enforcement agencies with their counterparts around the world. ILEAs also encourage strong partnerships among regional countries to address common problems associated with criminal activity.
The regional ILEAs address regional law enforcement priorities to combat security threats. The regional ILEAs offer three different types of programs: the core program, specialized courses, and seminars or workshops. The core program is a six-week series of blocks of instruction tailored to region-specific needs and emerging global threats. The core program typically includes 50 participants, normally from three or more countries. The specialized courses are one or two-week courses for law enforcement or criminal justice officials on a specific topic, comprised of about 30 participants. Lastly, regional seminars or workshops present various emerging law enforcement topics such as transnational crimes, financial crimes, and counter-terrorism.
The ILEAs help to develop an extensive network of alumni who exchange information with their regional and U.S. counterparts and assist in transnational investigations. Many ILEA graduates become the leaders and decision-makers in their respective law enforcement organizations. The Department of State coordinates with the Departments of Justice (DOJ), Homeland Security (DHS) and the Treasury, and with foreign government counterparts to implement the ILEA programs. To date, the combined ILEAs have trained over 38,000 officials from over 85 countries in Africa, Asia, Europe and Latin America.
Africa. ILEA Gaborone (Botswana) opened in 2001. Its main feature is a six-week intensive professional development program – the Law Enforcement Executive Development Program (LEEDP) – designed for law enforcement mid-level managers. The LEEDP brings together approximately 40 participants from several nations for instruction in areas such as combating transnational criminal activity, supporting democracy by stressing the rule of law in international and domestic police operations, and overall professional development through enhanced leadership and management techniques. ILEA Gaborone also offers specialized courses for police and other criminal justice officials to boost their capacity to work with U.S. and regional counterparts. 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, 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. ILEA Gaborone trains approximately 500 students annually.
Asia. ILEA Bangkok (Thailand) opened in 1999. ILEA Bangkok focuses on enhancing regional cooperation against transnational crime threats in Southeast Asia, primarily illicit drug trafficking, financial crimes, and human trafficking. 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 the Special Administrative Regions of Hong Kong and Macau), and the strengthening of each jurisdiction’s criminal justice institutions to increase its abilities to cooperate in the suppression of transnational crime. ILEA Bangkok provides a Core course - the Supervisory Criminal Investigator Course (SCIC) - designed to strengthen management and technical skills for supervisory criminal investigators and other criminal justice managers. In addition, it also provides over 20 specialized courses—each lasting one to two weeks—on a variety of criminal justice topics each year. ILEA Bangkok has offered specialized courses on narcotics trafficking, and terrorist financing-related topics such as Complex Financial Investigations (instructed by IRS). Instruction is provided to participants from Brunei, Cambodia, China, Hong Kong, Indonesia, Laos, Macau, Malaysia, Philippines, Singapore, Thailand, Timor Leste and Vietnam. Subject matter experts from the United States, Thailand, Japan, Philippines, Australia and Hong Kong provide course instruction. ILEA Bangkok trains approximately 1,400 students annually.
Europe. ILEA Budapest (Hungary) was the first ILEA, established in 1995. The mission of the ILEA 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. The ILEA provides advanced training for law enforcement and criminal justice officials on regional threats such as organized crime, cybercrime, and anti-money-laundering topics. Instruction is provided to participants from Albania, Armenia, Azerbaijan, Bosnia and Herzegovina, Bulgaria, Croatia, Czech Republic, Georgia, Hungary, Kazakhstan, Kosovo, Macedonia, Moldova, Montenegro, Romania, Russia, Serbia, Slovakia, Slovenia, Tajikistan, Turkmenistan, Turkey, Ukraine and Uzbekistan. Trainers from over 17 federal agencies and local jurisdictions from the United States, Hungary, United Kingdom, Russia, INTERPOL and the Council of Europe provide instruction. ILEA Budapest trains approximately 950 students annually.
Global. ILEA Roswell (New Mexico) opened in September 2001. In 2011 INL revised and updated the Roswell program in an effort to address ever emerging global criminal threats. ILEA Roswell, through a combination of academic programs, senior policy forums and model law workshops provides the tools necessary to enable partner countries to formulate and execute effective and responsible criminal justice public policy. The Academic program will equip participants with the knowledge and skills necessary for successful criminal justice careers with a strong focus on constructing an international network of like minded U.S. and foreign counterparts. The Criminal Policy Forum proceedings will focus on familiarizing high-level officials with essential elements to counter emerging criminal threats and on encouraging partner country officials to work inter- and intra-regionally to establish cooperative means to counter criminal activity consistent with international standards. The Model Law programs will engage ILEA partner countries on enhancing their legal and regulatory frameworks, and instilling a deep-seated appreciation for the importance of implementing modern, effective criminal justice legislation. The participants are drawn from pools of ILEA graduates from the Academies in Bangkok, Budapest, Gaborone, San Salvador and the ILEA Regional Training Center (RTC) in Lima. 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 international terrorism, illegal trafficking in drugs, alien smuggling, terrorist financing and financial crimes investigations. Segments of the LEMDP focus on terrorist financing (presented by the FBI) and financial evidence/money laundering application (presented by DHS/Federal Law Enforcement Training Center and IRS). 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, Suriname, Trinidad and Tobago, Uruguay and Venezuela. ILEA San Salvador trains approximately 1,000 students per year.
The ILEA Regional Training Center in Lima (Peru) opened in 2007 to complement the mission of ILEA San Salvador. The RTC 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.
Department of the Treasury
Financial Crimes Enforcement Network (FinCEN)
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 2011, 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 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 a key 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 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 2011, FinCEN conducted analyst exchanges with the FIUs of Afghanistan, Brazil, Nigeria, Panama, Paraguay, the Philippines, Russia, and Tanzania.
Internal Revenue Service (IRS), Criminal Investigative Division (CID)
In 2011, Internal Revenue Service, Criminal Investigation (IRS-CI) continued its involvement in international training and technical assistance efforts designed to assist international law enforcement officers in detecting tax, money laundering, and terrorist financing crimes. With funding provided by the U.S. Department of State and other sources, IRS-CI delivered training through agency and multi-agency technical assistance programs to international law enforcement agencies. IRS-CI partnered with several U.S. Government and multilateral organizations, including agencies and offices of the U.S. Departments of State, Justice, Treasury and Homeland Security; the Joint Interagency Task Force West; host country governments; and the IMF to deliver a variety of training.
Financial Investigative Techniques Training
Training primarily consisted of Basic, Intermediate and Advanced Financial Investigative Techniques (FIT) courses which, depending on the venue, focused on indirect methods of proof, an overview of global and regional investigative issues, tax laws, bank records, interviewing, off-shore banking, and/or corporate fraud. In 2011, IRS-CI conducted FIT courses for law enforcement, customs, intelligence, and revenue officers; prosecutors; for the following countries: Albania, Algeria, Australia, Cambodia, Colombia, Denmark, Finland, Hungary, Iceland, Kosovo, New Zealand, Norway, Philippines, Senegal, South Korea, Sweden, and Thailand.
Other Training Initiatives
Funded by the Korean National Tax Service, IRS-CI provided a one week Special Investigative Technique course to 49 participants in South Korea. Topics included investigative tools, undercover operations and forensic accounting.
In Indonesia, 30 participants received training in public corruption and complex financial investigation techniques. This course used various practical exercises to instruct participants in Indonesian case law dealing with money laundering, public corruption and asset recovery. IRS-CI also presented a one week Fraud and Public Corruption course in Thailand for 48 participants from Thailand’s financial and anti-corruption units.
IRS-CI presented an organized crime seminar to approximately 40 - 50 Georgian investigators and prosecutors.
Multiple training seminars were presented to investigators, prosecutors and judges in Kosovo. These seminars were part of the ongoing United States Attorney’s Office for the Eastern District of North Carolina - Kosovo initiative and their focus was to encourage aggressive investigations, case development, and the use of plea bargaining to develop evidence to resolve cases.
IRS-CI presented three workshops on financial investigations, with an emphasis on money laundering, to a total of 101 Canadian law enforcement officials. IRS-CI also participated in delivering training to combat terrorism financing and money laundering in Islamabad, Pakistan; Cairo, Egypt; and Johannesburg, South Africa.
Sixty Mexican federal judges, prosecutors, financial intelligence analysts, and investigators attended a one week money laundering course. Another program titled “Using Financial Evidence in Criminal Prosecutions – Illicit Financing and Money Laundering” provided participants information on money laundering, financial investigations, asset forfeiture, and special investigative techniques, with an international scope. Other training included a one week casino gaming conference that assisted the Mexican government in developing best practices for regulating gaming activity and preventing money laundering. A three-day counter-terrorism and money laundering course was also presented to federal prosecutors, investigators, forensic criminalists and representatives from the Mexican financial intelligence unit.
International Law Enforcement Academy Training
IRS-CI provided instructor support to the State Department International Law Enforcement Academies (ILEA).
ILEA Bangkok: IRS-CI participated in one Supervisory Criminal Investigator Course which included participants from various law enforcement agencies. IRS-CI also conducted two FIT sessions for 93 participants from various law enforcement agencies from the following countries: Brunei, Cambodia, China, Hong Kong, Indonesia, Laos, Macau, Malaysia, Philippines, Singapore, Thailand, and Vietnam. Additionally, a one week Fraud and Public Corruption course was presented to 42 participants from ten countries. The training focused on recognizing methods of bribery and corruption and included two extensive practical exercises.
ILEA Budapest: IRS-CI participated in delivering five sessions of the ILEA core program. Participating countries included Albania, Bosnia and Herzegovina, Bulgaria, Croatia, Hungary, Kazakhstan, Kosovo, Macedonia, Montenegro, Moldova, Romania, Serbia, Turkey, and Ukraine. IRS-CI also conducted a one week FIT course for 30 law enforcement officials from Croatia, Montenegro, and Serbia.
ILEA Gaborone: IRS-CI provided instructor support for four Law Enforcement Executive Development (LEED) programs for participants from Botswana, Cameroon, Republic of the Congo, Gabon, Ghana, Kenya, Lesotho, Malawi, Namibia, Nigeria, Rwanda, Senegal, Seychelles, Sierra Leone, Swaziland, and Tanzania. IRS-CI supplied the class coordinator for LEED 39. The coordinator organized and supervised the participants’ daily duties and activities.
ILEA San Salvador: IRS-CI assisted in the delivery of four courses for the Law Enforcement Management Development Programs (LEMDP) that stress the importance of conducting a financial investigation to further develop a large scale criminal investigation. Participants were from Antigua, Argentina, Barbados, Belize, Brazil, Chile, Colombia, Costa Rica, Dominican Republic, El Salvador, Guatemala, Honduras, Jamaica, Panama, Paraguay, Peru, St Lucia, and Trinidad and Tobago. For LEMDP 20, IRS-CI provided the class coordinator. IRS-CI also led two one week FIT/Money Laundering courses. The 65 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
The International Training Team (ITT) hosted two foreign delegations. Representatives from the Ugandan Revenue Authority and the Indian Central Board of Taxation toured the Federal Law Enforcement Training Center (FLETC). The delegations received an overview of Special Agent Basic Training and law enforcement techniques, plus briefings from other divisions at the FLETC.
The ITT completed two course development projects. Representatives from Norway and Denmark met at the FLETC to design and develop the Nordic Financial and Organized Crimes course. In Cambodia, the ITT met with banking, financial, law enforcement and judicial officials to assist in the development of Cambodian-specific course material.
ITT also participated in various overseas activities. At the Organization for Economic Cooperation and Development’s Tax and Crime Conference, ITT provided a guest speaker on money laundering and bribery awareness. In Budapest, Hungary, IRS-CI met with Hungarian tax and customs officials to discuss future training initiatives.
Office of the Comptroller of the Currency (OCC)
The U.S. Department of the Treasury’s (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 2011, the agency 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 2011 school was attended by foreign supervisors from Australia, Brazil, Canada, India, Indonesia, Italy, Korea, Malaysia, Netherlands, Philippines, Turkey, Taiwan and Zambia. In addition to organizing and conducting the School, 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 agency’s 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 2011 by participating with other federal banking agencies in regulator panels at the 10th Annual International Anti-Money Laundering Conference (ACAMS) which was attended by more than 1,000 AML professionals from 50 countries and the Institute of International Bankers Annual Anti-Money Laundering Seminar which hosted attendees from 30 countries. The agency also participated in a similar panel at the Florida International Bankers Association (FIBA)’s Annual AML Compliance Conference. FIBA draws its membership from 18 countries worldwide.
The OCC also participated in Treasury’s 2011 Private Sector Dialog which brings together Latin American and U.S. bankers to discuss issues related to AML compliance and an AML/CFT conference organized by the Asociación de Bancos de México (ABM). This discussion focused on the U.S AML regime and approach to conducting supervisory examinations.
Office of Technical Assistance (OTA)
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 reforms. The mission of the Economic Crimes Team (ECT) is to provide technical assistance in support of 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 engagement by the ECT is tailored to the specific conditions of the jurisdiction in which it is engaged. An ECT engagement may involve placement of a Resident Advisor or utilize Intermittent Advisors, under the coordination of a Team Leader. The nature of ECT technical assistance is broad and can include efforts to improve (i) the legal framework; (ii) technical competence of stakeholders; and (iii) awareness-raising aimed at the full range of AML/CFT stakeholders to include the public, legislative bodies and implementers. 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.
The ECT is divided along three regions -- Europe and Asia, Africa and the Middle East, and Latin America and the Caribbean -- each managed by a Regional Advisor. In 2011, the ECT delivered technical assistance programs in 25 jurisdictions. In the Western Hemisphere, the ECT operated Resident Advisor programs in Costa Rica, Guatemala, Haiti, Honduras, Mexico and Paraguay; an Intermittent Advisor program in Uruguay; and initiated programs in Guyana as well as Trinidad and Tobago. Highlights for 2011 include a successful, ongoing regional initiative in Central America aimed at international cooperation, particularly pertaining to asset forfeiture.
In Africa and the Middle East in 2011, the ECT operated Resident Advisor Programs in Botswana, Ghana, Iraq, Morocco and the Palestinian Authority; Intermittent Advisor programs in Saudi Arabia as well as Sao Tome and Principe; and conducted an assessment in Djibouti. Program highlights include support for the development of financial intelligence units (FIUs), particularly in Botswana, Ghana, Morocco and the Palestinian Authority. 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 2011, the ECT operated Resident Advisor programs in Afghanistan, Kosovo and the Mekong Region (Cambodia, Lao, Viet Nam); initiated an Intermittent Advisor program in Turkmenistan; and continued other Intermittent Advisor programs in Armenia, Azerbaijan and Georgia. Particular attention was focused on FIU and financial investigative skills 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.
Federal Deposit Insurance Corporation (FDIC)
In 2011, 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 an anti-money laundering and counter-terrorist financing (AML/CFT) training session for 27 representatives from Ethiopia, Ghana, Kenya, Nigeria, and Tanzania. The training session addressed current trends and methodologies, the AML examination process, suspicious activity monitoring, customer due diligence, and foreign correspondent banking risks and controls.
During the year, the FDIC met with 20 supervisory and law enforcement representatives from Pakistan and the United Arab Emirates to discuss AML issues. Topics included examination policies and procedures, the USA PATRIOT Act, suspicious activity reporting requirements, and government information sharing mechanisms.