Years ago, when I was a criminal investigator for U.S. Customs/Treasury assigned to the American Embassy in Rome I worked a long-term complex international money laundering case. The investigation had ties to the Middle East, Europe, and the United States. It involved the misuse of the international gold trade to launder staggering amounts of drug money. I spent two years of my life working the case. I developed an incredible amount of intelligence, recruited numerous sources in multiple countries, coordinated investigations with international police forces, learned a great deal about trade-based money laundering, etc. and finally had enough information to present the case for prosecution to the U.S. Department of Justice in Washington, D.C. They liked the case but declined prosecution. It was extremely difficult to prove the nexus of the predicate offense of trafficking in narcotics to the laundered money and properties in the U.S. and Europe we had identified as the fruits of the criminal activity.
The end result from management’s perspective was that the case was a tremendous waste of time, money, and resources. A more practical result from my perspective is that when I was rated for promotion, I had no “stats.” I had no arrests, convictions, prosecutions, seizures, etc. These are the bottom line metrics that drive management’s decision making on everything from personnel decisions, investigative priorities, allocation of resources, etc. I couldn’t compete with my colleagues assigned, for example, to the southwest border that could get multiple “bag and tag” arrests and multiple “stats” which look good before the promotion boards.
The above exemplifies many of the current problems we face today. There is an expression in law enforcement management circles; “Big cases equal big problems.” Although everybody wants big, headline-grabbing, impact, game-changing investigations and prosecutions, most managers feel the headaches aren’t worth it. They opt instead for smaller, routine, insignificant, cases where they can harvest statistics that make themselves appear productive. In short, they play it safe. This also contributes to our “stalled” efforts to combat money laundering and contributes to the lack of “imagination” that has proved detrimental in our war against terror finance. This will be increasingly important in the coming years as we are hard pressed to keep pace with new and evolving money laundering methodologies.
This management syndrome can and should be changed. Our priorities and incentives must change as well. Directives need to come from headquarters that encourage “impact cases.” (See the article I wrote a number of years ago, “Where Have the Impact Cases Gone.”) Stats should be weighted to reward those who pursue long-term, difficult investigations that, unfortunately, sometimes do not bear fruit but maybe result in excellent information. Congress can get involved by allocating funds towards the development of complex, financial crimes investigations. And then, they should hold the agencies and departments responsible for delivering (see step two in this series on “accountability”).
The end result from management’s perspective was that the case was a tremendous waste of time, money, and resources. A more practical result from my perspective is that when I was rated for promotion, I had no “stats.” I had no arrests, convictions, prosecutions, seizures, etc. These are the bottom line metrics that drive management’s decision making on everything from personnel decisions, investigative priorities, allocation of resources, etc. I couldn’t compete with my colleagues assigned, for example, to the southwest border that could get multiple “bag and tag” arrests and multiple “stats” which look good before the promotion boards.
The above exemplifies many of the current problems we face today. There is an expression in law enforcement management circles; “Big cases equal big problems.” Although everybody wants big, headline-grabbing, impact, game-changing investigations and prosecutions, most managers feel the headaches aren’t worth it. They opt instead for smaller, routine, insignificant, cases where they can harvest statistics that make themselves appear productive. In short, they play it safe. This also contributes to our “stalled” efforts to combat money laundering and contributes to the lack of “imagination” that has proved detrimental in our war against terror finance. This will be increasingly important in the coming years as we are hard pressed to keep pace with new and evolving money laundering methodologies.
This management syndrome can and should be changed. Our priorities and incentives must change as well. Directives need to come from headquarters that encourage “impact cases.” (See the article I wrote a number of years ago, “Where Have the Impact Cases Gone.”) Stats should be weighted to reward those who pursue long-term, difficult investigations that, unfortunately, sometimes do not bear fruit but maybe result in excellent information. Congress can get involved by allocating funds towards the development of complex, financial crimes investigations. And then, they should hold the agencies and departments responsible for delivering (see step two in this series on “accountability”).
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