Guest Author - Consuelo Herrera, CAMS, CFE
That’s the challenge for forensic accountants and financial investigators.
According to the Department of Homeland Security, U.S. Immigration and Customs Enforcement (ICE) a key fact of law enforcement in the 21st century is that financial investigations will be critical in the fight against criminal and terrorist organizations. ICE aims to be the investigative leader by applying a systems-based approach to attacking financial crimes.
ICE’s financial investigators and analysts build on the legacy we inherited from the U.S. Customs Service, which was empowered under the Bank Secrecy Act and Money Laundering Control Acts to investigate and interdict the illegal movement of currency in and out of the United
States. High-profile Customs investigations of the past, such as the Bank of Credit and Commerce International (BCCI) case, illustrated how our financial system could be corrupted and exploited to facilitate the laundering of criminal proceeds.
This expectation is a worldwide goal. For example, the Accredited Financial Investigator profile in the United Kingdom, portrays a high profile. Some of his or her essentials are: To support the UK Counter Terrorist Finance Programme (CTFP) and the National Terrorist Financial Investigation Unit in the disruption of the support networks that make terrorism possible by undertaking investigations into the finances of individuals, groups and organizations that have been identified as suspicious. In particular, to:
O Work closely with private sector financial institutions and any other business engaged in high value transactions in response to Suspicious Activity Reports (SARs), sudden changes in established patterns of banking behavior, or payments to companies whose products may enable terrorist activity
O Liaise with other agencies, such as Revenue & Customs, to investigate sources and receptors of large cash movements and other high value assets
O Develop relationships with private sector forensic accountants and investigators to help in the identification of suspicious financial transactions and movements, particularly through “money service businesses” (MSBs) such as bureau de change, check cashiers and “wire transfers”
O Undertake investigations into the abuse of charities, donations by individual “philanthropists” and the use of pre-paid credit cards available from offshore institutions that leave little by way of paper trails
O Support the identification and freezing of terrorist assets
Essential activities of the role includes:
O Investigate allocated enquiries
O Interview suspects
O Use intelligence to support policing objectives
Essential experience and specialist skills and knowledge:
O Should have an investigative background (Police, Military, Customs, Revenue, Local Authorities etc.
O Skilled interviewer
O Broad knowledge of search and seizure powers (PACE/terrorism) as well as an awareness of recent EU counter-terrorism legislation
O Ability to prepare and present case material
O Prepared to be subject of security vetting and integrity testing
Essential Behavioral Competencies are:
O Strategic perspective
O Respect for race and diversity
O Team working
O Effective communication
O Problem solving
O Planning and organizing
O Personal responsibility
Core Responsibilities include: Investigate inquiries. Act as officer in the case ensuring the investigation is carried out thoroughly and expeditiously in accordance with investigation policy and relevant legal requirements. Ensure that all matters relating to the process of information are carried out in a prompt, efficient manner and in accordance with legislation, policy and procedure.
The ICE also states its concerns for the impact that bribery, fraud, and embezzlement have on financial markets. As part of its challenge financial investigators need to be aware of ICE results of investigations that have discovered that corrupt foreign leaders channel illicit funds to U.S. financial institutions for laundering or investment. ICE point out some “red flags” for investigators:
O High-ranking government officials establishing offshore companies and bank accounts
O Officials writing checks for non-existent goods and services to companies owned by a politician, his associates, or family members
O Wire transfers to bank accounts in the United States or elsewhere
O Government officials purchasing significant assets or investing in high-end real estate in the United States or other countries
O Officials accumulating unexplained financial wealth, often inconsistent with information provided on public disclosure forms
O Disregard of general accounting procedures for purchases of government equipment and use of government funds
One of the fruitful fields for forensic accountants is serving as financial investigators. The demand for these professionals is high across the globe. Meeting the essentials and core competences expected from Accredited Financial Investigators is a great way to start.