Willfully Failed To Establish an AML Program -- by T_Duxbury on Thursday, October 6 2011

Miami-based Ocean Bank has agreed to pay almost $11 million to satisfy any penalty, forfeiture, fine, or assessment that may be called for by the U.S. Department of Justice, the Federal Deposit Insurance Corporation, the Florida Office of Financial Regulation, and the Financial Crimes Enforcement Network to resolve charges that it willfully failed to establish an anti-money laundering program for a period of seven years. "Operation Dirty Dinero" consisted of a lengthy, multi-agency investigation that delved into the bank's handling of certain of its customers, including those involved in transactions with Mexican currency exchange houses (casas de cambio). The results were the finding not only of the failure to establish an anti-money laundering program with internal controls reasonably designed to detect and report money laundering and other suspicious activity in a timely manner for a considerable number of years, but also the following shortcomings:

* Failure to monitor potential money laundering activity in certain accounts alleged to have been used to launder money;
* Served as medium for the laundering of over $10 million in the proceeds of narcotics sales through five accounts at the bank;
* Failed to conduct adequate independent testing, particularly with respect to suspicious activity reporting requirements;
* Failure to sufficiently staff the BSA compliance function with appropriately trained staff to ensure compliance with BSA requirements;
* Failure to recognize and mitigate risks and report transaction activity often associated with money laundering involving direct foreign account relationships in high-risk jurisdictions, especially Venezuela.

Among the remedial actions the bank has taken is a "revamping of its management and Bank Secrecy Act staffs, including the CEO, COO, CFO, BSA officer, and the heads of lending, branch administration, the legal department, human resources, the credit department, and wealth management"! Also reportedly implemented at the bank are a program of account monitoring, investment in additional training, and the hiring of additional staff for its BSA department. In response to the bank's "willingness to acknowledge responsibility for its actions, its remedial actions to date, its overall cooperation, and promises to continue cooperation in the future," the U.S. Attorney's Office agreed to defer prosecution of the criminal charge in the bill of information for 24 months.Then if the bank shows that it has "fully complied with its obligations under the agreement," as agreed to by the U.S. Attorney, the bill of criminal information will be dismissed at the end of 24 months.

For further information about this case, visit http://www.justice.gov/usao/fls/PressReleases/110822-01.html, FinCEN "What's New," Department of Justice Press Release and Joint News Release, both dated August 22, 2011.

Looking Back at Katrina: Key Lessons Learned -- by T_Duxbury on Thursday, October 6 2011

The FDIC has issued a reminder (Financial Institution Letter-60-2011) that guidance developed in response to Hurricane Katrina emphasized valuable lessons learned that should be considered when preparing for a significant storm. The post-Katrina guidance, issued by the Federal Financial Institutions Examination Council (FFIEC), highlights unique challenges created by significant storms.

Key lessons learned from the Hurricane Katrina experience:

* Key challenges included communication and power outages, destruction of facilities, and interruption in availability of certain branches and ATMs; and while business continuity plans generally worked well in enabling financial institutions to meet these challenges and restore operations swiftly, preparation remains critical to the speed at which essential services can be restored.
* Anticipate disruptions in communication services and the ability of critical staff to reach their assigned recovery areas, possibly over an extended period of time.
* Anticipate that financial institution operational facilities could be damaged or destroyed, creating a need for alternate facilities. The location of a backup site can be critical to successful recovery efforts.
* Be prepared to operate in a "cash only" environment.
* Recognize that a financial institution's involvement in neighborhood, city, state, and federal volunteer programs can facilitate a community's recovery from a catastrophic event.

Lo and Behold -- by T_Duxbury on Thursday, October 6 2011
In the August issue of "The Advisor," we discussed the possibility of earthquakes in areas of the country other than the one in which we would most commonly expect an earthquake -- California. Current estimates cited in the article ("Thinking Scenarios Through," pp. 10-11) indicated that the areas most likely to experience earthquake nuclear reactor damage were not in California, or in the West at all, but east of the Mississippi. Lo and behold, the Furies must have been listening. A powerful 5.8-magnitude earthquake startled Easterners from Boston to Charleston to Detroit, the strongest East Coast tremor in 67 years. Many buildings in Washington, D.C., were closed, such as all those at Georgetown University, and some suffered what appears to be minor damage, like the Washington National Cathedral and the Washington Monument.

What banks have to concern themselves with in events like this is not only the possibility of direct damage -- this would apply to events like tornadoes, earthquakes, tsunamis along coasts, hurricanes, and also man-made events -- but, in addition, the possibility of indirect damage, for example, contamination from a nuclear reactor that has been damaged by a tornado or tsunami, as the Japanese tragically experienced earlier this year. In the Virginia quake, two Dominion nuclear power plants in North Anna, Virginia, just 10 miles from the quake's epicenter, shut down automatically when the quake hit. They lost power from the grid and switched to four diesel generators, according to a spokesperson at the Nuclear Regulatory Commission.

The point of this coincidental and unfortunate example is to use this Eastern earthquake to avoid the "it won't happen here" mindset. It did happen "here," in Virginia and Washington, D.C., and surrounding regions.

Counter-Terrorist-Financing Measures Working 10 Years Later -- by T_Duxbury on Thursday, October 6 2011

In the view of the Treasury Department's Assistant Secretary for Terrorist Financing, the killing of Osama bin Laden may very well have a serious crippling effect on al Qaeda's ability to raise money for the worldwide jihad. Said the Assistant Secretary to the U.S. Senate's Banking Committee, "The death of the al Qaeda leader is a tremendously important step, and it takes away a person who, at minimum, as a symbol, was helpful in raising terrorism money."

While he said that Treasury's efforts to limit terrorism financing have notched some successes, he offset the positive announcement with a statement of a difficult realization about the growth of al Qaeda in the Arabian peninsula and elsewhere. He maintained that even with bin Laden's death, there has been an expansion of al Qaeda networks in the Middle east and North Africa.

The successes the Assistant Secretary alluded to were not, in his view, all recently won with bin Laden's death. Rather they were, in his opinion, realized, in part, because of Treasury's engagement and sharing of information with other financial intelligence units (FIUs like Treasury's FinCEN), as well as with foreign central banks and governments. In other words, the real progress is made with hard work over time, not with highly charged bolts of melodrama. "The success we've had with al Qaeda has been something that has developed over a number of years by both taking targeted actions against financial facilitators [of terrorism] moving money as well as dedicated engagement with counterparts in the gulf to identify the networks where the money is raised and moved into Pakistan, and it has really put a fair amount of financial pressure on al Qaeda," remarked the official.

Treasury's efforts in recent years to limit worldwide terrorist financing through work with other financial intelligence units throughout the world and other of its means have been laudable, but we bankers can do our part in fighting terrorism by attacking terrorist financing's vulnerable underbelly: money laundering. In an article he wrote for The Advisor several years ago ("Understanding and Disrupting Terrorist Financing," January 2008), Dennis Lormel suggested the direction in which our counter-terrorist-financing efforts should be channeled. He began by saying, "In order to succeed, a terrorist group must have the capacity to raise funds, the means to launder funds, and the availability of funds to operate." Lormel, who was responsible for developing the Federal Bureau of Investigation's counter-terrorist-financing program, establishes the importance of money laundering to the terrorist financier and, hence, terrorist. One would think Mr. Lormel should be in the know on this point. As he continues, he reiterates the importance, nay, the necessity, of money laundering operations to terrorists and their financial facilitators: "In terms of the sources of funds, the ability to launder funds, and the availability of funds, the focus should be placed in the middle, on the ability to launder funds. By focusing in the middle, government can develop strategies to move outward in both directions by tracing the sources and applications of funds. In essence, they will be able to go directly after the individuals and entities responsible for providing funds, disrupt their flow, identify and trace the use of funds, and go directly after the facilitators and operatives conducting terrorist activities. By focusing in the middle -- the financial sector, as a conduit between sources and application of funds -- we can develop filters to disrupt the flow of funds from one side to the other, thereby diminishing the ability of terrorists to operate...Meaningful and consistent strategies deny terrorists funding. Denying terrorists funding limits their ability to strike and successfully carry out devastating attacks."

When we bankers wage war on money laundering and therefore for a portion of the time automatically on the financing of terrorism, and when we hone our skills in recognizing the traits of money launderers and terrorist financial facilitators (see "Ohio Couple Pleads Guilty to Financing Terrorism: Methods to Watch For," August 2011) we disrupt the ability of terrorists to fund and stage terrorist operations, help prevent money launderers and terrorist financiers from abusing our financial institutions, help prevent these individuals from undermining and weakening our nation's (and the international) financial infrastructure, and help make America a little safer. We actually might have a little more potential leverage in this area than most of us think we have.

100 Times! -- by T_Duxbury on Tuesday, September 13 2011

A 54-year-old Connecticut man was recently charged with, and pled guilty to, structuring almost $1 million. Not an astounding occurrence. But what is surprising is that he was able to do it in one financial institution with 100 transactions in amounts that mostly approximated $9,000, and, moreover, he was charged with only one count of structuring!

According to court documents and statements he made to the FBI, the defendant made more than 70 large cash deposits into his savings account and more than 30 large cash payments to his personal line of credit account over a three-year-and-five-month period, every one of the transactions just under the currency transaction reporting threshold. This brings up an interesting issue. The problems of due diligence, frequency, detecting and evaluating for the presence of structuring, and suspicious activity reporting. If all hundred structuring transactions were spaced out evenly over the three years and five months (unlikely), one would have occurred approximately every 12 calendar days. If structured transactions like this are conducted once every year or six months, do you have a case against the person? Probably not, judging from what the standard of evidence has to be these days in American courts. Every month? Who knows, judging by those same infamous standards? Every week? Probably. Where is the line -- or area -- of demarcation?

Other questions. Why did this criminal process go on for so long? To get enough evidence? Did it take months and months to detect a pattern? How long before a SAR was prompted? The defendant used some of the funds to purchase property in Connecticut and Florida. We know he had a "former partner," and used some of the money to pay off a debt to him, so he had a line of work. Did the line of work correlate reasonably with the cash this fellow was dumping into his bank? Could the pattern of his transactions be reasonably considered usual and customary for his line of work? We also know he agreed to forfeit almost $390,000 to the government, and that he might have to cough up a little more of what was once a lot of cash: he faces a fine of up to $500,000 and a maximum term of imprisonment of 10 years.

A Flood of Money -- by T_Duxbury on Tuesday, September 13 2011

How much of the cash that is brought to the U.S./Mexican border for illegal transport to drug cartels is intercepted by U.S. and Mexican officials?

Immigration and Customs officials estimate that only about one percent of the twenty to twenty-five billion dollars in cash that is smuggled southward over the U.S./Mexican border each year to pay off Colombian, Peruvian, Bolivian, and Mexican drug cartels is intercepted. Unfortunately Mexican couriers have become geniuses at hiding cash in places like spare truck and auto tires, children's toys, loaves of bread, body cavities, engine transmissions, hidden vehicle compartments welded shut, vehicle undercarriages, baby diapers, and even engine oil pans (by leaving out several quarts of oil). One of the great features of this mode of transport for the criminal is that there is no paper or electronic trail to follow. Another is traffic. In Laredo alone, over 30,000 vehicles cross the border each day. Inspection is a losing proposition. Unfortunately, banker due diligence has become a double-edged sword. Increased BSA compliance and currency transaction reporting has forced criminals to follow a path of less resistance, which in the Southwest is cash smuggling.

We are reminded of recent examination and enforcement cases involving banks whose internal systems failed to detect or consider as unusual these types and volumes of large bulk-cash shipments. These cases undoubtedly led to the 2010 expanded discussion of bulk-cash in the BSA/AML examination manual. Certainly, large volumes of unexplained cash transactions involving a bank or other financial institution would seem to warrant close scrutiny and enhanced due diligence:

* What is the source or destination of the cash?
* Is the volume consistent and commensurate with the nature of the customer's business?
* Are there indications of related cross-border activity, such as ACH or wire transfers?
* Are the parameters, profiles, and scenarios linked to the bank's surveillance systems appropriate?
* Is there a process for internally reporting this to a central investigations or Security/BSA/AML unit for appropriate follow up?
* Is there provision for evaluating this activity in light of other circumstances or comparisons to similar patterns of other customers?

Guidance to Financial Institutions on Recent Events in Syria in a Context of Potential for Public Corruption -- by T_Duxbury on Tuesday, September 13 2011

FinCEN has issued an advisory to U.S. financial institutions to take reasonable risk-based steps with respect to the potential increased movement of assets that may be related to the current unrest in Syria. During this period of uncertainty, FinCEN is issuing this advisory to remind U.S. financial institutions of their requirement to apply enhanced scrutiny for private banking accounts held by or on behalf of senior foreign political figures and to monitor transactions that could potentially represent misappropriated or diverted state assets, proceeds of bribery or other illegal payments, or other public corruption proceeds. As a reminder, this guidance is separate and apart from any actions taken by OFAC. The guidance was directed to all U.S. financial institutions, however remote the possibility of any such activity relating to a particular institution.

A financial institution must file a Suspicious Activity Report (SAR) if:

* the institution knows, suspects, or has reason to suspect that a transaction relating to senior foreign political figures involves funds derived from illicit activity,
* the transaction appears to have no business or lawful purpose, or
* a customer has engaged in activities indicative of money laundering, terrorist financing, or any other violation of federal law or regulation.

Additionally, covered financial institutions are reminded of the regulations implementing Section 312 of the USA PATRIOT Act, (31 U.S.C. 5318(i)), which require a written due diligence program for private banking accounts held for non-U.S. persons designed to detect and report any known or suspected money laundering or other suspicious activity. In instances where senior foreign political figures maintain private banking accounts at a covered institution, those financial institutions are required to apply enhanced scrutiny of such accounts to detect and report transactions that may involve the proceeds of foreign corruption.

Read more about this at www.fincen.gov, “What’s New.” Questions or comments regarding the contents of this Advisory should be addressed to the FinCEN Regulatory Helpline at 800-949-2732.

Terrorist Financing and Money Laundering Risks to the International Financial Infrastructure -- by T_Duxbury on Tuesday, September 13 2011

FinCEN has recently issued advisories (FIN-2011-A011 and A012) informing banks and other financial institutions operating in the United states of the money laundering and financing of terrorism risks associated with no fewer than 44 countries identified by the Financial Action Task Force as having strategic deficiencies in their anti-money laundering and counter-terrorist financing (AML/CFT) regimes. Many have shown a conscious effort to improve. Other jurisdictions, however, namely Iran, the Democratic Peoples' Republic of Korea, Bolivia, Cuba, Ethiopia, Kenya, Myanmar, Sri Lanka, Syria, and Turkey, have not made sufficient progress in addressing their deficiencies, not provided a political commitment to address anti-money laundering and counter-terrorist financing deficiencies, or, as in the case of Iran and North Korea, are subject to FATF's call for countermeasures. It is this last category that we wish to focus on here.

As a reminder, FinCEN guidance is separate from any action taken by OFAC, which still considers strict sanctions against some of these jurisdictions. But at the very least, U.S. financial institutions are expected to take into account these geographic money laundering and terrorist financing risks when assessing and reevaluating their internal risk assessments. Any financial activity or bank customer dealings relating any of these geographic areas should warrant enhanced scrutiny and due diligence.

Iran and the Democratic People's Republic of Korea (DPRK)
The FATF remains concerned by the failures of Iran and the Democratic People's Republic of Korea (DPRK) to meaningfully address the ongoing and significant deficiencies in their anti-money laundering and combating the financing of terrorism (AML/CFT) regimes and the serious threat this poses to the integrity of the international financial system. The FATF urged both to immediately and meaningfully address their AML/CFT deficiencies. In the case of Iran, FATF urged the country to immediately and meaningfully address its AML/CFT deficiencies, in particular by criminalizing terrorist financing and effectively implementing suspicious transaction reporting requirements.

The FATF reaffirmed its call on members (all 127 FIUs -- ours is FinCEN) and urged all jurisdictions to advise their financial institutions to give special attention to business relationships and transactions with Iran and the DPRK, including Iranian and DPRK companies and financial institutions. Your attention is directed to articles entitled "Careful Bankers! Iran Seeks to Outmaneuver Sanctions" and "A Significant Step, but Only a Step" published in our July 2011 issue. In them we briefly chronicled Iran's attempts to circumnavigate sanctions and dupe bankers by purchasing foreign banks and money-exchange businesses around the world in order to disguise and distance itself from the banks it hopes to trick into engaging in business. Also chronicled is a June indictment against Iran's state-sponsored shipping line and 10 other corporations for allegedly conspiring to evade sanctions by tricking U.S. banks in this manner.

In both these cases, FATF called for enhanced scrutiny of its members and urged all jurisdictions to apply effective counter-measures to protect their financial sectors from money laundering and financing of terrorism risks emanating from Iran and North Korea. In the case of Iran, failure to take concrete steps to improve its AML/CFT regime would result in FATF calling on its members and urging all jurisdictions to strengthen counter-measures in October 2011.

For more information, visit www.fincen.gov , "What's New."

2011 Egmont Group Plenary -- by T_Duxbury on Tuesday, September 13 2011

In news that could indirectly affect US financial institutions, FinCEN Director James H. Freis, Jr., and other FinCEN representatives participated recently in the 19th annual plenary meeting of the Egmont Group of financial intelligence units (FIUs) held in Yerevan, Armenia. An FIU is the central authority in each jurisdiction responsible for the receipt, analysis and dissemination of financial information for anti-money laundering and counter-terrorist financing (AML/CFT) purposes; FinCEN is the FIU of the United States of America.

As we approach the tenth anniversary of 9/11 we can look back at the significant events over the past decade that had some bearing and were influenced by the actions taken by FIUs around the world. These Egmont actions often had far-reaching implications for US institutions when FinCEN issued responsive guidance or regulatory advisories. Implications could extend to US money laundering threat assessments, examination and enforcement policy, enhanced investigations relating to financial crimes and a plethora of individual rulings -- currency and other money-transfer reporting, customer due diligence, detection of suspicious activity, MSBs, sharing of financial information, and the convergence of money laundering and financial crimes, just to name a few.

This year's plenary saw the admission of FIUs from Azerbaijan, Kazakhstan, Mali, Morocco, Samoa Islands, Solomon Islands and Uzbekistan, bringing the Egmont Group membership to 127 FIUs from jurisdictions around the world. FIUs have unique authority to share financial intelligence to help law enforcement combat transnational organized crime, and the Egmont Group's primary purpose is to facilitate increased information exchange for AML/CFT purposes. A focus throughout plenary discussions was how to strengthen the FIU-to-FIU channels for the secure and confidential international exchange of information. On the occasion of the plenary, FinCEN signed memoranda of understanding (MOU) with three counterpart FIUs from Fiji, Israel and Saudi Arabia, which will help support information sharing between each of these nations and the United States in global efforts to fight financial crimes.


In recent years the Egmont Group has also placed increased emphasis on the fight against corruption. This year’s plenary included further sessions devoted to combating corruption and asset recovery, as well as discussions on the impacts that corruption can have on efforts to establish new FIUs and to effectively carry out the FIU mission.


Other key topics of this year's plenary in which FinCEN played an active role were related to tactical and strategic analysis of financial information; facilitating increased cooperation and sharing of expertise among the growing number of FIUs that, like FinCEN, also have AML/CTF regulatory responsibilities; and best practices in FIU security protections.


For more information on the Egmont Group and FinCEN's international activities, visit http://www.egmontgroup.org and http://www.fincen.gov/international.

Ohio Couple Pleads Guilty To Financing Terrorism -- by T_Duxbury on Wednesday, September 7 2011

There is little doubt that terrorist financing and associated money laundering are practiced in our country on a daily basis, and not necessarily just in New York, Miami, Chicago, Los Angeles, and the Southwest border region or some metropolitan area where stereotypical thinking might lead one to expect it. In a recent case, an Ohio husband-and-wife team pleaded guilty to charges relating to a plan to send hundreds of thousands of dollars to the terrorist organization, Hezbollah. This organization is considered perhaps the most dangerous of all terrorist groups, with the possible exception of al Qaeda, but is probably the most sophisticated, and without peer at constructing large improvised explosive devices (IEDs).

Our terrorist financing couple met numerous times with a confidential source actually working undercover with the FBI. This person pretended to be a financial facilitator of terrorism during his 10-month association with the pair. During meetings the husband and wife discussed ways to secretly send money to Hezbollah leaders in Lebanon.

On an appointed day, the confidential source brought $200,000 to the couple so they could prepare it for shipment. During later surveillance the couple was seen wrapping the money in plastic and duct tape, preparing it for concealment.

They never reached the concealment stage. The FBI decided it had enough information for a case against the two terrorist financiers and arrested them. Among the charges against them, and to which they pleaded guilty, were conspiracy to provide support to a foreign terrorist organization and conspiracy to violate money laundering law.

METHODS TO WATCH FOR: MOST EASILY RECOGNIZED

What follows is a list of transaction types and methods that could indicate association with criminal fund-raising and money laundering to support terrorist activity. While these transaction types and methods would not necessarily justify suspicion when considered individually, they may if several appear together.

* financial activity inconsistent with the stated purpose of the business;
* same-day transactions at the same depository institution using different tellers;
* financial activity not commensurate with stated occupation;
* use of multiple accounts at a single bank for no apparent legitimate purpose;
* importation of high-dollar currency and traveler's checks not commensurate with stated occupation;
* significant and even-dollar deposits to personal accounts over a short period;
* structuring of deposits at multiple bank branches to avoid BSA requirements;
* refusal by any party conducting transactions to provide identification;
* apparent use of a personal account for business purposes;
* abrupt change in account activity;
* use of multiple personal and business accounts at one or more financial institutions to collect and then funnel funds to a small number of foreign beneficiaries, especially in a Persian gulf state;
* use of cash intensive businesses to disguise sources of funds;
* deposits followed within a short time frame by wire transfers of funds;
* deposits made using a combination of monetary instruments atypical of legitimate business activity (e.g., business checks, payroll checks, and Social Security checks);
* movement of funds made through FATF*-designated non-cooperative countries or territories (*Financial Action Task Force);
* use of sequentially-numbered money orders;
* shared addresses, which are also business locations, by individuals involved in cash transactions;
* involvement of people of multiple nationalities from countries associated with terrorist activity acting in behalf of similar business types;
* movement of funds through state sponsors of terrorism and countries listed as having highly active Anti-American terrorist activities (e.g., Cuba, Iran, North Korea, Libya, Sudan, etc.);
* use of a charity/relief organization (especially an unfamiliar one) as a link in transactions;
* wire transfer activities to and from multiple relief and/or charitable organizations, domestic and foreign (terrorists have used both obscure charitable/relief organizations and "dark corners" of popular ones);
* individual or entity involved is identified on one of the lists of suspected terrorists, terrorist organizations, or associated individuals or entities.

September is National Preparedness Month -- by T_Duxbury on Wednesday, September 7 2011
Every year, financial institutions review and reexamine their programs for emergency preparedness and business continuity. Such programs are not only necessary from a business perspective, but are also required by banking law and regulation.

There are many facets to planning and preparedness. The institution's formal program will detail policy and procedures as well as contingencies and actions. Starting with an assessment of risk, the institution must determine its points of vulnerability and plan for at least two and preferably three contingencies ("three-deep"). From the planning strategy and administration to action tasks and responsibilities to maintenance, each program must take into account the unexpected, and, as such, hope for the best and plan for the worst. [Note: Our "Emergency Planning: Business Continuity and Disaster Recovery" (a manual now in its third edition) details each of these, along with sample policies, procedures, and documents, including action tasks and checklists.]

Each financial institution's board of directors and senior management must meet the spirit and letter of the law and supervisory/regulatory expectations when discharging their duties. Among these responsibilities are:

* Establishing policies and procedures and assigning responsibilities to ensure that comprehensive corporate business resumption, contingency planning, and testing take place.

* Annually reviewing the adequacy of the institution's business recovery and contingency plans and test results.

* Documenting such reviews and approvals of the institution's business recovery, contingency plans and test results.


In addition, if the institution uses information processing services from a third party, senior management must also:

* Evaluate the adequacy of contingency planning and testing for its service bureau.

* Ensure that the institution's contingency plan is compatible with that of its service bureau.


Just as these programs are critical to the success of each financial institution's business continuity, proper planning should also be undertaken by its customers/members/clients and members of the community. Just as the local financial institution is often one of the leaders in its local community, it leads by example when dealing with emergency planning. There are many sources for emergency planning -- the Department of Homeland Security, FEMA, the Red Cross, better business bureaus, and the local hometown media. But a financial institution's duty to its customer/member can often make a difference -- in education, financial preparation, and communication. In this way, banks and other financial institutions preserve the lifeline that is so important in times of emergency.

White House Plan Targets Organized Crime Threat to Banks -- by T_Duxbury on Wednesday, September 7 2011

Because a year-long study commissioned by the Obama Administration has concluded that online networks "undergird" nearly every illicit organization in the world, the administration has devised a plan to fight global organized crime with a special focus on computer crime. The research is the first such organized crime study in 15 years. Some of the major problems that the new battle plan is going to address are:

* The burgeoning of global syndicate-orchestrated theft of intellectual property. Domestic and foreign enterprises steal proprietary items through intrusion into corporate and proprietary computer networks.

* As alluded to above, virtually every transnational criminal organization and its enterprises are connected and enabled by computer systems, making cybercrime a substantially more significant concern than it was even in the recent past. The focus on, and level of expertise in, cybercrime has placed transnational criminal organizations in positions where they pose a significant threat to financial systems like banking, stock markets, e-currency, and value and credit card services. These are major factors upon which the world economy depends.

* The United States is admittedly short on help for tracking criminal digital money trails. In addition, there is a speed differential between cybercriminal acts and cyber investigations. Crimes can occur very quickly, while the investigations proceed much more slowly not only because of the comparative nature of the two processes but because of the shortage of qualified personnel, who must be highly trained just to function adequately. Digital evidence piles up in ever-increasing amounts very quickly.

The forces of good remain undaunted and indefatigable. The President's plan proposes to do the following:

* It coordinates with foreign partners on executing better computer forensics analysis, as well as on recovering digital evidence for prosecutors. On a very positive note, in 2010 the U.S. Secret service, surprisingly home to 31 electronic crime task forces, arrested more than 1,000 suspects for fraud-related violations that generated losses amounting to more than $500 million.

* The White House strategy calls for the United States to ramp up its tackling of drug trafficking, terrorist financing, and human smuggling, among other areas of global conspiracy.

* The plan outlines a series of legislative proposals to expand the federal government's power to investigate and prosecute top crime families.

* Proposals will, according to U.S. Attorney General Eric Holder, expand racketeering laws to cover new kinds of crime.

* The plan contains an executive order that places economic sanctions on syndicates and prohibits Americans from doing business with them.

* It bars individuals covered by the executive order from entering the United States.

* The plan initiates a rewards program to elicit tips that could lead to the arrest of leaders who pose the greatest threat to national security.

Aspects of the plan are moving forward, and another sign that the White House plan is being pursued very seriously can be seen in President Obama's recent imposition of sanctions on serious global criminals such as The Brothers' Circle, a Eurasian group of criminal enterprises, mainly located in the former Soviet Union, which is said to be growing rapidly; Camorra, the largest Italian organized crime group; Yakuza, a major Japanese network that primarily engages in drug trafficking; and Los Zetas, a brutal organization largely based in Mexico that is responsible for killing U.S. Customs agents and carrying out mass murders.