On Jan. 19, 2017, The Western Union Company (Western Union) agreed to forfeit $586 million and admitted to criminal violations including willfully failing to maintain an effective anti-money laundering program and aiding and abetting wire fraud. A U.S. Department of Justice (DOJ) investigation uncovered hundreds of millions of dollars being sent to China in structured transactions designed to avoid the reporting requirements of the Bank Secrecy Act, and much of the money was sent to China by illegal immigrants to pay their human smugglers.
Kenneth A. Blanco, Acting Assistant Attorney General at the DOJ, shared this case at the 2017 ACFE Law Enforcement and Government Anti-Fraud Summit, and encouraged the work of Certified Fraud Examiners (CFE) who globally fight to prevent and detect fraud. “As the Western Union case demonstrates, your work matters,” said Blanco. “A case like this stops not just one or a handful of criminals, but cuts off a financial highway for untold criminal schemes, wherever those criminals may be located.”
Hosted by the ACFE Law Enforcement and Government Alliance (LEGA), this 1-day event on October 30 in Washington, D.C., brought 149 law enforcement and government professionals together to learn about the latest insights, techniques and tools to address anti-fraud challenges. Blanco, a keynote speaker, also highlighted the efforts of the DOJ in stopping white-collar criminals globally.
“White-collar criminals, hackers, transnational-organized criminal groups, terrorist and even nation states are becoming more sophisticated at using our networks and devices against us — moving criminal proceeds, stealing from our bank accounts, and compromising sensitive and private information,” said Blanco. “Fighting these types of schemes is and will remain a priority for the Department of Justice.” Blanco explained that the DOJ is working more closely than ever with foreign counterparts to investigate and resolve cases in an effort to stamp out corruption and level the playing field for honest companies.
Blanco also shared a piece of advice for CFEs when working complex white-collar crimes at home or abroad. “Consulting with prosecutors early on ensures that they will understand the evidence, and working together, you can develop an effective investigative plan,” he explained.
In addition to its global efforts, Blanco said that the DOJ is using data analytics to aid its investigations and prosecutions. He explained that the criminal division’s fraud section has been a leader in the effort, in part through its Health Care Fraud Unit, which oversees the Medicare Fraud Strike Force with nine locations nationwide. “By finding anomalies in the billing data, law enforcement and prosecutors are able to focus on outliers from the outset, identifying schemes in real time, and focus limited resources on the most important matters,” Blanco said. “This approach has proven so valuable that the [U.S.] Attorney General recently announced a new data analytics program to focus specifically on opioid-related health care fraud using data to identify and prosecute individuals that are contributing to the opioid epidemic.”
According to Blanco, these are but a few examples of the great work the DOJ is doing. And these examples of successes are only possible thanks to the hard work of investigators and analysts. “People like you, who follow the leads, follow the money, analyze the data, and help develop the evidence necessary to bring criminals to justice and protect innocent people,” he said. “Together we will ensure that there is no place for criminals to hide, and no place for them to hide their money, assets or any kind of wealth.”