Page 24 - Customs Today Winter1984-OCR
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Through independent and objective inquiry and reporting, the investigative, audit and management inspection disci
plines work together to identify corrup
tion, fraud, misconduct and mismanage ment.
The Internal Security Function
The Office of Internal Security
conducts investigations based on allega
tions or suspicions of criminal activity or
misconduct under criminal laws or
Department-administered rules and reg
ulations. When sufficient evidence exists
to support the allegations, the Office of
Internal Affairs presents the case to the
U.S. Attorney or local law enforcement
agency for possible prosecution. When
prosecution is not warranted or is de
clined, matters are referred to Customs
managers for administrative action. Internal Security responsibilities in
clude the following principle functions:
• Investigations of complaints or in
formation indicating criminal acts, viola tions of Service Regulations and other
improprieties on the part of current and former employees.
• Investigations of persons outside
the Service where their actions involve
corruption of, or attempts to corrupt or
improperly influence Service employees. • Investigations of personnel in
volved in certain other Treasury Inspec tor General referrals; and special in
vestigations, studies or inquiries when re
quested by the Office of the Secretary of the Treasury, the Commissioner or other
senior officials.
We have three criteria which we
utilize in making the decision to open an
investigation. First, the matter or allega tion must be serious. Secondly, there
must be some fact or issue in dispute. And finally, there must be an avenue of
investigation open to pursue. What is fre-
quendy misunderstood is that the inter nal security role is only investigative. The
facts of a particular situation are reported to Customs managers and/or supervisors who have the ultimate responsibility for
any action taken. On occasion, a dis honest person may seek to gain by at
tempting to bribe or otherwise corrupt an
employee to commit crimes against the United States Government. If a prospec
tive employee has established an integrity
pattern below the high standards de manded of Service employees, or if an
employee is vulnerable to temptations or tries to defraud the revenue, the reputa
tion and integrity of the entire Service, as well as his own, is in jeopardy. For this reason, the work of the Internal Security agent involves as much "prevention" as
The program mission of Internal
Security is responsive to—and closely mirrors—the enforcement initiatives of
the Customs Service, and proactive
investigations have been conducted or will be developed in the areas of drug
enforcement, commercial fraud, curren
cy, and critical technology.
A trend of growing concern is the
number of integrity investigations being conducted in the area of drug enforce ment. This, by its very nature, brings our officers into contact with powerful and organized criminal elements with
large amounts of illegally obtained money.
Since Internal Security resources are strained to accomplish its criminal in
vestigative function, whenever possible,
managers are encouraged to make ad ministrative inquiries and to deal with
less serious disciplinary matters without
involving Internal Affairs. For example, time and attendance matters, disciplinary
problems, travel vouchers, etc., are all matters that fall within basic manage
ment and supervisory responsibilities. Approximately 250 integrity investi
gations are performed annually, resulting in about 60, arrests of employees and
civilians fpr a variety of integrity breaches^ft should be noted that em
ployees are cleared of all allegations in
many investigations, which indicates In ternal Security's commitment to objec
tively discover the facts in each situation.
Additionally, approximately 1,200 full field background investigations are proc
essed annually. All new Customs em
ployees receive National Agency Checks
(NAC) for employment screening, and all individuals in sensitive positions
receive full field background investiga tions. Based upon the actual classified materials handled and the need to know classified information, security clearances are issued based upon a clear full field background investigation.
The Office of Internal Security has
oversight responsibility for establishing
procedures and ensuring the protection of national security classified materials.
Internal Security agents perform surprise
inspections of classified material con tainers and facilities, and engage in train
ing seminars for Customs employees who will handle such materials.
While there is no certain way of pre
venting isolated instances of misconduct, there are several important things that a
manager can do to reduce the likelihood of serious problems. First, through his
personal conduct and attention to
integrity-related matters, he must send out a clear and consistent message that he
expects the utmost in integrity and will
tolerate nothing less. Secondly, he should establish and maintain adequate internal controls. That is, a system of checks and balances and a practice of periodic per sonnel rotation which insures that employees are not subjected to unneces sary temptations and do not, over a period of time, become too comfortable with their counterparts in the private sec tor. Thirdly, he should be responsive to the findings and recommendations con tained in Management Inspection and Internal Audit reports.
Managers are expected to take an active role in establishing procedures and
an atmosphere conducive to the develop ment and enhancement of integrity within Customs. Managers and super visors, in addition to setting examples by their own honesty, have a very important role in maintaining the integrity of opera tions and individuals under their control, and minimizing any resulting tempta tions as much as possible. In analyzing many investigative reports, Internal Security has determined that a number of serious integrity lapses have occurred because of managerial deficiencies which, because of improper supervision, have afforded employees the opportunity to go astray or be corrupted.
Corruption, accepting gratuities, mismanagement or failure to perform assigned duties properly can be insidious, and grow larger in any organization. The responsibility to prevent or report occur rences early to Internal Affairs is yours, and yours alone, thereby keeping the Customs Service a proud tradition. The caller is afforded complete confidentiality by dialing the Internal Affairs Hodine at FTS 566-2220. This number allows the caller to make Internal Affairs aware of criminal misconduct, fraud, waste and abuse through a 24-hour taped telephone message.
The Internal Audit Function
The Internal Audit activity is opera tional in the seven regional cities in addi tion to Headquarters. It is responsible for
auditing Customs programs and activi ties and providing management with
reports of their findings. These reports are used to document the fact that man
agement's policies and procedures are
being carried out as expected, to state an
opinion on the accuracy and fairness of financial records, and to alert manage
ment to the possible need for taking cor rective actions to improve operations that are not meeting expectations. In addi tion, the Office of Internal Audit and its field counterparts conduct special audits, such as pre-award contract audits, to help managers decide the most effective use of
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