As the Special Agent in Charge of the Department of Homeland Security’s ICE New York field office from 2003 to 2007, I had the privilege of participating in the supervision of the El Dorado Task Force.  The El Dorado Task Force is the largest multi-agency financial crime task force in the United States.  It has conducted, and continues to conduct, some of the most important money laundering investigations in the world.  Some of my fondest law enforcement memories are associated with El Dorado investigations.

And as good as that task force is, due to the skill and commitment of the agents and law enforcement officers working it, I worry that it’s not enough.

When I managed the task force, I had a nagging belief that some of the criminal and terrorist organizations we were up against were conducting sophisticated money laundering schemes that the federal government lacked the capacity to identify, investigate and neutralize.  Simply put, the government lacked the necessary resources and expertise to compete with the criminal and terrorist minds set on exploiting the ever-evolving complexities of the financial world.

Jeff Stein’s “Spy Talk” article in CQ Politics on “terror finance tracking priorities” this week brought this concern back to mind.

Stein reviewed a recent article in the New York Times by Vikas Bajaj and John Eligion outlining significant Iranian money laundering schemes conducted with the knowledge and collusion of well-known financial institutions in Europe to deceive American financial institutions and law enforcement authorities.  Extraordinary and complex efforts were made to conceal this money, much of which could be directly connected to the support of Iran’s nuclear and missile programs.  The article concludes that “Iran, with years of experience in the game, is unlikely to be knocked much off its stride in the acquisitions game.”

I remain concerned that we (after 33 years as a Special Agent, I still use “we” when referencing federal law enforcement) lack the expertise necessary to compete in this venue.  Because money is the lifeblood of a criminal and terrorist organization, these shadowy and sophisticated organizations will continue to make extraordinary efforts to conceal their assets by developing schemes that they believe are beyond the capacity of law enforcement to investigate.

The federal government must remain competitive.  We need to assess our resources and capabilities in light of each “new” money laundering scheme discovered.

We must develop the necessary investigative expertise by recruiting, training, and maintaining the “best and the brightest” investigators in the complex underworld of money laundering and financial crime.

We must strive to develop closer partnerships with the financial industry to exchange intelligence on emerging money laundering patterns.

Even then, because of changing priorities and resources in the United States, I remain concerned it may not be enough.