By Rick Ziolkowski, Director and Vice President, Citibank Credit Card Investigations, Hagerstown, Maryland
inancial and identity crimes are becoming more complex and time consuming to investigate. Frequently, these investigations can be overwhelming and intimidating for law enforcement officers. This often tempts officers to resolve quickly any obligation to the victim and move on to simpler work. It may be human nature for people to gravitate toward areas where they feel comfortable and where they are more confident of doing a good job, but such actions do a disservice to the victim, the agency, and the community. In truth, financial and identity crimes are some of the easiest investigations to work. There is ample evidence and documentation available for those who know where to look. In addition, financial and identity crimes have some of the highest solvability and prosecution ratios for officers. This article shows how effortless it can be for officers to gain support and understanding on these investigations.
Rarely does a police officer have direct support or assistance on an investigation. Officers are expected to act independently, making the best use of limited resources to complete their investigations. Each event is unique, and although officers receive general training, they often have to rely on their best judgment to resolve a situation. Training can take officers only so far. Ideally, they need someone who can assist throughout the course of the investigation, offering support and evidence as needed. It is time for officers to meet their new partners: financial investigators.
The typical law enforcement officer is expected to respond to a variety of criminal situations. All officers graduate from the police academy with a general knowledge of law and some investigative ability. However, no one person can be an expert in every area. Financial and identity crimes are specialized areas that require specific knowledge and expertise. Most major financial institutions have dedicated investigative teams to support police inquiries where the bank or its customers are victims. Many of these units employ former police officers for their ability to bridge the gap between the law enforcement and financial communities. Many regional and local banks have dedicated bank officials who regularly support criminal investigations. The first objective of investigating officers should be to reach out to one of these individuals to gather and secure evidence as well as to offer guidance and support to the investigation.
Where to Begin
One of the first considerations in any financial investigation is knowing whom to call for assistance. In the United States alone, there are over 7,000 banks and countless more financial providers. Many financial institutions offer a variety of products, from credit, debit, and stored-value cards to small loans, wire transfers, and other exotic payment vehicles. These products may be siloed within a certain department of the company, and generally, no cross-communication takes place between the departments that offer these product lines. The problem for police officers is how to reach the unit that will support their needs. In many cases, officers have little more than a billing statement with a business name and an account number. With a little effort, officers can obtain a general service number to call the business. Often, victims will also be able to provide a general customer service number for the bank.
This is where it gets tricky, however, and police need to know how to navigate to the appropriate department for support. Should officers try to resolve cases with the customer service agent, the agent will most likely drop, misroute, or hang up on the call. Worse yet, officers may reach an automated messaging system that has no option for police assistance. If officers take the wrong course, they might end up with a legal unit demanding a subpoena. As a general rule, officers should navigate their call to a fraud unit within the business or, ideally, to a dedicated police support unit for those larger companies who have one. Once there, they should state the purpose of the inquiry and indicate that the business and/or its customers are financial victims in the investigation. This explicit statement of the situation is necessary because it allows the financial institution to provide restricted customer and transaction information to the investigators. In addition to stating the purpose of the call, officers should provide any known account or customer information. This expedites the process of locating customer accounts. Once in the care of a dedicated fraud professional, officers are well on their way to receiving the support they need.
Investigative Unit Staff
When officers reach the investigative unit, a host of resources and support becomes available. Equally important, these dedicated units routinely deal with law enforcement agencies and are more familiar with the officer’s needs.
As an example, Citi Cards (one of the largest credit card issuers) has a dedicated, toll-free police call center, staffed by several desk investigators who respond to financial and identity crime inquiries. Desk investigators respond quickly to most calls. Routinely, they provide officers with confirmation of fraud, loss totals, transaction details, and printed documentation. Desk investigators regularly provide guidance and support to officers. Because of their dedicated function, these individuals have learned the language, needs, and culture of the law enforcement world.
In addition to staffing a police call center, Citi has built a balanced team of field investigators comprising business experts and former local, state, and federal law enforcement officers. These investigators are located in major cities around the globe and establish close relationships with local authorities to better support efforts in their area. Field investigators are used generally for more complex financial and identity crimes. Like their desk investigator counterparts, field investigators are true experts in the area of financial crimes and have developed extensive contacts with their industry peers and regional government authorities. These investigators serve as the backbone of the Citi investigations unit, taking the time to discuss strategies with officers and providing direction to investigations.
Whether handling a routine call that can be quickly resolved over the phone or a complex case that requires direct field support, Citi Investigative Services has the resources and expertise to support the law enforcement community.
A typical police inquiry received by the call center involves some type of financial crime. Desk investigators research the account, order documents, and provide direction on further potential leads. The paper trail of evidence begins at the original application process and proceeds through the fraudulent transactions and account closure. Because desk investigators have detailed information available to them, they are at times able to associate other accounts or evidence previously unknown to investigating officers.
Citi has also invested in fraud analysts who attempt to identify patterns of fraud to identify crime rings from these links. Analysts work at the macro level, creating large-ring activity cases from individual events. Like putting together pieces in a puzzle, analysts can uncover a picture of previously unknown fraud ring activity. There have been countless cases in which a key piece of evidence, such as a captured phone number, a change of address, or a recovered security film, has been instrumental in linking cases and implicating a suspect.
Field investigators are the face of the financial investigative unit for law enforcement agencies. They are the ones who interact with officers in the field and provide hands-on support to the investigation. Suggestions may be made regarding additional tools or resources, such as providing a sting or an undercover card on a covert investigation or in reaching out to other banks to expand the investigation. Field investigators have also established relationships with mail carriers and merchants to ensure a controlled delivery of stolen merchandise. Once assigned to cases, field investigators stay with the investigations all the way through the court process. Field investigators regularly provide expert testimony on the complex mechanics in the financial process. Smart defense attorneys will likely look for a plea bargain if they know that financial investigators are prepared to testify against their clients.
Outside of performing investigative work, field investigators regularly attend regional police intelligence meetings to share the latest trends and ring activity. Field investigators can be relied on to provide the latest intelligence affecting the industry or information specific to a certain area of fraud. If resources allow, field investigators can also provide regionalized training to various police units, associations, and merchant groups on fraud prevention or education. These services are always provided free of charge. The value of sharing with and educating others benefits not only the financial industry but also bank customers and the community. There are few, if any, other resources available to police that offer such depth and support to an investigation.
Limited resources and increasing demands mean that any support the financial industry can provide to criminal investigations is a welcome relief. For this reason, law enforcement agencies should seriously consider using such a valuable service. The help financial investigators can provide to investigating officers should enable them to be seen as true partners in the effort to combat financial and identity crimes. ■
|Rick Ziolkowski is director and vice president for Citibank Credit Card Investigations, one of the world’s largest issuers of credit card products, where he is responsible for the management of a global investigations unit, a police call center, and other fraud support services. Before joining Citi, Ziolkowski served as a police officer and detective with the Washington County Sheriff’s Department in Maryland. An active member of the International Association of Financial Crimes Investigators for over 15 years, he sits on the association’s Board of Advisors and acts as cochair of its Law Enforcement Committee.|