On June 16th 2023 a workshop on internal investigations and the forensic use value of the TRACE tool for the purpose of tracing illicit money flows took place at the Vienna Centre for Societal Security. The workshop was attended by the project coordinator, two VICESSE staff members, an expert from the TRACE technology partners, as well as three investigators from different European countries who either work in internal investigations themselves or have been involved in internal investigations.
Internal investigations by their very nature often involve covert activities and observations inside one’s own organisation, to detect secret financial transactions and evidence of illicit practices involving the staff members of law enforcement agencies. A comprehensive screening of Open-Source Intelligence (OSINT) may provide a lead towards more targeted and in-depth investigative activities. Routine checks of staff’s publicly accessible social media activities can help to identify weak signals and leads for further investigations. The challenge is to filter out those pieces of evidence and suspicious links among the locations, activities and individuals that are most likely to be of forensic use value. The TRACE solutions should offer the flexibility to adapt search and retrieval procedures to specified typical patterns and to work from targeted individuals towards their broader networks; identifying any suspicious connections with outside persons or groups with prior criminal records, or vested interests in contacts with Law Enforcement Agencies.
Compared to the extant market for off-the-shelf tools that provide a plug and play solution for narrowly defined problems, TRACE promises broader and more comprehensive functionality. However, to make TRACE solutions an attractive alternative to existing tools will require a high level of maturity or Technology Readiness Level (TRL) at the end of the project, as well as reliable maintenance and service provision.
Another crucial issue that was raised by participants was the involvement of high-level staff and political actors in illicit activities revealed by internal investigations. Passing on evidence and suspicious findings upstream within the organisational hierarchy may have detrimental effects for individuals and teams, while public prosecutors can stop any further investigation when political office holders or powerful actors seem to be involved in illicit activities. For complex and politically charged cases an independent prosecuting agency, operating outside the (in)formal political networks and hierarchies of national law enforcement communities, could help to curb any undue influence on the path of internal investigations. Institutions like EPPO or OLAF, operating at the European Commission level, could provide a blueprint for such an independent body for criminal investigations.
The workshop applied Chatham House rules and the minutes were declared classified, and circulated only among the participants. The detailed insights shared by participants will feed into the meeting of the expert group on trust-based information sharing, arranged for later this year as part of TRACE WP7.
Author: Reinhard Kreissl, VICESSE