It should be noted that the schedules have been prepared solely to demonstrate the technique involved in tracing what appear to be worthwhile leads to the identification of hidden ownership of business interests and other assets, and are not intended to reflect a complete listing of all deposits and withdrawals from a target's bank accounts during a given period. The users of this guide will usually have a sufficient background in the facts of a case to speculate about and perhaps determine the reason for each deposit, as shown in the third (Remarks) column.

4.

Safe Deposit Box Entrance Records

One of the most overlooked sources of financial information by criminal investigators is the entry records to safe deposit boxes. The records establish the date and time of day that a target entered his safe deposit box and also provide the investigator with an exemplar of the target's signature. The information obtained from the entry records can be used in a variety of ways in the investigation of white-collar crime cases.

First, they assist the criminal investigator in analyzing a target's financial transactions, by making a comparison of the dates of entry into the safe deposit box with known financial transactions; i.e., the deposit and withdrawal of currency from bank accounts, the acquisition with and disposal of assets with currency, the reduction of liabilities with currency, etc.

Second, and of equal importance, the information can also be used to contradict a target's alibi as to his whereabouts during a key interrogation or by a prosecutor during cross examination of a target at trial.

After obtaining copies of safe deposit box entry slips, the investigator should prepare a simple schedule, listing by dates and times of day, that the target entered his box. Opposite the entry dates, appropriate space should be left for information concerning known financial transactions.

Thereafter, every time the investigator learns of a financial
transaction entered into by the target, particularly where
the source of the funds for the transaction are not apparent,
the safe deposit box entry schedule should be checked to
determine whether or not the target entered his box on or
about the date of the transaction. This technique takes
only a minimum of time, yet can provide the investigator
with a helpful tool in determining a target's pattern of
financial conduct. In addition, the psychological impact
on a target, when confronted during the course of interro-
gation with a literal reconstruction of his financial modus
operandi, can be overwhelming.

The value of such information to a prosecutor during the course of trial can also be of equal importance.

The record of entries into a safe deposit box should, accordingly, be obtained on every target whose financial transactions are being investigated, and on those targets on whom "financial intelligence" is being gathered.

The record retention period for safe deposit box entries varies among banks. However, most banks continue to retain the records well beyond the scheduled destruction dates due to the limited storage space they require and the cost of manpower to meet record destruction schedules. In any event, the information should be obtained as quickly as legally possible, after the subject of investigation is identified.

Examples of safe deposit box entry records maintained by and available from banks are contained on pages 8-11 of Appendix D, in "The Seventh Basic Investigative Technique.

A sample "Safe Deposit Box Entry Schedule" is contained on the following page.

*In Herbert Edelhertz, et al. The Investigation of WhiteCollar Crime (Washington: U.S. Government Printing Office, 1977), Stock No. 027-000-00507-1.

One of the most important types of records maintained by banks that can lead to the identification of hidden assets is a bank's loan files. They contain, among other things, a record of all loan transactions, the collateral that secures some of the loans, and the results (including documentation) of credit investigations made by the bank. Such documentation may frequently provide leads identifying important witnesses. When a bank makes a commercial loan to an individual, or a business entity, it requires a detailed statement of the assets and liabilities of the borrower. These statements, among other things, can lead directly or indirectly to the identity of assets controlled by a target. They also often contain references to other banking contacts of a target, which, again, opens up a whole new avenue of leads.

The basic loan files are maintained by banks in their Credit Departments and are retained, for the most part,

indefinitely.

One of the "tracing techniques" which can be most valuable in attempting to detect hidden ownership of assets by a target, is to analyze the record of loan payments contained in the loan files. Each loan payment should be checked against other records to isolate those payments where the source of the funds to make the payments cannot be readily identified. Each payment, isolated by this method, may well have been made from a source of funds associated with a hidden business interest, acquired from the proceeds derived from a target's white-collar crime activities, and is therefore worthy of the effort to trace the source of the payment through the banks records to its origin.

It is important that all criminal investigators who are involved in a white-collar crime investigation requiring the analysis of financial transactions be able to recognize when a check has been "cashed."

All banks use a code stamp on the face of a check to indicate that a check has been cashed. Since there is no standard code used by all banks, it is important that criminal investigators become familiar with the type of codes used by banks in their geographic area. Examples of "cashed" codes used by some of the leading banks in the United States are contained on page 39 of Appendix D to The Investigation of White-Collar Crime, "The Seventh Basic Investigative Technique."

Bank Identification Symbols

All checks printed for banking institutions contain a series of numbers in the upper right-hand corner on the face of the checks. These numbers represent an identification code developed by the American Bankers Association and are usually referred to as the "ABA Transit Number." The "ABA Transit Number" identification code is illustrated on pages 41-43 of "The Seventh Basic Investigative Technique." Holding and Administering Property for Others

Most full-service banks offer a variety of "Trust" services to their customers. The most important aspect of this trust service to criminal investigators investigating white-collar crime cases is the performance of "agency" services to their customers. This service can assist a target in the event that he is attempting to conceal his interests derived from the proceeds from white-collar crime. Some of the services, which should be checked out by the criminal investigator, are as follows:

1. Safekeeping

2.

The bank receives, holds and delivers property on the order of the customer.

Custodian The bank acts as a safekeeping agent; also collects and pays out income, buys, sells, receives and delivers securities on the order of the customer.

3.

Escrow

The bank acts as escrow agent. For example, a target may wish to dispose of a piece