INTRADEPARTMENTAL CORRESPONDENCE SUBJECT: ASSESSMENT OF UNITS EXEMPTED FROM THE FINANCIAL DISCLOSURE PROGRAM

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1 INTRADEPARTMENTAL CORRESPONDENCE March 28, TO: The Honorable Board of Police Commissioners FROM: Chief of Police SUBJECT: ASSESSMENT OF UNITS EXEMPTED FROM THE FINANCIAL DISCLOSURE PROGRAM RECOMMENDED ACTION 1. It is recommended that the Board of Police Commissioners REVIEW and APPROVE the attached Assessment of Units Exempted from the Financial Disclosure Program. DISCUSSION Internal Audits and Inspections Division conducted the Assessment of Units Exempted from the Financial Disclosure Program to: 1) provide a synopsis of the responsibilities of all entities within Gang and Narcotics Division (GND); and, 2) reassess the appropriateness of an original determination to exempt certain units within GND from participating in the Financial Disclosure Program. If additional information regarding this inspection is required, please contact Gerald L. Chaleff, Special Assistant for Constitutional Policing, at (213) Respectfully, r----7 Chief of Police Attachment <? \CHARLIE BECK

ASSESSMENT OF UNITS EXEMPTED FROM THE FINANCIAL DISCLOSURE PROGRAM Prepared by Internal Audits and Inspections Division March 2012 PURPOSE In January 2010, the Los Angeles Police Department

2 ASSESSMENT OF UNITS EXEMPTED FROM THE FINANCIAL DISCLOSURE PROGRAM Prepared by Internal Audits and Inspections Division March 2012 PURPOSE In January 2010, the Los Angeles Police Department (Department) underwent a reorganization to enhance its efficiencies and effectiveness. In order to ensure that the reorganization did not impact the Department's responsibilities pursuant to the Transition Agreement and Special Order No. 20, 2007, Internal Audits and Inspections Division (IAID) prepared this assessment to: 1) provide a synopsis of the responsibilities of all entities within Gang and Narcotics Division (GND); and, 2) reassess the appropriateness of an original determination to exempt certain units within GND from participating in the Financial Disclosure Program.' BACKGROUND The 2001 Consent Decree between the City of Los Angeles and the Department of Justice included a requirement to implement a Financial Disclosure Program in which Department employees who routinely handle valuable contraband or cash would complete a financial disclosure on a periodic basis. 2 In 2007, after extensive discussions with the Department of Justice, the former Independent Monitor, the Los Angeles Police Protective League, the former Inspector General, and City management, the Department drafted Special Order No. 20, entitled, "Confidential Financial Disclosure Policy and Procedures for Gang Enforcement Detail and Narcotics Field Enforcement Section Unit." This Special Order was approved by the Board of Police Commissioners on December 20, 2007 and became effective on March 29, The general consensus of the stakeholders was that the Financial Disclosure Program would be applicable to entities in which the primary focus involves monitoring, investigating, and/or reducing gang or narcotic related crimes. Therefore, Special Order No. 20, 2007 specified that financial disclosures would need to be completed by all sworn employees of the rank of lieutenant or below that were assigned to the following entities: Gang Impact Teams (GITs); Gang Enforcement Details (GEDs); Community Law Enforcement and Recovery (CLEAR) Units; Narcotics Division; and, Narcotic Enforcement Details (NEDs). Special Order No. 20, 2007 requires each employee in these assignments to complete a Confidential Financial Disclosure Face Sheet and Confidential Financial Disclosure Report (referred to as the financial disclosure) in which the employee documents his/her assets, liabilities, and income sources. The Financial Disclosure Program Administrator (FDPA) assigned to IAID meets with each employee submitting their financial disclosure to discuss their financial situation and reviews the disclosure for any obvious errors or omissions. The financial disclosure is then reviewed and approved by the Commanding Officer (C/O) of IAID, the References to entities may include teams, units, details, tasks forces, squads, sections, and/or divisions. 2 This requirement was carried over to a 2009 Transition Agreement that is still in effect.

3 Page 2 of 7 Special Assistant for Constitutional Policing, and the Chief of Police. A scanned version of the financial disclosure is stored within the Office of the Chief of Police and the hard-copy original version of the disclosure is either returned to the applicable employee or destroyed based on the employee's requested preference. Once approved and filed, the C/O of the receiving division is advised by the FDPA that the employee can begin to work within the assignment. As of March 15, 2012, over 1,000 financial disclosures have been submitted and filed within the Office of the Chief of Police by employees assigned to these entities. On January 3, 2010, to enhance efficiencies and effectiveness, the former Chief of Police decided to merge Narcotics Division (ND) with Gang and Operations Support Division (GOSD) to form Gang and Narcotics Division (GND). As consensus had previously been reached between multiple stakeholders that entities within GOSD were not subject to the Financial Disclosure Program, the original GOSD entities merged into GND continued to be exempt from the Financial Disclosure Program as their functions and responsibilities did not change. All original ND entities that merged into GND continued to be subject to the Financial Disclosure Program. SUMMARY OF ASSESSMENT RESULTS Based on IAID's discussions with the C/O of GND and the applicable Officers-in-Charge (OIC), the 14 entities within GND that are currently considered exempt from the Financial Disclosure Program were originally GOSD entities and the primary focus of the entities have not changed since before the merge into GND. One entity such as the Federal Bureau of Investigations (FBI) Gang Task Force, the employees are routinely exposed to handling valuable contraband or cash and the entity has the primary responsibility of monitoring, investigating, or reducing gang related crimes. The FBI completes a comprehensive background investigation prior to the Department employees being assigned to the task force which covers an assessment of the employee's financial status. Therefore the rationale to exempt them from the Financial Disclosure Program per the original intent of Special Order No. 20, 2007 still exists. Additionally, a few of the units have been disbanded and therefore an analysis of their functions and duties is not warranted and will be conducted if and when they are reformed. Going forward, on a quarterly basis, the FDPA within IAID will check the organization chart of GND to ensure that any newly created entities are appropriately considered for the Financial Disclosure Program and to ensure that the officers in these entities are in fact performing the duties described below. Any change in the duties performed will cause an evaluation to determine if the officers in the units should be subject to the Financial Disclosure Program.

Page 3 of 7 ENTITIES WITHIN GND EXEMPT FROM THE FINANCIAL DISCLOSURE PROGRAM Within GND, there are 14 entities that are considered exempt from the Financial Disclosure Program.

4 Page 3 of 7 ENTITIES WITHIN GND EXEMPT FROM THE FINANCIAL DISCLOSURE PROGRAM Within GND, there are 14 entities that are considered exempt from the Financial Disclosure Program. According to the C/O of GND and the applicable OIC, the 14 entities were originally under GOSD and the primary focus of these entities has not changed since that time. The table below delineates the entities within GND that were originally exempted (per Special Order No. 20, 2007) from the Financial Disclosure Program along with a brief synopsis of the primary focus of these entities. TABLE NO. 1 ENTITIES WITHIN GND EXEMPT FROM THE FINANCIAL DISCLOSURE PROGRAM Synopsis of the Primary Focus of Each Entity 3 1) GND's Fugitive Warrant Squad (21 sworn employees). This squad was originally part of GOSD. The squad primarily focuses on enforcing outstanding warrants originating from the City. The squad also extradites suspects arrested outside City limits for active warrants. 2) GND's Verification Squad (4 sworn employees). This squad was originally part of GOSD. The squad primarily focuses on verifying information on new warrants and assigning warrant enforcement to appropriate investigators. The squad also inputs relevant data into the Warrant Tracking System. The squad has administrative responsibilities and does not have any field duty or contact with suspects. 3) GND's Rendition Desk Unit (4 sworn employees). This unit was originally part of GOSD. The unit primarily focuses on coordinating with federal, state, and county prisons for incustody warrant suspects wanted for appearance on local charges. The unit also liaisons with prisons for in-custody transportation to court with the Los Angeles Sheriff's Department and surrounding agencies. This unit has administrative responsibilities and does not have any field duty or contact with suspects. 4) GND's FBI Criminal Gang Task Force (7 sworn employees). This task force was originally part of GOSD. The task force primarily focuses on providing assistance to the FBI in their investigations of federal Racketeering Influence Corrupt Organizations (RICO) cases against Hazard Gang and the Mara Salvatrucha (MS) Gang. The task force assists with the preparation of federal forms, conducts investigations into the gangs' activities through narcotic buys, gun buys, and extortion payments in the furtherance of RICO standards. The FBI does not complete a Confidential Financial Disclosure for Department personnel assigned to the unit. According to GND, the FBI completes a comprehensive background investigation prior to the Department employees being assigned to the task force which covers detailed financial information. 3 The number of sworn employees assigned within each GND entity is based on information provided by GND as of January 29, 2012 (DP No. 2, 2012). The figure can and does fluctuate through the year and does not include reserve officers or vacant sworn positions.

5 Page 4 of 7 5) GND's FBI Fugitive Task Force (6 sworn employees). This task force was originally part of GOSD. The task force primarily focus is to assist detective persormel with locating and apprehending those individuals wanted on felony warrants. In addition, the task force also performs extraditions of warrant suspects wanted in Los Angeles but who are arrested outside the State. 6) GND's United States Marshals/Foreign Prosecution Liaison Unit (4 sworn employees). This unit was originally part of GOSD. This unit primarily focuses on providing assistance to Interpol with the apprehension and extradition of wanted suspects residing in the United States. The unit also assists with the apprehension of wanted suspects outside the United States. 7) GND's United States Marshals Pacific Southwest Regional Fugitive Task Force (7 sworn employees). This task force was originally part of GOSD. This task force primarily works with the United States Marshals to identify the most criminally active, violent fugitives and criminal enterprises impacting the City for investigation, arrest, and prosecution. The technology side of this task force oversees and operates the United States Government Electronic Surveillance Equipment for the investigation and tracking of violent fugitives. 8) GND's Parolee at Large Unit (11 sworn employees). This unit primarily focuses on locating and arresting any post-released supervised persons deemed to be "at large" and extradites those persons when arrested out of the City or State. The unit was originally disbanded from GOSD in 2008 but was reestablished in January As Special Order 20 was approved in 2007, and this unit was not originally considered to be subject to the Financial Disclosure Program, it continues to be exempt within GND. 9) GND's Career Criminal Apprehension Unit (11 sworn employees). This unit was previously called the Gang Field Unit under GOSD. The unit was renamed to the Career Criminal Apprehension Unit when merged to GND. The unit primarily focuses on the surveillance of "career criminals" and assisting geographic Areas with the apprehension of "career criminals" who commit part-one crimes; such as Murder, Rape, Robbery, Burglary, etc. 10) GND's Administrative Unit (3 sworn employees). This unit was originally part of GOSD. The unit handles administrative duties/projects and is not assigned to field duties. 11) GND's CLEAR Liaison Detail (2 sworn employees). This detail was originally part of GOSD. The unit primarily focuses on providing oversight to ensure CLEAR units throughout the Department are following proper protocols and procedures. The unit has no enforcement function and is administrative in nature. 12) GND's Cal Gang/Los Angeles Regional Gang Information Network Detail (2 sworn employees). This detail was originally part of GOSD. The unit primarily focuses on providing oversight of the Cal Gang system and is administrative in nature. On a limited basis personnel assigned to the unit may be required to partake in field operations, but only for perimeter control and as force multipliers. 13) GND's Asian Crime Unit (4 sworn employees). This detail was originally part of GOSD. This unit primarily focuses on handling investigations into crimes involving Asian suspects and/or victims on a citywide basis where Asian language and/or cultural expertise is required, focusing on investigations involving part-one crimes (Robbery, Burglary, Extortion, etc.).

6 Page 5 of 7 14) GND's Gun Unit (13 sworn employees). This unit was originally part of GOSD. The unit's primarily focuses on reviewing and processing all concealed firearm license applications, developing strategies to combat firearm trafficking, inspecting all licensed firearm dealer locations in the Los Angeles City to verify compliance with federal, State, and local licensing requirements, investigate applicants requesting permits to sell firearms and/or ammunition in Los Angeles City, and investigating and seeking criminal filings on gun traffickers. The unit also acts as a subject matter expert in firearm related matters for the Department. ENTITIES SUBJECT TO THE FINANCIAL DISCLOSURE PROGRAM The table below delineates the entities currently subject to the Financial Disclosure Program (per Special Order No. 20, 2007). TABLE NO. 2 ENTITIES SUBJECTED TO THE FINANCIAL DISCLOSURE PROGRAM Synopsis of the Primary Focus of Each Entity 1) All GEDs, CLEAR Units, GITs, and NEDs Department-wide (601 sworn employees). The primary focus of these entities is to monitor, investigate, and reduce gang or narcotic related crimes. 2) GND's K9 Squad (10 sworn employees). This squad was originally part of ND. The squad's primary focus is to train and supervise the use of narcotics detection dogs for the Department. The K-9's are used to locate narcotics and drug tainted money in a variety of field situations. 3) GND's 9Y460 Squad (7 sworn employees). This squad was originally part of ND. The squad's primary focus is to investigate, arrest, and prosecute individuals and organizations that engage in narcotics trafficking and/or money laundering. The squad works in other local, state, and federal crime task forces. 4) GND's PARCEL Squad (6 sworn employees). This squad was originally part of ND. The squad's primary focus is to work closely with the United States Postal Service for the interdiction of narcotics and currency, and to arrest suspects who use the public and private mail systems to distribute narcotics. 5) GND's Los Angeles International Airport (LAX) Squad (6 sworn employees). This squad was originally part of ND. The squad's primary focus is to target drug traffickers entering the Los Angeles Area through the LAX. 6) GND's Narcotic Abatement Units (17 sworn employees). These units were originally part of ND. The units' primary focus are locations that have reputation of being centers for the distribution and sale of narcotics and works with Area senior lead officers to supplement Neighborhood Watch and Apartment Watch Programs. The units work in conjunction with the Los Angeles City Department of Building and Safety, the Los Angeles City Attorney's Office and community organizations, and under the authority of state narcotics abatement laws and federal narcotics asset forfeiture laws.

7 Page 6 of 7 7) GND's LAB Squad (8 sworn employees). This squad was originally part of ND. The squad's primary focus is to investigate illegal drug manufacturing laboratories and assists in handling extremely dangerous chemicals. Additionally, the squad responds to calls from other narcotics field units and from patrol divisions for expert assistance at locations involving illegal drug manufacturing or storage of dangerous chemicals. 8) GND's Los Angeles Intra-Agency Metropolitan Police Apprehension Crime Task Force Squad (8 sworn employees). This squad was originally part of ND. The squad's primary focus is to target, investigate and prosecute individuals who organize, direct, finance, and otherwise engage in medium to high-level drug trafficking enterprises or money laundering. Forty-two Los Angeles County municipal law enforcement agencies, the Bureau of Narcotics Enforcement and the U.S. Customs Service are involved with this task force. 9) GND's High Intensity Drug Trafficking Area Groups (23 sworn employees). These groups were originally part of ND. These groups were originally part of ND. The groups' primary focus is to conduct intensive investigations of drug trafficking organizations that operate on a national and/or international scale in an effort to dismantle those organizations. The groups also investigate and prosecute financial crimes and other crimes related to narcotics trafficking. The groups work in conjunction with other federal, State and local law enforcement agencies. 10) GND's Logistics Detail (5 sworn employees). This detail was originally part of ND. The detail's primary focus is to conduct technical installations of covert surveillance equipment and maintain/repair specialized electronic and communication equipment utilized in narcotic investigations. The detail also orders, inventories, and maintains all of GND's sensitive and costly surveillance equipment, body armor, and mission-specific equipment. 11) GND's Asset Forfeiture Investigation Detail (10 sworn employees). This detail was originally part of ND. The detail's primary focus is to conduct complex investigations requiring the preparation of search warrants for bank and other financial records, property, and business records, and any other evidence which tends to show that monies or assets seized are proceeds of narcotic transactions. The detectives also complete all reports required by the District Attorney's Office and/or the federal agency handling the civil forfeiture proceedings on all seizures of currency, vehicles, and related items, as well as the storage of all seized vehicles. 12) GND's Investigative Support Detail (2 sworn employees). This detail was originally part of ND. The detail's primary focus is to collect and analyze sensitive narcotics information and promote the exchange of confidential information not obtainable through regular law enforcement channels. Specific information relative to suspects, trafficking locations, trends, and ongoing investigations are obtained from numerous law enforcement agencies throughout the Southern California region. 13) GND's Joint Drug Intelligence Group Liaison Detail (1 sworn employee). This detail was originally part of ND. The detail's primary focus is to provide post-seizure analysis for the purpose of enabling more effective and efficient utilization of drug investigation resources. The detail is a federally-funded task force. 14) GND's Confidential Informant Coordinator Detail (5 sworn employees). This detail was originally part of ND. The detail's primary focus is to ensure Confidential Informants are properly utilized Department-wide.

8 Page 7 of 7 15) GND's Filing Detail (26 sworn employees). This detail was originally part of ND. The detail primarily focuses on evaluating all narcotic arrests for presentation to the District or City Attorneys for criminal filing. Additionally, the detail's duties encompass arrestee processing for all adult and felony criminal filings, follow-up responsibility on narcotic arrests, and maintaining records and files of narcotic arrests. 16) GND's "Buy" Team (10 sworn employees). This team was originally part of ND. The team primarily focuses on conducting buy/bust operations in targeted narcotics locations citywide resulting in the elimination of the blatant street sales of narcotics. The team also responds to requests from the Areas for deployment to narcotic hot spots. These hot spots, by virtue of the narcotics activity, have associated Part 1 crime problems to include: burglary, robbery, aggravated assaults, and murder. In addition, there are quality of life issues due to the prevalence of associated crimes such as prostitution, illegal drug use and possession, vandalism, and the involvement of gangs and firearms in narcotics sales. 17) GND's Staff Services Detail (2 sworn employees). This detail was originally part of ND. The detail's primary focus is to research and analyze short and long-term matters which affect narcotics operations and prepare fact sheets, orders, audits, special orders, and documentation on narcotics enforcement policies. 18) GND's Training Detail (5 sworn employees). This detail was originally part of ND. The detail's primary focus is to training officers monitoring, investigating, and reducing narcotic related crimes. Specifically, the detail puts on a five day Narcotics School, training on Health and Safety Code, training related to search warrant execution tactics, undercover operations, informant management and control training, and other training related to narcotic investigations and enforcement. 19) GND's Medical Marijuana Facility Inspection Detail (1 sworn employee). Although this detail was created after the merge into GND, since the detail's focus is on enforcing compliance with medical marijuana dispensary laws, the detail has been subjected to the Financial Disclosure Program. 20) GND's Dispensary and Medical Marijuana Enforcement Team (1 sworn employee). Although this team was created after the merge into GND, since the team's focus is on enforcing compliance with medical marijuana dispensary laws, the team has been subjected to the Financial Disclosure Program.

Signature: Signed by GNT Date Signed: 3/11/13

Signature: Signed by GNT Date Signed: 3/11/13 Atlanta Police Department Policy Manual Standard Operating Procedure Effective Date March 15, 2013 Applicable To: All sworn employees Approval Authority: Chief George N. Turner Signature: Signed by GNT