Corruption Prevention Guidelines No. 2 – Preventive Measures Against Gambling Fraud
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- Last updated：2018-11-01
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Electronic gambling games easily lead people astray and lead to many social and security issues. Gambling companies often go to great lengths to protect their enormous and often illegal interests, even to the point of enticing law enforcement officers to turn a blind eye, which causes serious damage and corruption.
Discipline is essential to the police, and as the nation’s upholder of the law, it serves the four major missions of maintaining public order, protecting social security, preventing all hazards, and promoting public welfare. The police shall thus lead by example and draw very clear lines, being the last line of defense for the protection of people's rights. Police officers are prohibited from associating themselves with any undertakings that are illegal or incompatible with their duties and responsibilities. Still, some are unable to resist the temptations offered by those illegal companies and engage in improper and prohibited contact, dealings, covering, bribery, or worse. Therefore, effective corruption prevention measures are essential to maintaining discipline at all levels within the police organization when dealing with the eradication of electronic gambling game venues.
l Summary of the case
Officer Huang and 14 other officers of the Police Bureau of County X were in charge of investigating gambling crime in their jurisdiction. Xu and 14 others were operating eight gambling companies there and were suspected of making profits from illegal gambling and of employing various channels to approach these officers through such briberies as gift boxes of premium tea leaves and Royal Salute whiskey, free membership fee of clubs and paying them TWD 20,000-30,000 in cash as consultancy fees every month. After being bribed in this way, these officers would leak information about police investigations to their benefactors, so that these illegal companies could prevent seizures during raids and such guises.
They even sent notes to the heads of these operations to alert them. Huang and other officers even took shares in these illegal electronic gambling operations. Within a time frame of fewer than five years (2006-2010), these illegal companies amassed profits of more than TWD 120 million (USD 4 million).
After the plot was uncovered, the police officers were criminally prosecuted for bribery, illegal profiteering, leaking of national security information by public service personnel, and harboring (shielding) gambling, among other counts.
l Review of the issues
1. Most of these officers had been involved in the criminal investigation for a long time or under investigation of the eight major occupations that temp to crime. In these roles they were in frequent contact with certain gambling companies’ owners, and then morphed into improper conduct.
2. The police officers of this case all had excellent performance records in terms of dedication, execution, and efficacy, without any bad assessments or negative records from their supervisors. Evidently, performance evaluators at all levels failed to grasp the true situation of these officers’ lifestyles and social interactions, and this first line of defense had clearly failed.
3. The electronic gambling game companies had been running for a long time. The officers of Police Bureau of County X failed to timely investigate and eradicate this crime, which was a clear failure.
4. The police officers of this case all had duties specifically related to the investigation and eradication of electronic games in their jurisdiction, and they were clear grooming targets for the illegal companies. In addition, the officers’ concept of the rule of law was inadequate, which is why they could be lured by improper benefits and become ensnared in a net of illegality.
1. A rotation system may help prevent breaches of discipline:
2. Officers whose duties regularly involve them in disputes around profits from the illegal business are clear targets for illegal companies to groom. A long period in the same position heightens the risk of enticement and bribery. A system of job rotation will help strengthen the internal control mechanism and prevent breaches of discipline from occurring again.
3. Inventory of officers of concern with regard to discipline may serve as a point of reference for evaluating discipline-related laws and regulations. Continuous evaluation of officers' tendencies to breach discipline and such penalties as current salary deductions, lower discipline assessment ratings, problematic contacts, and playing card games with gambling, shall all be included as key topics of such audits, to prevent corruption.
4. Investigation of venues where temptations to breach discipline occur, strengthen audits of corruption risks:
5. Police units at all levels shall continue to investigate and eradicate venues in their jurisdictions that offer enticements to breach disciplines, such as pose professional casinos, gambling games, prostitution, and other illegal businesses. Only when such enticing venues and illegal businesses are eliminated, can corruption be prevented. Also, corruption-focused audits shall be conducted to prevent opportunities for corruption from arising.
6. Strengthen legal awareness efforts and promote proper leisure activities: police agencies at all levels shall gather to disseminate information about clean government and corruption cases and promote positive forms of recreation, strategies for coping with work pressure, spending more time with family, and grasp the family context.
7. Strengthen the administrative punishment timely:
8. In corruption cases involving major administrative negligence or violation of laws and regulations, the negligent officers shall be strictly punished. Moreover, if supervising officers are found negligent in their duties, they are held jointly liable to make the consequences match with their authorities and responsibilities.
9. Actively uncover corruption and unlawful conduct, investigation, and punishment: With regard to officers potentially involved in aforementioned major corruption, monitoring of their whereabouts and communications shall be conducted to collect potential evidence as a means to detect major criminal cases to be investigated further. When a case has been ascertained as true, it shall be strictly investigated and handled. Also, cooperation with government ethics units, inspection units, and external investigation forces shall be sought to actively uncover corruption and unlawful conduct and carry out investigation and punishment in order to correct inappropriate negligence and errors.
l Suggestions from AAC
Illegal profits from electronic gambling games are sizeable, and those companies are often operated by organized gangsters. Not only do they operate under membership systems based on members’ introductions and dual identification of new members, but these venues also have surveillance video systems to record and identify visiting police officers. Cover-up tricks such as software alterations that cover up their identities, pretend gamblers redeeming their point cards for cash, camouflaging their personal transactions, exchanging money, or remitting the monies won through gambling directly to the gambler’s bank account all make police officers’ detection more difficult. These companies even use local councilors to peddle their influence to reduce the risks of raids. They employ "standard-bearers" to monitor the movements of competent authorities and receive continuous reports on this. They also bribe police officers. Under pressure from these relations and the enticement of big profits, police officers may easily go astray. When investigating such matters, supervisors and inspectors shall take their time to plan, visit and supervise the discipline, including the following matters:
o Has the electronic gambling game venue repeatedly been reported but never been routinely monitored, inspected without notice, eradicated, or eradicated ineffectively, or sprang up again?
o Has there ever been timely cross-regional inspection or eradication? Has the inspection unit ever conducted multiple visits?
o What is the discipline status of the inspections without notice? Have there been any violations of the Regulation Governing Contact between Police Officers and Specific Persons?
o Is confidentiality of investigation and eradication work duly observed? Are there any suspicious persons following the itinerary during the investigation?
o Are there any influential people involved in the eradication process? Is this reported to the higher level or recorded in writing?
o Is the investigation process complete? Is somebody else taking the blame for a suspect?
o Are there complete audio and visual recordings of interviews with criminal suspects and important witnesses? Or, if necessary, have surveillance tapes of illegal venues been accessed and inspected?
o Have supervisors and investigators reviewed the investigations or transferred documents?
o Is there any bias in the discharge of duties? Has there been any abuse of power?
o Are seized assets handled in accordance with regulations?
o Have cases where eradication has strangely failed been proactively reviewed to ascertain any unlawful matters such as leaking or shielding by officers involved in investigations?
o Have inspections of the computer records of police officers involved in investigations yielded any anomalies? Have any other preventive actions such as monitoring and recording been taken?
In this case, the prosecutor found during the investigation process that most of police officers do their jobs faithfully, abide by their statutory police duties, do not fall for the temptation of bribery, do not give in to pressure from superiors, and insist on investigating the gambling cases in accordance with the law. The dedication of the police force to doing their duty and to get rid of external hazards to police discipline was palpable to the prosecutor.
Agency Against Corruption offers the above review, policy, and suggestions to the public and the police for their review in order to establish a good image of a police force that operates in accordance with the law and with integrity.