Return to Article Details INTERPOL: A Primer
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INTERPOL: A Primer

Felix LoStracco

Introduction

Since its formation, the International Criminal Police Organization (Interpol) has remained steadfast in its mission and objectives.  Interpol has always been a non-governmental organization that promotes law enforcement cooperation and intelligence sharing among member countries.  Interpol does not have authority to investigate violations of law, and it does not intervene in activities of a political, military, religious, or racial character.  In the post-9/11 environment, law enforcement agencies from across the globe have come to increasingly rely on Interpol as a repository of intelligence.  Interpol is able to succeed as an organization in part because of its relatively narrow focus.  The organization is able to avoid the significant political and ideological differences between member countries, such as between the United States and China, by having a single goal of combating crime.

Brief History and Organizational Structure

Interpol was created in part to respond to the need to combat criminals who were crossing country borders to evade capture and prosecution.  In 1923, 14 European countries created the International Criminal Police Commission (ICPC) to share intelligence.  The ICPC was an organization created to support law enforcement in member countries; the ICPC was not intended to be an agency that enforced laws.  The ICPC created a reporting structure where each of the member counties would have a single point of contact for all of its law enforcement agencies.  Each country was then responsible for disseminating intelligence to its own agencies as it deemed appropriate.  ICPC placed special attention on sharing criminal records and information on counterfeit currency and travel documents

The US did not join the ICPC until 1938.  The Federal Bureau of Investigation (FBI) was designated as the central point of contact in the US for the ICPC.  Shortly after the US joined the ICPC, Adolf Hitler’s Nazi regime annexed Austria, the country where the ICPC was headquartered.  Hitler’s Gestapo, the organization charged with investigating “all tendencies dangerous to the State,” took control of the ICPC.  Most countries ceased membership in the Gestapo-controlled ICPC.

Following the conclusion of World War II, the countries who were former members of the ICPC resurrected the organization and renamed it Interpol.   A new headquarters was set up in Paris, France.  The rules of governance for Interpol were established, and most of those policies and procedures are still followed today. 

Interpol is governed by a General Assembly that meets annually to decide on policy.  Each member country appoints a delegate to the General Assembly; each delegate’s vote is weighted equally.  Once decisions are made by the General Assembly, an Executive Committee implements the decisions.  The Executive Committee is comprised of 13 positions:  one president, three vice-presidents, and nine delegates.  The General Assembly elects personnel to sit on the Executive Committee.  The president serves a four-year term, and the vice-president serves a three-year term.  Each member of the Executive Committee is expected to represent the interests of their region, not just their country.

Interpol’s full-time chief executive is the Secretary General, who serves a five-year term.  Since 1989, the Secretary General is located at Interpol’s headquarters in Lyon, France.  The Executive Committee nominates a candidate for Secretary General and the General Assembly confirms the candidate by a two-thirds majority.  The current Secretary General is Ronald K. Noble, who formerly was the chief law enforcement officer at the US Department of the Treasury.  Noble is the first Secretary General from the US.

In addition to its headquarters, also known as the General Secretariat, Interpol has five regional bureaus—Abidjan, Cote D’ Ivoire; Buenos Aires, Argentina; Harare, Zimbabwe; Nairobi, Kenya; and San Salvador, El Salvador.  Although the five regional bureaus are geographically clustered, their responsibilities are spread to cover each member country.  Each member country maintains its own National Central Bureau (NCB) and staffs it with its own law enforcement officers.  While Interpol does not have any authority to enforce laws, the law enforcement officers working out of each country’s NCB is where Interpol’s intelligence can be implemented into action.  The NCB in the US, managed jointly by the Department of Justice and the Department of Homeland Security, is located in Washington DC.  The major functions of the NCB in the US are to[1]:

  1. Transmit information of a criminal justice, humanitarian, or other law enforcement related nature between NCBs and the law enforcement agencies of the US,
  2. Respond to requests by law enforcement agencies, legitimate organizations, institutions, and individuals when in agreement with the Interpol constitution, and
  3.   Coordinate and integrate information for investigations of an international nature and identify those involving patterns and trends of criminal activities

Participating agencies include the FBI, the US Marshals Service, US Fish and Wildlife Service, US Secret Service, US Postal Inspections Service, Environmental Protection Agency, the Department of Agriculture, and the Food and Drug Administration.

In 1984, China joined Interpol; its NCB is located in Beijing.  Zhu Entao, Assistant Minister of Public Security and I-Class Police Commissioner is director of the NCB in China.  By the beginning of 2007, Interpol had 186 member countries, which are listed in table 1.  As the table indicates, diplomatic relations do not exist between many of the countries.  By design, Interpol does not intervene in a country’s political, military, religious, or racial issues.  Interpol’s relatively narrow focus—to assist in international police co-operation—allows the organization to function effectively where bodies with broader goals are paralyzed with inaction.  The table also indicates that countries historically known for their inability to police its laws, countries that have widespread corruption in their law enforcement, and countries that use law enforcement for political ends are allowed to join Interpol.


Table 1. Interpol’s 186 Member Countries (as of 06/01/2007)[2]
Afghanistan Albania Algeria Andorra
Angola Antigua Argentina Armenia
Aruba Australia Austria Azerbaijan
Bahamas Bahrain Bangladesh Barbados
Belarus Belgium Belize Benin
Bhutan Bolivia Bosnia - Herzegovina Botswana
Brazil Brunei Bulgaria Burkina - Faso
Burundi Cambodia Cameroon Canada
Cape Verde Central African Republic Chad Chile
Colombia Comoros Congo Costa Rica
Côte d'Ivoire Croatia Cuba Cyprus
Czech Republic Denmark Democratic Republic of Congo Djibouti
Dominica Dominican Republic Ecuador Egypt
El Salvador Equatorial Guinea Eritrea Estonia
Ethiopia Fiji Finland France
Gabon Gambia Georgia Germany
Ghana Greece Grenada Guatemala
Guinea Guinea Bissau Guyana Haiti
Honduras Hungary Iceland India
Indonesia Iran Iraq Ireland
Israel Italy Jamaica Japan
Jordan Kazakhstan Kenya Korea
Kuwait Kyrgyzstan Laos Latvia
Lebanon Lesotho Liberia Libya
Liechtenstein Lithuania Luxembourg Madagascar
Malawi Malaysia Maldives Mali
Malta Marshall Islands Mauritania Mauritius
Mexico Moldova Monaco Mongolia
Montenegro Morocco Mozambique Myanmar
Namibia Nauru Nepal Netherlands
Netherlands Antilles New Zealand Nicaragua Niger
Nigeria Norway Oman Pakistan
Panama Papua New Guinea Paraguay People's Republic of China
Peru Philippines Poland Portugal
Qatar Republic of Macedonia Romania Russia
Rwanda St. Kitts St. Lucia St. Vincent
San Marino Sao Tome Saudi Arabia Senegal
Serbia Seychelles Sierra Leone Singapore
 
Table 1. Interpol’s 186 Member Countries (as of 06/01/2007)[2]
Afghanistan Albania Algeria Andorra
Angola Antigua Argentina Armenia
Aruba Australia Austria Azerbaijan
Bahamas Bahrain Bangladesh Barbados
Belarus Belgium Belize Benin
Bhutan Bolivia Bosnia - Herzegovina Botswana
Brazil Brunei Bulgaria Burkina - Faso
Burundi Cambodia Cameroon Canada
Cape Verde Central African Republic Chad Chile
Colombia Comoros Congo Costa Rica
Côte d'Ivoire Croatia Cuba Cyprus
Czech Republic Denmark Democratic Republic of Congo Djibouti
Dominica Dominican Republic Ecuador Egypt
El Salvador Equatorial Guinea Eritrea Estonia
Ethiopia Fiji Finland France
Gabon Gambia Georgia Germany
Ghana Greece Grenada Guatemala
Guinea Guinea Bissau Guyana Haiti
Honduras Hungary Iceland India
Indonesia Iran Iraq Ireland
Israel Italy Jamaica Japan
Jordan Kazakhstan Kenya Korea
Kuwait Kyrgyzstan Laos Latvia
Lebanon Lesotho Liberia Libya
Liechtenstein Lithuania Luxembourg Madagascar
Malawi Malaysia Maldives Mali
Malta Marshall Islands Mauritania Mauritius
Mexico Moldova Monaco Mongolia
Montenegro Morocco Mozambique Myanmar
Namibia Nauru Nepal Netherlands
Netherlands Antilles New Zealand Nicaragua Niger
Nigeria Norway Oman Pakistan
Panama Papua New Guinea Paraguay People's Republic of China
Peru Philippines Poland Portugal
Qatar Republic of Macedonia Romania Russia
Rwanda St. Kitts St. Lucia St. Vincent
San Marino Sao Tome Saudi Arabia Senegal
Serbia Seychelles Sierra Leone Singapore
 
Table 1. Interpol’s 186 Member Countries (as of 06/01/2007)- -continued
Slovakia Slovenia Somalia South Africa
Spain Sri Lanka Sudan Suriname
Swaziland Sweden Switzerland Syria
Tajikistan Tanzania Thailand Timor - Leste
Togo Tonga Trinidad & Tobago Tunisia
Turkey Turkmenistan Uganda Ukraine
United Arab Emirates United Kingdom United States Uruguay
Uzbekistan Venezuela Vietnam Yemen
Zambia Zimbabwe
 

Core Functions

Communications:  Technological advances in the 1990s enabled Interpol to become an organization that can rapidly provide support to member countries.  In 1990, the X.400 communication system launched, enabling NCBs to send electronic messages to each other and to the General Secretariat.  Two years later, an automated search facility for remote searches of Interpol databases was introduced.  In 2003, Interpol launched a secure, web-based global communications system, known as I-24/7, which significantly improved access to Interpol’s databases and services.  Almost all member countries are connected to I-24/7, with the remaining handful of countries to be connected in the near future.  As the name of the system implies, urgent information can be accessed and disseminated around the clock.[3]

            Intelligence:  Interpol developed and maintains numerous databases, to include information on biometric data, stolen or lost identification documents, and wanted notices.  Each NCB controls what level of direct access, if any, to provide to law enforcement agencies within its borders.  Some chose to act as the single clearinghouse for all of its agencies.

                        Notices:  Interpol’s color-coded notice system alerts member countries of law enforcement information.  The Red Notice is probably Interpol’s most well-known function.  Red Notices are issued by the Secretariat General at the request of a member country, and distributed to all other member countries.  Red Notices provide descriptive information on wanted subjects and request a provisional arrest of that subject, pending extradition.  Although it is not an international arrest warrant, it is backed by a valid arrest warrant in the requesting member country.  Interpol’s Red Notice allows an arrest warrant from one country to be circulated, and potentially enforced, around the world.  In the US, law enforcement is prohibited from arresting subjects based solely on the issuance of a Red Notice[4]. Upon receipt of a Red Notice, the Office of International Affairs in the US Department of Justice must determine whether the requesting country has an outstanding arrest warrant that charges a crime which would be a felony if committed in the US and a valid extradition treaty exists between the US and the requesting country for the specified crime[5].

Interpol has other colored notices.  Yellow notices help locate missing persons, particularly minors.  Blue notices seek additional information about a subject’s identity or activities.  Black notices seek information on unidentified dead bodies or deceased people who have used an alias.  Green notices provide warnings about repeat offenders who may commit the same offense in another country.  Orange notices provide warnings about disguised weapons, parcel bombs, and other potentially dangerous material.  In 2005, Interpol created a United Nations Security Counsel Special Notice for subjects of UN sanctions against al-Qaida and the Taliban.

                        Biometrics:  Approximately 40 member countries provide DNA information to Interpol on known criminals.  Although biometric information is spread across several databases, it includes photographs, fingerprints, and DNA.  One search feature attempts to match evidence from different crime scenes or individuals across regions.  Interpol follows the FBI’s guidelines on the collection of biometric data, ensuring that data collected by member countries is of sufficient quality and in the proper format to be compatible.[6]

Stolen or lost travel documents:  Approximately 100 member countries provide information on lost or stolen travel documents.  More than twelve million documents are contained in this database, which can be searched by law enforcement at a country’s borders[7]. The database can assist in confirming the validity of suspect travel documents.  Interpol is in the process of taking this database one step further.  It is developing an image-based database that will enable a side-by-side comparison of valid and counterfeit travel documents.

Stolen vehicles:  This database currently has detailed information on approximately five million vehicles that have been reported stolen in over 100 member countries.  The makes of the most stolen vehicles are Toyota, Volkswagen, and Ford.  Approximately 25,000 cars are recovered annually based on searches of this database.[8]

Art and antiquities:  Interpol finds it difficult to measure the extent of the trade in stolen cultural objects because the theft may not be discovered until the object reaches a legitimate art sale, and countries send “very little information to Interpol” on this type of crime.  News media often carries stories on stolen art, such as when antiquities were raided from a museum in Iraq in 2003.  Nevertheless, information on approximately 30,000 pieces or art or antiquities that have been reported stolen is contained in Interpol’s database.[9]

Priority crime areas:  Interpol currently ranks fugitives, terrorism, drugs / organized crime, human trafficking, and financial / high tech crimes as its five priority areas.[10]

            Fugitives:  These criminals pose a continuing threat to the community.  They may be on the move and financing their unlawful flight by committing additional criminal acts.  International fugitive investigations—with the goal of apprehension and extradition—have been a part of Interpol’s core functions since its founding.  Interpol expanded this service to include collecting and disseminating “best practices” information.[11]

            Terrorism: Following the 09/11/2001 attacks, Interpol created a Fusion Task Force to identify membership in active terrorist groups; collect and share intelligence; and provide analytical support.  This approach is a departure from most of Interpol’s structure as this unit attempts to be predictive instead of reactive.[12]  It is one thing for a country to share the rap sheet of a known criminal; it a quite another to share sensitive intelligence.  In the US intelligence community, “need to know” is the mantra to compartmentalize information.  If domestic agencies are reluctant to share sensitive information with each other, how can they be expected to share it with countries that they do not have full diplomatic relations with?

Drugs / Organized Crime: Nearly every country listed in table one is impacted by some aspect of the drug trade or organized crime.  While most drugs are grown or produced in only a few countries, drug suppliers, dealers, smugglers, and users are prolific.  Interpol is able to assist in drug investigations by identifying common links that affect countries in a region.[13]

            Human trafficking: Interpol seeks to end the abuse and exploitation of women from developing countries and young children for financial gain.  There is a distinction between human trafficking and human smuggling.  The latter involves gaining illegal entry into a country for a non-citizen or non-resident.  The former involves exploiting the migrant, often for forced servitude and/or prostitution.  Organized crime is often involved in running human trafficking rings.

            Like the drug trade, there are many interdiction points where member countries can play a role in stopping human trafficking.  Countries can do a better job in preventing victims in being lured out of their home countries.  Countries where victims transit through can screen for trafficking indicators, such as individuals crossing borders with travel documents belonging to other persons or without travel documents.  The types of travel documents that individuals have attempted to use for the purpose of human trafficking needs to be disseminated so member countries can be on the lookout for these documents.  Countries where victims ultimately end up can tighten their borders, stiffen their penalties, and/or punish those that enable the trade to continue.[14]

Financial / high tech crimes: This category includes computer intrusion, credit card fraud, currency counterfeiting, intellectual property violations, and money laundering.  Spammers or hackers can impact millions of computer users in an instant, and can be located anywhere there is an internet connection.  Criminals adapt their tactics to evade prosecutions; financial scams that had previously been operated in a single country now cross multiple borders.  With the following three frauds, the subjects are able to cast a wide enough net that know they will catch some victims.  While the schemes sound overly unbelievable as to question how anyone could become a victim, annual losses for these schemes run into the several millions of dollars.

Budget

            Interpol is mainly funded by its member countries.  To assess the level of each member country’s annual contribution, Interpol uses a formula based on the “economic well being” of the country.  The formula has the wealthiest nations paying an increasing share of the total budget.  The US contributes approximately 14 percent of the total;[18] China contributes less than two percent.  Interpol’s total budget is approximately €42 million (roughly $56 million).[19]   Roughly half of that total is spent on compensation; the remainder is for travel and conferences, followed by telecommunications.  That total, however, does not reflect the true breadth of Interpol.  Each NCB is staffed with law enforcement officers who are assigned to that location on temporary duty.  While at the NCB, their compensation is paid by their agency or department, not Interpol.

Compatibility with the National Crime Information Center (NCIC)

            NCIC is another computerized database of documented criminal information.  This database is available to nearly every law enforcement officer—from state and local police to federal agents—in the US.  When NCIC was established in 1967, its original mission was to assist law enforcement in locating stolen property and apprehending fugitives.  Similar to Interpol but on a national level, NCIC is an intelligence sharing tool for law enforcement.  On an average day, NCIC, which contains over 50 million records, is queried over 4.6 million times.  One set of NCIC’s records is the foreign fugitive file, which contains information on subjects wanted in foreign jurisdictions.  If the NCB in the US determines that the Red Notice is valid and one that the US will enforce, it enters the information on the wanted subject into this database.[20]

In early 2007, Christian Steven Ponce was pulled over in a small town in New York for not wearing a seat belt.  The local police officer queried NCIC and saw that Ponce was a fugitive from Ecuador and a subject of a Red Notice.  Ponce was then arrested.  He is charged in Ecuador with killing a politician and two other men.[21]  This example shows the powerful force-multiplying impact that these databases can have—it is no longer the case that only a single agency or even a single country is seeking its fugitives.

Successes

            Terrorism

Egyptian-born Sheikh Abu Hamza al-Masri of the Finsbury Park Mosque in London is an extremist Islamic cleric who wanted to establish a training camp in southern Oregon to further his jihad recruiting program.  Al-Masri enlisted the assistance of Earnest James Ujaama, also known as Bilal Ahmed, Haroon Rashid Aswat, and Oussama Kassir.  Ujaama is an American-born Muslim convert.  Aswat is a citizen of the United Kingdom (UK) and Kassir is a citizen of Lebanon and Sweden.  The training camp was established to provide a place where Muslims could receive various types of training, including military-style training, prior to moving to Afghanistan.  The training would provide weapons familiarity so the men could immediately start fighting jihad upon arrival in Afghanistan, or pursue further training in Afghanistan.  According to the co-conspirators, the training camp location was chosen because of the “pro-militia and fire-arms state [of Oregon]” and the area looked “just like Afghanistan.”[22]

In 2002, Ujaama, who lived in Washington, was arrested for conspiring to provide material support to terrorism; he plead guilty the following year and agreed to cooperate with the government.[23]  Sealed indictments and arrest warrants were issued for Aswat and Kassir, both of whom had already left the US.  Red Notices were then issued for both men.  Aswat was located in Zambia and arrested based on the Red Notice.  He was deported to the UK, pending extradition to the US.[24]  Kassir was arrested in the Czech Republic, and the US is pursuing his extradition.[25]

            White collar crimes

Derrick Hubbard was a medical doctor in California.  He was involved in a scheme where he would prescribe medical supplies to “patients” even though the supplies were not medically necessary.  Hubbard had co-conspirators who would recruit Medicare beneficiaries and drive them to his office for free “milk” and other medical supplies.  He would perform a cursory examination of the recruited beneficiaries and then prescribe supplies and sometimes motorized wheelchairs.  Hubbard and his co-conspirators then billed Medicare for supplies that were not medically necessary, and also routinely over-billed Medicare by inflating the price of supplies that were delivered or for billing for supplies that were never delivered.  Approximately $24 million in fraudulent claims were submitted to Medicare.[26]

Hubbard moved from California to Georgia.  After he was indicted, Hubbard fled to South Africa.   A Red Notice was issued, Hubbard was arrested by South African police, and extradited to the US.  Hubbard is scheduled to go to trial in 2007.[27]

       

Differences

            In the early 1990s, the Chinese government banned the Falun Dafa Society, a group known as Falun Gong, for being an unregistered illegal organization that spreads superstitious and fallacious ideas to deceive the public and create disturbance.  By not applying for permits, the organization is charged with plotting and organizing gatherings and demonstrations to sabotage social stability. 

China issued an arrest warrant for the group’s founder and leader, Li Hongzhi, for disturbing the public order.  Li was born and raised in China, left the country in the late 1990s, and is now a permanent resident of the US.  The NCB in China sent a request to member countries seeking international cooperation in Hongzhi’s arrest.  China also requested the issuance of a Red Notice.  According to the US State Department, Interpol declined to issue a Red Notice.  Interpol’s Secretary General may have grounded his decision on Interpol’s founding principal to not intervene in a country’s political issues.  In this case, had a Red Notice been issued, the US would probably not arrest Hongzhi on China’s warrant because the US has no extradition treaty with China.[28]

Conclusion

            Interpol can only be as effective as the information provided to it by member countries.  The potential cost of one country withholding information if a crime occurs in another country or a crime goes unsolved.  If a country fills Interpol databases with information about subjects that are politically motivated, other countries have to attempt to sift through unnecessary noise in working their investigations.  While it is possible to be overwhelmed with information, connecting the dots becomes impossible when you only know about half of the dots.  By member countries improving the quality and quantity of information they provide to Interpol, they can significantly increase the organization’s effectiveness as other countries that need that information will have it available for the first time or have it more readily accessible. 

            By design, Interpol does not intervene in a country’s political, military, religious, or racial issues.  Interpol is able to bridge over these differences that member countries have by focusing only on international law enforcement co-operation.  Given the scope of law enforcement work, the inherent tensions between privacy of information and dissemination, and the varied laws in the different countries, Interpol is able to be as effective as it is.  The model of this organization should be adopted in other areas where single issues can bring together a diverse set of countries as listed in table 1.  Interpol has been able to succeed where other international organizations have been marred by debate and inactivity.



[1] United States Code Title 22, Section 263A

[2] Interpol member countries, http://www.interpol.int/Public/Icpo/Members/default.asp

[3] “Connecting police:  I-24/7,” Interpol Fact Sheet, COM/FS/2006-07/GI-03, http://www.interpol.int/Public/ICPO/FactSheets/GI03.pdf

[4] United States Attorneys’ Manual, Title 9, Criminal Resource Sections 613, 615, 616, and 620.

[5] United States Attorneys’ Manual, Title 9, Criminal Resource Section 614.

[6] Statement of ADIC Michael D. Kirkpatrick, Criminal Justice Information Division, Federal Bureau of Investigation, before the Senate Judiciary Committee, Subcommittee on Technology, Terrorism, and Government Information, November 14, 2001.

[7] “Databases,” Interpol Fact Sheet, COM/FS/2006-07/GI-04, http://www.interpol.int/Public/ICPO/FactSheets/GI04.pdf

[8] “Vehicle Crime,” Interpol, http://www.interpol.int/Public/Vehicle/Default.asp

[9] “Stolen Works of Art,” Interpol, http://www.interpol.int/Public/WorkOfArt/Default.asp

[10] http://www.interpol.int/default.asp

[11] “Fugitive Investigative Services,” Interpol, http://www.interpol.int/Public/Wanted/fugitiveInvestServ.asp

[12] “Public Safety and Terrorism,” Interpol, http://www.interpol.int/Public/Terrorism/default.asp

[13] “Drugs and Criminal Organizations,” Interpol, http://www.interpol.int/Public/Drugs/Default.asp

[14] “Trafficking in Human Beings,” Interpol Fact Sheet, COM/FS/2006-06/THB02, http://www.interpol.int/Public/ICPO/FactSheets/THB02.pdf

[15] “Advanced Fee Fraud: 4-1-9 letters (Nigerian letters),” Interpol, http://www.interpol.int/Public/FinancialCrime/FinancialFraud/NigerianLetter.asp

[16] Ibid

[17] Ibid

[18] US National Central Bureau, US Department of Justice, FY2008 Performance Budget, Congressional Submission.

[19] Interpol media release, “Interpol announces creation of global anti-crime centers.  Centers to provide unique support to law enforcement worldwide.,” December 11, 2006.

[20] Statement of Thomas E. Bush III, Assistant Director, Federal Bureau of Investigation, Criminal Justice Information Services Division, before the Senate Committee on Homeland Security and Governmental Affairs, “Pass[prt Information Sharing with Department of State,” June 29, 2005.

[21] “No seat belt leads to apprehension of Red Notice suspect,” Interpol, http://www.interpol.int/Public/News/2007/Rednotice20070207.asp

[22] United States of America versus Earnest James Ujaama, US District Court for the Western District of Washington, Seattle, Washington, Indictment.

[23] Statement of John S. Pistole, Executive Assistant Director, Federal Bureau of Investigation, Counterterrorism /Counterintelligence Division, Before the National Commission on Terrorist Attacks upon the United States, April 14, 2004.

[24] British Broadcasting Corporation, “Briton facing extradition to US ,” January 5, 2006, http://news.bbc.co.uk/2/hi/uk_news/4583520.stm

[25] Mike Carter, Seattle Times, “Islamic militant charged by feds,” December 14, 2005, http://seattletimes.nwsource.com/html/nationworld/2002682412_kassir14m.html

[26] Federal Bureau of Investigation, press release, “Four Guilty in $24 million Medicare Billing Scam,” August 29, 2006.

[27] Home Care, “Four Convicted in $24 Million Medicare Scheme,” April 24, 2006.

[28] British Broadcasting Corporation News, “World: Asia-Pacific, Sect Leader's Arrest Warrant Rejected, July 30, 1999.