HomeMy WebLinkAboutExhibit - MOUFOR OFFICIAL USE ONLY
FOR OFFICIAL USE ONLY
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FEDERAL BUREAU OF INVESTIGATION
CHILD EXPLOITATION TASK FORCE
MEMORANDUM OF UNDERSTANDING
PARTIES
1. This Memorandum of Understanding (MOU) is entered into by and between the
Federal Bureau of Investigation (FBI) and the City of Miami Police Department.
Nothing in this MOU should be construed as limiting or impeding the basic spirit of
cooperation which exists between these agencies.
AUTHORITIES
2. Authority for the FBI to enter into this agreement can be found at Title 28, United
States Code (U.S.C.), Section (§) 533; 42 U.S.C. § 3771; Title 28, Code of Federal
Regulations (C.F,R.), § 0.85; and applicable United States Attorney General's
Guidelines.
3. The purpose of this MOU is to delineate the responsibilities of the Child
Exploitation Task Force (CETF). CETF personnel formalize relationships between
participating agencies for policy guidance, planning, training, public and media.
relations; and maximize inter -agency cooperation. This MOU is not intended, and
should not be construed, to create any right or benefit, substantive or procedural,
enforceable at law or otherwise by any third party against the parties, the United
States, or the officers, employees, agents, or other associated personnel thereof.
MISSION
4. The mission of the CETF ultimately is to provide a rapid, proactive, and
intelligence -driven investigative response to the sexual victimization of children
and other crimes against children within the FBI's jurisdiction; to identify and
rescue child victims; to reduce the vulnerability of children to sexual exploitation
and abuse; to reduce the negative impact of domestic and international parental
rights disputes; and to strengthen the capabilities of the FBI and federal, state,
local, and international law enforcement through training, -intelligence-sharing,
technical support, and investigative assistance.
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The CETF will enhance the effectiveness of Federal/State/Local law enforcement
resources through a . well coordinated initiative seeking the most effective
investigative/prosecutive avenues by which to convict and incarcerate those
criminals that continue to present the greatest threat to the Miami area, The CETF
will continue to collaborate with other federal agencies, coordinate with
international partners, and cooperate with other FBI field divisions to increase
indictments, arrest warrants and convictions. To mitigate the threat posed to the
Miami AOR, the CETF will also focus on identifying methods of laundering criminal
proceeds when seizing assets, Task force personnel, under the direct supervision
of the designated FBI supervisor, will be used to address the task force priorities as
deemed necessary.
SUPERVISION AND CONTROL
A. Supervision
6. Overall management of the CETF shall be the shared responsibility of the
participating agency heads and/or their designees.
7. The Executive Management of the Miami Division shall designate one Supervisory
Special Agent (CETF Supervisor) to supervise the CETF. The CETF Supervisor
may designate a Special Agent to serve as the Child Exploitation Task Force
Coordinator (Task Force Coordinator). Either the CETF Supervisor or the Task
Force Coordinator shall oversee day-to-day operational and investigative matters
pertaining to the CETF.
8, Conduct undertaken outside the scope of an individual's CETF duties and
assignments under this MOU shall not fall within the oversight responsibility of the
CETF Supervisor or Task Force Coordinator. As stated in paragraph 74, below,
neither the United States nor the FBI shall be responsible for such conduct.
9. CETF personnel will be subject to the laws, regulations, policies, and personnel
rules applicable to their respective agencies. FBI employees will continue to
adhere to the Bureau's ethical standards, including Department of Justice
(DOJ)/FBI regulations relating to outside employment and prepublication review
matters, and will remain subject to the Supplemental Standards of Ethical conduct
for employees of the DOJ.
10, CETF personnel will continue to report to their respective agency heads for
non -investigative administrative matters not detailed in this MOU.
11. Continued assignment of personnel to the CETF will be based on performance
and at the discretion of appropriate management. Executive Management and the
CETF Supervisor will also retain discretion to remove any individual from the
CETF.
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B. Case Assignments
12. The FBI CETF Supervisor will be responsible for opening, monitoring, directing,
and closing CETF investigations in accordance with existing FBI policy and the
applicable United States Attorney General's Guidelines,
13. Assignments of cases to personnel will be based on, but not limited to, experience,
training and performance, in addition to the discretion of the CETF Supervisor,
14, For FBI administrative purposes, CETF cases will be entered into the relevant FBI
computer system.
15. CETF personnel will have equal, responsibility for each case assigned. CETF
personnel will be responsible for complete investigation from predication to
resolution.
C. Resource Control
16, The head of each participating agency shall determine the resources to be
dedicated by that agency to the CETF, including personnel, as well as the
continued dedication of those resources, The participating agency head or
designee shall be kept fully apprised of all investigative developments by his or her
subordinates.
OPERATIONS -
A. Investigative Exclusivity
17. It is agreed that matters designated to be handled by the CETF will not knowingly
be subject to non-CETF law enforcement efforts by any of the participating
agencies. It is incumbent on each agency to make proper internal notification
regarding the CETF's existence and areas of concern.
18. It is agreed that there is to be no unilateral action taken on the part of the FBI or any
participating agency relating to CETF investigations or areas of concern as
described in paragraph 3. All law enforcement actions will be coordinated and
cooperatively carried out.
19. CETF investigative leads outside of the geographic areas of responsibility for FBI
Miami Division will be communicated to other FBI offices for appropriate
investigation.
B. Confidential Human Sources
20. The disclosure of FBI informants, or Confidential Human Sources (CHSs), to
non-CETF personnel will be limited to those situations where it is essential to the
effective performance of the CETF. These disclosures will be consistent with
applicable FBI guidelines.
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21, Non -FBI CETF personnel may not make any further disclosure of the identity of an
FBI CHS, including to other individuals assigned to the CETF. No documents
which identify, tend to identify, or may indirectly identify an FBI CHS may be
released without prior FBI approval.
22, In those instances where a participating agency provides a CHS, the FBI may, at
the discretion of Executive Management, become solely responsible for the CHS's
continued development, operation, and compliance with necessary administrative
procedures regarding operation and payment as set forth by the FBI.
23. The United States Attorney General's Guidelines and FBI policy and procedure for
operating FBI CHSs shall apply to all FBI CHSs opened and operated in
furtherance of CETF investigations. Documentation of, and any payments made
to, FBI CHSs shall be in accordance with FBI policy and procedure.
24. Operation, documentation, and payment of any CHS opened and operated in
furtherance of a CETF investigation must be in accordance with the United States
Attorney General's Guidelines, regardless of whether the handling agency is an
FBI CETF participating agency. Documentation of state, county, or local CHSs
opened and operated in furtherance of CETF investigations shall be maintained at
an agreed upon location.
C. Reports and Records
25. All investigative reporting will be prepared in compliance with existing FBI policy.
Subject to pertinent legal and/or policy restrictions, copies of pertinent documents
created by CETF personnel will be made available for inclusion in the respective
investigative agencies' files as appropriate.
26, CETF reports prepared in cases assigned to CETF personnel will be maintained at
an FBI approved location; original documents will be maintained by the FBI.
27. Records and reports generated in CETF cases which are opened and assigned by
the FBI SSA with designated oversight for investigative and personnel matters will
be maintained in the FBI investigative file for CETF.
28. CETF investigative records maintained at the Miami Field Office of the FBI will be
available to all CETF personnel, as well as their supervisory and command staff
subject to pertinent legal, administrative and/or policy restrictions.
29. All evidence and original recordings (audio and video) acquired by the FBI during
the course of the CETF investigations will be maintained by the FBI, The FBI's
rules and policies governing the submission, retrieval and chain of custody will be
adhered to by CETF personnel.
30. All CETF investigative records will be maintained .at an approved FBI location.
Placement of all or part of said information into participating agency files rests with
the discretion of supervisory personnel of the concerned agencies, subject to SSA
approval.
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31, Classified information and/or documents containing information that identifies or
tends to identify an FBI CHS shall not be placed in the files of participating
agencies unless appropriate FBI policy has been satisfied.
32. The Parties acknowledge that this MOU may provide CETF personnel with access
to information about U.S, persons which is protected by the Privacy Act of 1974
and/or Executive Order 12333, The Parties expressly agree that all such
information will be handled lawfully pursuant to the provisions thereof. The Parties
further agree that if this access to information by CETF personnel requires a
change in privacy compliance documents, those changes will be accomplished
prior to access being granted.
INFORMATION SHARING
33, No information possessed by the FBI, to include information derived from informal
communications between CETF personnel and FBI employees not assigned to the
CETF, may be disseminated by CETF personnel to non-CETF personnel without
the approval of the CETF Supervisor and in accordance with the applicable laws
and internal regulations, procedures or agreements between the FBI and the
participating agencies that would permit the participating agencies to receive that
information directly. Likewise, CETF personnel will not provide any participating
agency information to the FBI that is not otherwise available to it unless authorized
by appropriate participating agency officials,
34, Each Party that discloses Personal Identifiable Information (PII) is responsible for
making reasonable efforts to ensure that the information disclosed is accurate,
complete, timely, and relevant.
35, The FBI is providing access to information from its records with the understanding
that in the event the recipient becomes aware of any inaccuracies in the data, the
recipient will promptly notify the FBI so that corrective action can be taken,
Similarly, if the FBI becomes aware that information it has received pursuant to this
MOU is inaccurate, it will notify the contributing Party so that corrective action can
be taken,
36, Each Party is responsible for ensuring that information it discloses was not
knowingly obtained or maintained in violation of any law or policy applicable to the
disclosing Party, and that information is only made available to the receiving Party
as may be permitted by laws, regulations, policies, or procedures applicable to the
disclosing Party.
37, Each Party will immediately report to the other Party each instance in which data
received from the other Party is used, disclosed, or accessed in an unauthorized
manner (including any data losses or breaches).
38, The Parties agree that either or both may audit the handling and maintenance of
data in electronic and paper recordkeeping systems to ensure that appropriate
security and privacy protections are in place.
PROSECUTIONS
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39. CETF investigative procedures, whenever practicable, are to conform to the
requirements which would allow for either federal or state prosecution.
40. A determination will be made on a case-by-case basis whether the prosecution of
CETF cases will be at the state or federal Level. This determination will be based
on the evidence obtained and a consideration of which level of prosecution would
be of the greatest benefit to the overall objectives of the CETF.
41. In the event that a state or local matter is developed that is outside the jurisdiction
of the FBI or it is decided to prosecute a CETF case at the state or local level, the
FBI agrees to provide all relevant information to state and local authorities in
accordance with all applicable legal limitations.
A. Investigative Methods/Evidence
42. For cases assigned to an FBI Special Agent or in which FBI CHSs are utilized, the
parties agree to conform to federal standards concerning evidence collection,
processing, storage, and electronic surveillance. However, in situations where the
investigation will be prosecuted in the State Court where statutory or common law
of the state is more restrictive than the comparable federal law, the investigative
methods employed by FBI case agents shall conform to the requirements of such
statutory or common law pending a decision as to venue for prosecution.
43. In all cases assigned to state, county, or local law enforcement participants, the
parties agree to utilize federal standards pertaining to evidence handling and
electronic surveillance activities as outlined in the Domestic Investigations and
Operations Guide to the greatest extent possible. However, in situations where
the statutory or common law of the state is more restrictive than the comparable
federal law, the investigative methods employed by state and local law
enforcement agencies shall conform to the requirements of such statutory or
common law pending a decision as to venue for prosecution.
44. The use of other investigative methods (search warrants, interceptions of oral
communications, etc.) and reporting procedures in connection therewith will be
consistent with the policies and procedures of the FBI.
B. Undercover Operations
45, All CETF undercover operations will be conducted and reviewed in accordance
with FBI guidelines and the Attorney General's Guidelines on Federal Bureau of
Investigation Undercover Operations. All participating agencies may be requested
to enter into an additional agreement if an employee of the participating agency is
assigned duties which require the officer to act in an undercover capacity.
USE OF LESS -THAN -LETHAL-DEVICES1
1 Pursuant to Section VIII of the DOJ Less -Than -Lethal Devices Policy dated May 16, 2011, all state/local
officers participating in joint task force operations must be made aware of and adhere to the policy and its limits on DOJ
officers.
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46. The parent agency of each individual assigned to the CETF will ensure that while
the individual is participating in FBI -led task force operations in the capacity of a
task force officer, task force member, or task force participant, the individual will
carry only less -lethal devices that the parent agency has issued to the individual,
and that the individual has been trained in accordance with the agency's policies
and procedures.
47. The parent agency of each individual assigned to the CETF will ensure that the
agency's policies and procedures for use of any less -lethal device that will be
carried by the task force officer, task force member, or task force participant are
consistent with the DOJ policy statement on the Use of Less -Than -Lethal Devices.
DEADLY FORCE AND SHOOTING INCIDENT POLICIES
48. CETF personnel will follow their own agencies' policies concerning firearms
discharge and use of deadly force.
DEPUTATIONS
49. Local and state law enforcement personnel designated to the CETF, subject to a
limited background inquiry, may be sworn as federally deputized Special Deputy
United States Marshals, with the FBI securing the required deputation
authorization, These deputations should remain in effect throughout the tenure of
each investigator's assignment to the CETF or until the termination of the CETF,
whichever comes first.
50, Deputized CETF personnel will be subject to the rules and regulations pertaining
to such deputation. Administrative and personnel policies imposed by the
participating agencies will not be voided by deputation of their respective
personnel.
VEHICLES
51. In furtherance of this MOU, employees of the City of Miami Police Department may
be permitted to drive FBI owned or leased vehicles for official CETF business and
only in accordance with applicable FBI rules and regulations, including those
outlined in the FBI Government Vehicle Policy Directive (0430D) and the
Government Vehicle Policy Implementation Guide (0430PG). The assignment of
an FBI owned or leased vehicle to CETF personnel will require the execution of a
separate Vehicle Use Agreement.
52. The participating agencies agree that FBI vehicles will not be used to transport
passengers unrelated to CETF business.
53. The FBI and the United States will not be responsible for any tortious act or
omission on the part of the City of Miami Police Department and/or its employees
or for any liability resulting from the use of an FBI owned or leased vehicle utilized
by City of Miami Police Department CETF personnel, except where liability may fall
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under the provisions of the Federal Tort Claims Act (FTCA), as discussed in the
Liability Section herein below.
54. The FBI and the United States shall not be responsible for any civil Liability arising
from the use of an FBI owned or leased vehicle by the City of Miami Police
Department CETF personnel while engaged in any conduct other than their official
duties and assignments under this MOU.
55. To the extent permitted by applicable law, the City of Miami Police Department
agrees to hold harmless the FBI and the United States, for any claim for property
damage or personal injury arising from any use of an FBI owned or leased vehicle
by City of Miami Police Department CETF personnel which is outside the scope of
their official duties and assignments under this MOU.
SALARY/OVERTIME COMPENSATION
56. The FBI and the City of Miami Police Department remain responsible for all
personnel costs for their CETF representatives, including salaries, overtime
payments and fringe benefits consistent with their respective agency, except as
described in paragraph 57 below,
57. Subject to funding availability and legislative authorization, the FBI will reimburse
to the City of Miami Police Department the cost of overtime worked by non-federal
CETF personnel assigned full-time to CETF, provided overtime expenses were
incurred as a result of CETF-related duties, and subject to the provisions and
limitations- set forth in a separate Cost Reimbursement Agreement to be executed
in conjunction with this MOU. A separate Cost Reimbursement Agreement must
be executed between the FBI and the City of Miami Police Department for full-time
employee(s) assigned to CETF, consistent with regulations and policy, prior to any
reimbursement by the FBI. Otherwise, overtime shall be compensated in
accordance with applicable City of Miami Police Department overtime provisions
and shall be subject to the prior approval of appropriate personnel.
PROPERTY AND EQUIPMENT
58. Property utilized by the CETF in connection with authorized investigations and/or
operations and in the custody and control and used at the direction of the CETF,
will be maintained in accordance with the policies and procedures of the agency
supplying the equipment. Property damaged or destroyed which was utilized by
CETF in connection with authorized investigations and/or operations and is in the
custody and control and used at the direction of CETF, will be the financial
responsibility of the agency supplying said property,
.FUNDING
59, This MOU is not an obligation or commitment of funds, nor a basis for transfer of
funds, but rather is a basic statement of the understanding between the parties
hereto of the tasks and methods for performing the tasks described herein. Unless
otherwise agreed in writing, each party shall bear its own costs in relation to this
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MOU. Expenditures by each party will be subject to its budgetary processes and to
the availability of funds and resources pursuant to applicable laws, regulations,
and policies. The parties expressly acknowledge that the above language in no
way implies that Congress will appropriate funds for such expenditures,
FORFEITURES
60. The FBI shall be responsible for processing assets seized for federal forfeiture in
conjunction with CETF operations.
61. Asset forfeitures will be conducted in accordance with federal law, and the rules
and regulations set forth by the FBI and DOJ. Forfeitures attributable to CETF
investigations may be equitably shared with the agencies participating in the
CETF,
DISPUTE RESOLUTION
62. In cases of overlapping jurisdiction, the participating agencies agree to.work in
concert to achieve the CETF's objectives.
63. The participating agencies agree to attempt to resolve any disputes regarding
jurisdiction, case assignments, workload,- etc., at the field level first before referring
the matter to supervisory personnel for resolution.
MEDIA RELEASES
64. All media releases and statements will be mutually agreed upon and jointly
handled according to FBI and participating agency guidelines.
65, Press releases will conform to DOJ Guidelines regarding press releases. No
release will be issued without FBI final approval.
SELECTION TO CETF AND SECURITY CLEARANCES
66. If a City of Miami Police Department candidate for the CETF will require a security
clearance, he or she will be contacted by FBI security personnel to begin the
background investigation process prior to the assigned start date.
67. If, for any reason, the FBI determines that a City of Miami Police Department
candidate is not qualified or eligible to serve on the CETF, the participating agency
will be so advised and a request will be made for another candidate.
68. Upon being selected, each candidate will receive a comprehensive briefing on FBI
field office security policies and procedures. During the briefing, each candidate
will execute non -disclosure agreements (SF -312 and FD -868), as may be
necessary or required by the FBI
69. Before receiving unescorted access to FBI space identified as an open storage
facility, CETF personnel will be required to obtain and maintain a "Top Secret"
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security clearance. CETF personnel will not be allowed unescorted access to FBI
space unless they have received a Top Secret security clearance.
70. Upon departure from the CETF, each individual whose assignment to the CETF is
completed will be given a security debriefing and reminded of the provisions
contained in the non -disclosure agreement to which he or she previously agreed.
LIABILITY
71. The participating agencies acknowledge that this MOU does not alter the
applicable law governing civil liability, if any, arising from the conduct of personnel
assigned to the CETF.
72. The participating agency shall immediately notify the FBI of any civil,
administrative, or criminal claim, complaint, discovery request, or other request for
information of which the agency receives notice, concerning or arising from the
conduct of personnel assigned to the CETF or otherwise relating to the CETF. The
participating agency acknowledges that financial and civil liability, if any and in
accordance with applicable law, for the acts and omissions of each employee
detailed to the CETF remains vested with his or her employing agency. In the
event that a civil claim or complaint is brought against a state or local officer
assigned to the CETF, the officer may request legal representation and/or defense
by DOJ, under the circumstances and pursuant to the statutes and regulations
identified below,
73. For the limited purpose of defending against a civil claim arising from alleged
negligent or wrongful conduct under common law under the FTCA, 28 U.S.C. §
1346(b), and §§ 2671-2680: An individual assigned to the CETF who is named as
a defendant in a civil action. as a result of or in connection with the performance of
his or her official duties and assignments pursuant to this MOU may request to be
certified by the Attorney General or his designee as having acted within the scope
of federal employment at the time of the incident giving rise to the suit. 28 U,S.C.. §
2679(d)(2). Upon such certification, the individual will be considered an
"employee" of the United States government for the limited purpose of defending
the civil claim under the FTCA, and the claim will proceed against the United
States as sole defendant. 28 U.S.C. § 2679(d)(2). Once an individual is certified
as an employee of the United States for purposes of the FTCA, the United States is
substituted for the employee as the sole defendant with respect to any tort claims.
Decisions regarding certification of employment under the FTCA are made on a
case-by-case basis, and the FBI cannot guarantee such certification to any CETF
personnel.
74, For the limited purpose of defending against a civil claim arising from an alleged
violation of the U.S. Constitution pursuant to 42 U.S.C. § 1983 or Bivens v, Six
Unknown Named Agents of the Federal Bureau of Narcotics, 403 U,S. 388 (1971):
An individual assigned to the CETF who is named as a defendant in a.civil action
as a result of or in connection with the performance of his or her official duties and
assignments pursuant to this MOU may request individual -capacity representation
by DOJ to defend against the claims. 28 C.F,R. §§ 50.15, 50,16. Any such
request for individual -capacity representation must be made in the form of a letter
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from the individual defendant to the U,S. Attorney General. The letter should be
provided to Chief Division Counsel (CDC) for the FBI Miami Division, who will then
coordinate the request with the FBI Office of the General Counsel, In the event of
an adverse judgment against the individual, he or she may request indemnification
from DOJ. 28 C,F.R. § 50.15(c)(4). Requests for DOJ representation and
indemnification are determined by DOJ on a case-by-case basis. The FBI cannot
guarantee the United States will provide legal representation or indemnification to
any CETF personnel.
75. Liability for any conduct by CETF personnel undertaken outside of the scope of
their assigned duties and responsibilities under this MOU shall not be the
responsibility of the FBI or the United States and shall be the sole responsibility of
the respective employee and/or agency involved.
DURATION
76. The term of this MOU is for the duration of the CETF's operations, contingent upon
approval of necessary funding, but may be terminated at any time upon written
mutual consent of the agency involved.
77, Any participating agency may withdraw from the CETF at any time by written
notification to the SSA with designated oversight for investigative and personnel
matters or program manager of the CETF at least 80 days prior to withdrawal.
78. Upon termination of this MOU, all equipment provided to the CETF will be returned
to the supplying agency/agencies. In addition, when an entity withdraws from the
MOU, the entity will return equipment to the supplying agency/agencies. Similarly,
remaining agencies will return to a withdrawing agency any unexpended
equipment supplied by the withdrawing agency during any CETF participation.
MODIFICATIONS
79, This agreement may be modified at any time by written consent of all involved
agencies.
80. Modifications to this MOU shall have no force and effect unless such modifications
are reduced to writing and signed by an authorized representative of each
participating agency.
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SIGNATORIES
George L. Piro
Special Agent in Charge Date
Federal Bureau of Investigation
Rodolfo Llanes
Chief Date
City of Miami Police Department
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Federal Bureau of Investigation
Memorandum of Understanding
Child Exploitation Task Force
CITY OF MIAMI, a Florida Municipal Corporation
Daniel J. Alfonso, City Manager
Attest:
1-2
Todd B. Hannon, City Clerk
Approved as to Form and Correctness:
Victoria Mendez, City Attorney
Approved as to Insurance Requirements:
.0
Ann -Marie Sharpe, Director of
Risk Management
Date:
Date:
Date:
Date: