Multi-Jurisdictional Concealed Asset Recovery Investigations – A Blueprint -

Introduction

In general, the prosecution of a multi-jurisdictional concealed asset recovery investigation involves both extra-judicial and judicially assisted investigative procedures. The former concentrate on cross-border evidence and intelligence collection activities, using both covert and overt techniques, and the forensic analysis of documents and information. The latter focus on obtaining information and evidence through the use of secret, ex parte discovery or confidential document disclosure orders.

The deconstruction of complex asset protection devices used by professional money launderers and their facilitators requires the employment of a detailed planning process that takes into account the personality and modus operandi of the primary obligor. A proposed investigation and asset recovery process can be organized into three distinct yet overlapping phases. At the end of each phase, a decision point is reached that requires an assessment of the work accomplished to date and the rendering of decisions with respect to how the matter should progress. Thus, the results achieved at the end of each phase provide both stimuli for any necessary changes to the operational objectives and building blocks for the prosecution of the next phase.

A strong commitment to strategic and tactical planning is of paramount importance in any asset recovery exercise. The strategic plan is a highway to attaining the overarching goal of bringing meaningful remedies to the victim of fraud by discovering, preserving and recovering concealed value from the primary target or obligor.

The goals and objectives that are established in strategic and tactical plans must be realistic and attainable so as to allow the members of the concealed asset recovery team - investigative, analytical and legal - to think strategically and act operationally. Equally, a tactical plan of investigation is a virtual necessity for the efficient and cost-effective conduct of an asset recovery investigation. The strategic plan ought to be visionary, conceptual and directional. In contrast, the investigative plan will be an operational model that is tactical, focused, implementable and measurable.

Preparing the Model

Any model for a multi-jurisdictional concealed asset recovery investigation should be case specific, and designed from the bottom up to serve as a framework for management decisions and for securing approval from clients as appropriate. The investigative plan should be a 'nuts and bolts' guide to the realization of the strategic, overarching goal, as well as a basis for benchmarking and performance monitoring. Equally, it should provide a platform for more detailed, tactical planning (or for situational planning within a plan). While planning does not guarantee success, to proceed without it is an invitation to failure.

One of the most important considerations in preparing an outline plan of investigation and recovery is the management of risk with respect to both operational considerations and budgetary discipline. The benefit of breaking an inquiry into phases helps to establish signposts and decision points that aid decision makers in their efforts to quantify and manage risk. The downside risk that is attached to continuing a concealed asset investigation can be weighed against the progress that has been made and the assets that have been identified, up to that point in time. The costs associated with the process are incurred incrementally. Thus, as more resources are committed, the risk of a complete failure in the investigation typically declines.

The phased structure of an investigative plan encourages the service provider and client to revisit critical assumptions at certain strategic points, so that objective decisions can be made about going forward with the work.

Investigation - Forward and Reverse Tracing

For the most part, any asset recovery exercise will be best launched by conducting a preliminary investigation with the view to building a model or plan to locate, define the manner of holding, preserve and recover substantial value that has been concealed by means of complex money laundering typologies. In general, the preferred method is to build a model slowly, from the bottom up using the classic intelligence cycle of direction, collection, processing and dissemination. Multi-source, multi-level intelligence, procured according to key principles, and advanced analytical techniques should be used to drill down to the detail and highlight crucial issues and individuals as soon as possible. By proceeding in such a manner, it is possible to maximize efficiency and deploy the client's resources optimally.

The management of risk is a primary consideration, and in this regard it is important to take steps to preserve the operational security of work proposed or carried out. Such steps might include source protection and communication security as part of case management and reporting. The importance of thorough planning, and a coordinated and harmonized approach to analyzing the available facts, cannot be overstated. A dual-pronged approach is advocated, with both 'forward' and 'reverse' traces being run concurrently.

The traditional asset tracing method follows the movement of misappropriated value in the forward direction, from the scene of the crime, and by means of an overt investigation or through inter partes discovery litigation. Conducting a forward trace using traditional, non-confidential methods is usually ineffectual. It allows the dishonest obligor to observe the progress being made by the investigators as they travel along the value chain, and to gauge how close the investigation is to discovering the location(s) and manner of holding of the concealed assets. As a result, the illusive, hidden value may continue to move, remaining several steps ahead of the tracing exercise. In contrast, the employment of a non-traditional approach when conducting both forward and reverse asset traces presents the benefit of inverting the paradigm and operating in an ex parte, or secret, investigative environment.

The reverse asset tracing method follows the trail of funds (or concealed value) in the direction opposite to its actual movement - that is, it tracks wealth from the point of consumption, or the exercise of dominion or control over concealed assets, back into the laundering and protection of value system, in the direction of its origin. By starting with the obligor's visible, if confidential, symbols of wealth (eg, expensive travel, schooling for children, homes and vehicles), or by seizing computers and documents through the execution of an ex parte civil search order, the reverse trace can lead to both assets that derive from the misappropriated funds and value that cannot be identified as the proceeds of any specific wrongful acts, but which nevertheless may be recovered in a civil asset forfeiture proceeding. Reverse tracing, like forward tracing, is best accomplished by employing secret investigative methods up to a point, such as sealed ex parte proceedings protected by anti-tip off orders, which will ensure that the dishonest obligor is not given advance notice of the investigation's direction and status. Typically, the combined effect of using both tracing methods together produces greater synergy than would be achieved by using either method independently. Moreover, using both methods increases the speed of the process and the likelihood of success.

A well executed, dual-directional tracing inquiry ordinarily reveals facts relevant to a parallel plan of third-party investigation and litigation, inasmuch as evidence material to previously unknown third-party obligors or facilitators may be secured when tracing the value chain. The two strands of work overlap and interact, in varying degrees and at various points in the investigative and analytical process. For instance, by its nature, tracing will inevitably identify a string of yet unknown, well-capitalized recipients of funds impressed with a constructive trust. If it can be determined that one or more of such recipients had actual knowledge of the fraudulent manner in which the funds were generated, then they become primary candidates for a third-party or accessory civil liability suit.

Phase one of any tracing investigation should involve a reasonably comprehensive preliminary inquiry to uncover facts and information that will: (i) form the building blocks necessary for the successful planning and conduct of phase two of the tracing investigation, generally described as a comprehensive, full-field, judicially assisted tracing inquiry; and (ii) provide the client with information upon which tactical and risk decisions can be made with respect to moving forward with phase two. Phase three, the final phase of the recovery process, is generally represented by the prosecution of pre-emptive asset preservation and enforcement litigation in the jurisdictions where assets are found. The purpose of breaking the concealed asset recovery process down into phases is that it helps to manage the risk that is intrinsic in the speculative nature of all investigations. It thus creates important pause, plan and decision points. The scale of each distinct phase in the process will vary according to the degree of complexity involved, the jurisdictions that are known to be involved and the estimated measure of the value to be located and preserved.

Identification of Targets

The general objectives of any phase one inquiry are to focus on the primary target or obligor while identifying and considering the value of other potential targets of relevant information. During this phase of the tracing investigation, primary and potential targets may be ranked with respect to the amount of resources that should be focused on each. As the process evolves, it will be possible to add or remove names from the list of potential targets as being, respectively, material or immaterial to the achievement of the overarching goal. Accordingly, such a list may change substantially throughout phase one.

Once primary and potential targets have been identified, certain tasks or objectives should be defined in relation thereto. These might include:

building the primary investigative model or plan from the bottom up;

developing baseline, background and real-time information with respect to individuals, venues and modus operandi;

identifying ways and means, specific to the principal target, of (i) locating and defining the manner of holding of the relevant concealed funds, or the assets that represent the exploitation of such funds, and (ii) attributing ownership or control thereof to the principal target;

developing a tasking sheet to gain access to intelligence and objective facts with respect to the means and methods used by the principal target to move, conceal and retrieve the wealth wrongfully acquired;

designing and evaluating the application of certain case-specific investigative methods that can be used during phase two in the continuing effort to locate, preserve and recover the assets concealed by the principal target, and if thought advisable, by one or more of the potential targets; and

issuing a report, a set of recommendations and a plan of investigation and recovery upon the completion of the phase one work objectives.

Once a plan of investigation and recovery has been finalized, it should serve as a basic, single-source planning document that presents an overall view of the allocation of resources in terms of priorities, proactive intelligence collection initiatives and other goal-oriented operational activities that need to be accomplished to ensure the attainment of the strategic or overarching goal of bringing meaningful remedies to the victim of the fraud. The primary purpose of any such plan will be to establish case-specific priorities and objectives to ensure that case tasks are performed efficiently and effectively. Priorities and objectives are relevant to the application of resources, to the management of financial risk and to specific investigative tasks (eg, determining what entities to investigate, what records to review, what investigative methods to employ and realistic timeframes for completing tasks). It also provides budget guidance, performance measures and a guide for managers to implement specific tasks.

A plan should be designed specifically to focus on tracing and recovering:

the proceeds of fraud;

assets or earnings derived from such proceeds; and

assets of the principal target that may not necessarily be directly traceable to the fraud.

Flow of Operations

Over the course of any investigation, the plan will require alterations as additional facts are revealed. For this reason, the plan should be flexible enough to accommodate the shifting of investigative emphasis and staff resources as circumstances dictate, and provide a continuing, up-to-date basis for the professional management of resources and workload. The plan will thus represent an evolving programme of priorities and objectives that will be appropriately modified as circumstances change, and which will necessarily be updated from time to time as new facts are discovered.

Any primary phase of operations should commence with:

a comprehensive debriefing;

analysis of available materials;

a database search; and

some basic investigative work in respect of each of the individuals who fall to be considered as the principal targets or primary accomplices.

As more information emerges during the process, it will become apparent whether it is worthwhile assessing whether potential targets should be the subject of comprehensive research.

The specific investigative measures to be used during the primary phase will need to be custom-built and articulated during the initial period of the preliminary inquiry. The measures that are most suitable to the subjects involved are dependent upon a host of variables and, at any early stage, imponderables.

Access to Evidence

While documentation in the hands of third parties may sometimes be accessed by voluntary means, such materials will be most usually accessed through ex parte applications for extraordinary, pre-emptive relief in the nature of Norwich Pharmacal/Bankers Trust confidential document disclosure orders (wrapped with a seal over the court's record and anti-tip-off or gagging injunctions directed against the banks). Anton Piller private search and seizure orders executed simultaneously at homes and offices of primary targets represent the "nuclear bomb of civil justice" (per Lord Justice Donaldson). Anton Piller relief is intended to preserve evidence which may be crucial to a worldwide asset trace. The Anton Piller jurisdiction is used only to preserve evidence in instances where it is shown that the target is likely to destroy any evidence at hand to frustrate any investigation.

As a general proposition, good results can be obtained by interviewing witnesses. Ordinarily, however, it is not recommended to do so until the investigation is well into its second phase. The preparation of a comprehensive list setting out the names and known summary details of witnesses and accomplices is an invaluable step during the early phase of operations. A plan of witness interviews should be formulated and put into place as a part of the second phase of the investigation.

It may also be helpful for one or more hypotheses to be built indicating collective expectations of the range of value of concealed wealth. This can influence how the investigative tasking sheet is drawn up.

Each part of the investigation should be conducted in a thorough and lawful manner, free from conjecture, unsubstantiated opinion or bias. It is important that team workers be receptive to evidence and information that is helpful to the victim's cause, as well as that which is not. Evidence and information should be gathered, collated, assessed and analyzed through a number of techniques, including the following:

Covert activities - such activities may be used throughout the inquiry. In particular, the primary phase of the inquiry will rely heavily on the making of discreet inquiries as a part of overall operational security. These activities will involve the review of records, collection of evidence and intelligence, surveillance, consensual monitoring and the use of computer technology (eg, to produce link analysis diagrams, databases and spreadsheets). Judicially assisted investigative activities may also be pursued, as appropriate, to include applications for secret, or ex parte, discovery orders to courts of competent jurisdiction. The client should be provided with all the 'news' - both good and bad.

Quasi and fully overt activities - after the predominantly covert phase of the inquiry has been completed (with the view to collecting as much information and evidence as possible without disclosure of the fact of an inquiry), certain overt investigative measures will generally need to be undertaken. These will likely include interviews of witnesses. Certain subjects may need to be approached under cover of a pretext to seek to procure information. Also, court-ordered subpoenas for the production of records might be requested, as appropriate.

Evidence collection - the gathering of evidence should be undertaken in such a way as to ensure, to the extent possible, that all relevant material is obtained, the chain of custody is preserved and the evidence is admissible in a subsequent proceeding.

Legal and Ethical Restraints on the Conduct of Private Inquiries

There are a number of important legal, ethical and regulatory issues that must be considered at the beginning of any proper investigation to identify the location and manner of holding of concealed assets believed to be linked to one of the principal targets of an inquiry. For such an inquiry to be successful, every action to be taken must be vetted against four questions:

Is the proposed activity lawful in the place where it is to be undertaken?

Will evidence deriving from the activity be admissible in the forum where it is to be adduced, in the light of the manner by which it was obtained?

Is it ethically proper for a lawyer to cause the activity under consideration to be done?

Which of the alternative methods available is likely to be the most effective and/or economical way of obtaining the relevant data, intelligence or evidence required?

At each decision point in an investigation, each of these four questions must be posed before any further contemplated action can be taken. If there is ever a negative or unsatisfactory answer, the team involved in the inquiry must seek to find an alternative path forward. This alternative path must then be vetted before being followed. In instances where a certain action is being considered and there are concerns about whether it can or should be done, it may be necessary to seek judicial approval of the same before proceeding.

Privilege - Maintaining Control

Information and documents collected, and even information and documents generated, by an inquiry may be accessible by the government, regulators, private litigants and the public. A plan of preservation of the lawyer-client and litigation privileges must form part of the fabric of any inquiry. The ability to choose if, when, how and to whom the results of the inquiry will be disclosed will exist only to the extent that the lawyer-client or litigation privileges apply, and only to the extent that certain conditions are met and maintained. Factors which may add to the complexity of this issue are the numbers of jurisdictions that may be involved - and the number of legal systems that may influence the maintenance of privilege over confidential communications and reports. This is a fluid area.

Judicially Assisted Concealed Asset Investigations

As a complement to extra-judicial investigative activities, it may be advisable to seek to obtain extraordinary, secret document disclosure orders to secure copies of confidential banking and other records wherever it appears feasible and materially fruitful to do so. Typically, such orders are available in the Anglo-Saxon legal world. Under civil law systems of justice, complementary local criminal proceedings are ordinarily used as an alternative means of gaining access to the relevant records.

Applications for such extraordinary, ex parte relief ought to be made on a situation-specific basis, and pursued for the purposes of defeating any target's use of bank secrecy and other financial privacy laws to obstruct the victim's path to discovery. This measure is more rapidly rolled out and executed upon than the turgid pace that characterizes the execution of most government-to-government mutual legal assistance treaty requests. Moreover, placing reliance on governments to perform international document retrieval work may sound appealing in its promise of 'saving money'; but it can also be completely unsatisfactory. There are legal impediments to prosecuting civil asset recovery actions - where defendants are wont to argue abuse of the mutual legal assistance treaty process (inasmuch as defendants will, where possible, allege the violation of the strict conditions placed on the use of evidence obtained from mutual legal assistance treaty requests for criminal matters). Moreover, the traditional role and objective of governments is to catch the criminals rather than seize the money, leaving recovery to the victim to pursue. In practical terms, this means that the focus of government action is different to that of 'private asset recovery'. Government resources can be looked upon to assist in the achievement of objectives, but should ideally form no greater role than that.

In many instances, intra-judicial investigations are the only realistic option for legally unveiling information that is otherwise concealed by corporate structures, attorney-client relationships or other mechanisms used as asset protection devices.

Typically, judicially assisted investigations involve court orders that are issued in secret, with an enjoinder against unauthorized disclosure (consisting of an order wrapped with a gag or an anti-tip-off order), and served on, among others:

banks;

investment advisers and securities dealers;

insurance companies;

telephone companies, credit card issuers and airline frequent flyer accounts, utility companies; and

law, tax consultant, estate planning, accountancy, and company formation and administration firms.

Successful applications for Norwich Pharmacal/Bankers Trust document disclosure orders - which compel the disclosure of information under anti-tip-off or gagging injunctions and other legal restrictions - must be constructed and directed by counsel experienced with multi-jurisdictional pre-emptive remedy laws. Experienced local counsel, knowledgeable of circumstances unique to particular venues, must also be employed and guided. This element of a concealed asset investigation is ordinarily crucial, particularly as time limits can be crucial.

Research and Analytical Tasks

To accomplish the general and specific objectives mentioned above, various intelligence and information gathering activities should be set in motion in the primary phase. These investigative activities may include:

an examination of all available records and other documentary evidence;

liaisons with known sources of information, both open and confidential, including sources within official police and government circles where appropriate;

attempts to develop additional confidential and open sources;

covert gathering of intelligence and evidence;

the retrieval of pertinent information from various electronic and other databases;

the surveillance of principal targets (and, should it be considered appropriate, potential targets);

the initiation of covert evidence and intelligence gathering and the commencement of discreet inquiries to accomplish, among other things, the reverse tracing of concealed assets;

pretext contacts with specific sources of information;

the possible interview of selected witnesses; and

the initiation of judicially assisted investigations, if considered appropriate in terms of timing.

Various tasks performed during the first phase will be continued into the second. These tasks may include:

the identification and interviewing of witnesses;

physical surveillance of key individuals;

covert evidence gathering; and

more applications to courts for extraordinary judicial remedies.

Any baseline, comprehensive background investigations of principal targets, and any applicable corporate or other alter egos, will focus on seeking to develop and analyze the following information:

real property ownership and property values;

luxury assets;

intangible assets;

mortgage information;

liens;

judgments;

bankruptcies;

history of addresses and phone numbers;

relatives;

involvement in past or pending lawsuits;

criminal record searches;

lifestyle;

key business, advisory and social contacts;

background history;

modus operandi;

general psychological profile and 'litigation psyche';

key strengths and weaknesses;

decision cycle (ie, how fast one will have to move in order to move faster than the primary obligor, to ensure success);

preferred laundering typologies;

the identities of money laundering advisers or model builders; and

likely preferred courses of action.

A focused investigation should begin the process of locating and defining the manner of holding of concealed assets that are believed attributable to principal targets, including real property, investments, links to businesses, financial holdings and other sources of income. The investigation of principal targets may include:

surveillance;

covert retrieval of evidence and records;

pretext contacts; and

other investigative activities to ascertain means of lifestyle funding.

Overt, extra-judicial investigative activities, coupled with judicially assisted investigations, where appropriate, may be conducted to develop information on entities that are believed to have been used to move, conceal and perhaps hold assets that were fraudulently obtained.

Plan of Investigation and Litigation - Managing Risk

The recovery of concealed assets involves the need to manage risk. Experience has revealed several points about risk in this specialist area:

Investigations conducted in a factually tangled and difficult environment, and directed towards persons who have conducted themselves in a dishonest and harmful manner over a protracted period, represent complex and dynamic work.

To be effective, the work must be undertaken within a fluid and lateral-thinking environment. Restated, the work must move laterally around the dishonest obligors' strengths. Analytical barriers and traps need to be avoided. Dishonest obligors expect to see a conventional or orthodox approach - devoid of imagination, sustained financial commitment and the unexpected. The rigors of budgetary projections for this type of work are not applied easily. However, breaking an inquiry down into elements and phases helps to establish signposts and decision points to manage risk.

The quantum of the cost of the process is not a function of the measure of value of the obligation sought to be enforced, or the economic size of the problem - once the amount of value 'handled' by the subject exceeds, say, €50 million. Thus, the cost of pursuing an inquiry involving the apparent mismanagement or misappropriation of €50 million is often roughly the same, in absolute terms, as the cost of pursuing a €200 million one.

In general, as more capital is spent on the process, the risk associated with a complete failure in the investigation declines. In other words, with each step, there is ordinarily greater access to objective fact with which to support moving forward to the next step. The process of mitigating the risk of a total failure in the inquiry is thus incremental.

Risk must be managed by the repeated revisiting of critical assumptions, and the preservation of an initial pool of assets, to objectively justify the completion of the work.

Operational Security

In the context of an asset tracing investigation, operational security is about keeping potential adversaries from discovering information that can be pieced together or interpreted to discern the plans, intentions, capabilities or activities of the asset tracing team. The process of denying information to adversaries involves identifying, controlling and protecting the outward signs, or indicators, associated with the planning processes or operations. The management of operational security is vital to achieving the critical objectives relevant to a concealed asset investigation, especially when it involves particularly sensitive or critical activities, such as requesting applications for ex parte discovery or confidential document disclosure orders. In such circumstances success depends on secrecy and surprise.

The basic premise of operational security is that the accumulation by the adversary of one or more elements of seemingly unimportant information could damage or defeat the entire investigation, as secrecy and surprise can be compromised by the disclosure of even minor pieces of information. Intelligence collection and analysis is very much like assembling a mosaic or puzzle, and an adversary can employ measures to obtain bits of information from many sources and assemble them to form the overall picture. It is therefore of paramount importance to deny information (the pieces of the intelligence puzzle) to the adversary whenever possible, particularly during the covert stages of the investigation and when dealing with sensitive or crucial field operations or legal actions.

Because mishaps can occur due to events that are beyond reasonable control, countermeasures must be developed to reduce the vulnerabilities or utility of the investigative information to the adversary, and to enable any damages sustained from unauthorized disclosures to be swiftly contained. Being mindful that the elements of secrecy and surprise are vital to achieving any overarching goal within the context of asset location and recovery, an active defence strategy that includes prevention, detection and response will be part of the process. Such general defensive measures will include alternatives that may vary in effectiveness, feasibility and cost, and may include countermeasures that are likely to work in a particular situation. The decision of whether to implement specific measures must be based on a cost/benefit analysis and an evaluation of the specific objectives. Awareness and vigilance are the most critical elements of operational security (particularly when discussing planning processes, operations or legal strategies, or when handling and transmitting documents). Conversely, the most serious threat to operational security is complacency.

Definition of Objectives

Ultimately, the conduct of works in the context of a far-reaching asset location and recovery exercise will require the preparation of and reliance upon a comprehensive plan of action and objectives. The work objectives for the initial phase of any such work should have the following aims, at the very least:

Leads to wealth - perform investigative work to obtain leads to the main protagonist's wealth;

Identification of accessories - conduct inquires to ascertain others involved in concealing assets;

Research and background investigation - conduct database research and basic background investigations on any primary targets and potential targets;

Identification of key subjects - perform preliminary research and investigations of any primary targets, and also possibly in relation to potential targets, with the view to identifying the 'weakest link(s)' for concentrated investigation during the more advanced phases of the process;

Specific tasks - design and implement discrete investigative tasks that are most suitable to develop meaningful information in further phases;

Witness interviews - formulate a plan of witness interviews, to be implemented possibly in later stages of the process;

Forward and reverse traces - initiate covert activities and discreet inquiries involving a review of available records, surveillance, pretext contacts and possible consensual monitoring to permit the commencement of the tracing of assets. The start of physical surveillance of the key targets may begin, as appropriate, considering how the case progresses during the initial phase. The covert activities may involve the start of judicially assisted investigative activities, as appropriate, to include applications for ex parte discovery orders. The true points of beginning of the forward trace will be sought;

Overt investigation planning - continue to plan the various steps to be taken in the overt investigative phase;

Evidence and intelligence collection - the performance or use of suitable investigative techniques and methods to gather, collate and analyze intelligence and evidence will begin in the primary phase. This process will likely continue throughout the process;

Diagram of sequence of events - compare relevant dates of asset acquisition and disposal and/or transfer;

Link analysis - develop the foundation for the use of computer-assisted analyses to construct databases, spreadsheets and link analysis diagrams;

Documents database - propose and implement an electronic system for the imaging and retention of all evidence and documents for the concealed asset investigation;

Plan of preservation of privilege - develop a plan to protect confidential and privileged communications and reports; and

The plan - issue the first manifestation of the plan.

The above list is not exhaustive, but does provide a useful checklist of specific tasks or objectives to be addressed within the pursuit of the overall objective. Defining the overall objective at an early stage involves more than a commitment to locate or follow the money. It will necessarily involve an analysis of the means available towards achieving that end, the route to be taken and the potential for compromise in given situations. The overarching goal cannot be viewed in isolation from the route towards that goal and, in particular, the potential obstacles along the way. Thus, the importance of early focus and analysis on key issues cannot be overemphasized. This will reduce the potential for incurring unnecessary or futile expenditure of human and financial capital and should present the benefit of defining intermediate objectives at an early stage. This will provide both the service provider and the client with a reasonably well-defined estimate of cost and benefit. The level of commitment required must be projected and addressed adequately. In an ideal scenario, the only surprises in an asset recovery and investigation exercise should be those for the targets of the investigation.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

British Virgin Islands: Multi-Jurisdictional Concealed Asset Recovery Investigations – A Blueprint