intradepartmental correspondence october 13, 2016 … · office of justice programs office of the...

INTRADEPARTMENTAL CORRESPONDENCE

October 13, 20161.17

TO: The Honorable Board of Police Commissioners

FROM: Chief of Police

SUBJECT: TRANSMITTAL OF THE GRANT APPLICATION FOR THE 2016-2018INTELLECT UAL PROPERTY ENFORCEMENT GRANT

RECOMMENDED ACTIONS

1. That the Board of Police Commissioners (Board) REVIEW and APPROVE this report.

2. That the Board TRANSMIT the attached grant application, pursuant to Administrative CodeSection 14.6(a), to the Mayor, Office of the City Administrative Officer (CAO), Office of theChief Legislative Analyst and to the City Clerk for committee and City Councilconsideration.

3. That the Board REQUEST the Mayor and City Council to:

A. AUTHORIZE the Chief of Police to ACCEPT the grant award for the 2016-2018Intellectual Property Enforcement Grant in the amount up to $314,653 for the period ofOctober 1, 2016 through September 30, 2018, from the Bureau of Justice Administration,United States Department of Justice;

B. AUTHORIZE the Los Angeles Police Department (LAPD) to spend up to the grantamount of $314,653 in accordance with the grant award agreement;

C. AUTHORIZE the Chief of Police or his designee to negotiate and execute theCooperative Agreement, subject to City Attorney approval as to form and legality;

D. AUTHORIZE the LAPD to submit grant reimbursement requests to the grantor anddeposit grant receipts in Fund No. 339, Department No. 70;

E. AUTHORIZE the Controller to set up a grant receivable and appropriate $314,653 to anappropriation account to be determined within Fund No. 339, Department No. 70, for thereceipt and disbursement of the 2016-2018 Intellectual Property Enforcement Grant inaccordance with the grant award agreement;

F. AUTHORIZE the Controller to increase appropriations for 2016-2018 IntellectualProperty Enforcement Grant as needed from appropriation account number to bedetermined in Fund No. 339, Department No. 70, to Fund No. 100, Department No. 70,account number and amount as follows:

Account No. 001092, Sworn Overtime: $ 235,990

The Honorable Board of Police Commissioners1.17

G. AUTHORIZE the Controller to transfer appropriations for 2016-2018 IntellectualProperty Enforcement Grant, as needed from appropriation account to be determined inFund No. 339, Department No. 70 to the City Attorney's Office Fund No. 100,Department No. 12, in the amount as follows:

Account No. 1010, Salaries General $ 28,255

a. AUTHORIZE the City Council to Instruct the City Clerk to place on CouncilCalendar for July 1, 2017 the following action relative to the Intellectual PropertyEnforcement grant:

i. That the City Council, subject to the approval of the Mayor, AUTHORIZE theController to transfer $40,477 from Fund 339, Department 70, Account to bedetermined to Fund 100, Department 12, Account 1010 Salaries General.

b. AUTHORIZE the City Council to Instruct the City Clerk to place on CouncilCalendar for July 1, 2018, the following action relative to the Intellectual PropertyEnforcement grant:

i. That the City Council, subject to the approval of the Mayor, AUTHORIZE theController to transfer $9,931 from Fund 339, Department 70, Account to bedetermined to Fund 100, Department 12, Account 1010 Salaries General

H. AUTHORIZE the LAPD to prepare Controller Instructions for any technical adjustments,subject to the approval of the CAO, and AUTHORIZE and INSTRUCT the Controller toimplement the instructions; and

I. RESOLVE that that the position authority in the City Attorney's Office be continueduntil September 30, 2018, for one Deputy City Attorney II (0551) position.

DISCUSSION

The LAPD was a recipient of the FY 2009, 2010, 201 1, 2013 and 2014 Intellectual PropertyEnforcement grants. As a result of grant funding, LAPD has been able to dramaticallystrengthen its efforts in combating the proliferation of counterfeit goods; enforcing copyright,trademark, and patent laws; and deterring organized counterfeit manufacturing and distributionrings.

The LAPD will use the $314,653 grant award to fund a project entitled "Reducing andPreventing Intellectual Property Crime in the City of Los Angeles." The LAPD Anti-PiracyUnit, working in partnership with the Los Angeles City Attorney, proposes a multi-facetedapproach to continue to reduce and prevent IP crime in Los Angeles. The long-term goal of theLAPD is to reduce the supply of and demand for pirated merchandise and counterfeit activities inLos Angeles. The following are the objectives under the proposed grant: 1. Reduce the supplyside of IP crime by reducing the number of repeat IP crime offenses and the number of chronicIP crime locations or "hot spots;" 2. Develop and evaluate additional strategies to address the

The Honorable Board of Police Commissioners1.17

changing trends and kinds of IP crime and to prevent IP crime linkages to othernational/international crimes; 3. Reduce the demand for IP crime by educating the public aboutthe economic and personal dangers of IP crime; and 4. Prevent IP crime displacement by sharingbest practices.

The LAPD will allocate $235,990 for sworn overtime to investigators in the Anti-Piracy Unit toimplement strategies and tactics in fighting highly-organized and upwardly mobile repeatoffenders. The City Attorney's office has been allocated $78,663 for salary costs to partiallyfund a Deputy City Attorney II who will dedicate 43% of their time to prosecute IntellectualProperty related crimes as well as participate in task force efforts, training and outreach.Additional prosecutorial resources will address a significant gap in IP criminal case filings.Following City Attorney staff reductions during the City's fiscal crisis, criminal IP case filingrates dropped more than 70% from 2009 to 2013. Through grant resources, a Deputy CityAttorney will implement a vertical prosecution approach to IP enforcement to improve publicsafety. This approach entails direct handling of criminal IP matters investigated by LAPD'sAnti-Piracy Unit commencing with case filing through the criminal prosecution steps andongoing sentencing compliance thereafter.

If you have any questions, please contact Chief Information Officer Maggie Goodrich,Commanding Officer, Information Technology Bureau, at (213) 486-0370.

Respectfully,

CHASChief of Police

Attachments

U.S. Department of Justice

Office of Justice Programs

Office of the Assistant Attorney General Washington. D.0 20531

September 9, 2016

Chief Charlie BeckCity of Los Angeles200 N. Spring StreetSW Mezzanine. Rm. M175Los Angeles, CA 90012

Dear Chief Beck:

On behalf of Attorney General Lomita Lynch. it is my pleasure to inform you that the Office of Justice Programs has approvedyour application for funding under the FY 16 Intellectual Property Enforcement Program in the amount of $314,653 for City ofLos Angeles.

Enclosed you will find the Grant Award and Special Conditions documents. This award is subject to all administrative andfinancial requirements, including the timely submission of all financial and programmatic reports, resolution of all interimaudit findings, and the maintenance of a minimal) level of cash-on-hand. Should you not adhere to these requirements, youwill be in violation of the terms of this agreement and the award will be subject to termination for cause or other administrativeaction as appropriate.

If you have questions regarding this award, please contact:

- Program Questions, Olga Santiago, Program Manager at (202) 532-0117; and

- Financial Questions, the Office of the Chief Financial Officer, Customer Service Center (CSC) at(800) 458-0786, or you may contact the CSC at ask.ocfo@usdoLgov.

Congratulations, and we look forward to working with you.

Sincerely,

.Karol Virginia Mason

Assistant Attorney General

Enclosures

IU.S. Department of JusticeOffice of Justice Programs

, Bureau of Justice Assistance..-,.

GRANT MANAGER'S MEMORANDUM, PT. I:PROJECT SUMMARY

Grant

PROJECT NUMBER

2016-ZP-BX-0006PAGE 1 OP 1

This project is supported under FYI6(BJA - Economic/Nigh-Tea) Pub. L No. 114-113, 129 Sim 2242, 2307

I. STAFF CONTACT (Name & telephone number)

Olga Santiago(202) 532-0117

2. PROJECT DIRECTOR (Name, address It telephone number)

Nichols TrujilloManagernerd Analyst II100 West 1st StreetLee Angeles, CA 90012(213) 486-0385

3a. TITLE OF THE PROGRAM

Imellectual Property Enforeenxm Program

3b. POMS CODE (SEE INSTRUCTIONSON REVERSE)

4. wiz OF PROJECT

LOS Angeles Police Department FY 2016.2018 Intellectual Property Crime Enforcement Program

5. NAME a ADDRESS OF GRANTEE

City of Los Angeles200 N. Spring Street SW NICZnthille, F(111. M175Los Angeles, CA 90012

6. NAME & ADRESS OF SUBGRANTEE

7. PROGRAM PERIOD

FROM: 10101/2016 TO: 09/30:2018

8. BUDGET PERIOD

FROM: 10101/2016 TO: 09/30/2018

9. AMOUNT OF AWARD

S 314,653

10. DATE OF AWARD

09/09/2016

II. SECOND YEAR'S BUDGET 12. SECOND YEAR'S BUDGET AMOUNT

13.1111RD YEAR'S BUDGET PERIOD 14. THIRD YEAR'S BUDGET AMOUNT

15. SUMMARY DESCRIPTION OF PROJECT (See instruction on reverse)

This program is barged by section 401 of Public Law 110-403 and is authorized by Be BJA —Ecommlefffigh-Tediwhich authorizes the Department to provide funding to suppon Nude and Meal intelketuel properly tadbecement stria.Program is designed to provide national support and improve the comity of etate, lewd, mid Mit mindoeljualiceenforcement,

(Pub. L. No. 1144 13. 129 Sou 2242.2307),The Intellectual Property Enforcement

intents so address intellectual purity

both the supply and demand sides of counterfeitingthe evolving methods In salts of III products

includmg prosecution, penmen:tit. Paining, and technical moisten

The funds by aimultenemiely erldremingof IP mime is well ea adapt to

crime. CA/NCF

recipient will use the to expand and enhance current enforcanatt effortsthrough new data collection and analysis strategies and enhanced public awarenessthrough social media and other websites to effectively and efficiently reduce IP

OW FORM 4000/2 (REV. 4-88)

OFFICE FOR CIVIL RIGHTS



810 7th Street, NWWashington, DC 20531

Tel: (202) 307-0690TTY: (202) 307-2027E-mail: askOCR®usdolgovWebsite: www.ojp.usdoj.gov/ocr

September 9,2016

Chief Charlie BeckCity of Los Angeles200 N. Spring StreetSW Mezzanine, Rm. MI75Los Angeles, CA 90012

Dear Chief Beck:

Congratulations on your recent award. In establishing financial assistance programs. Congress linked the receipt of federal funding tocompliance with federal civil rights laws. The Office for Civil Rights (OCR), Office of Justice Programs (01P), U.S. Department of Justice(DOJ) is responsible for ensuring that recipients of financial assistance from the 01P, the Office of Community Oriented Policing Services(COPS), and the Office on Violence Against Women (OVW) comply with the applicable federal civil rights laws. We at the OCR areavailable to help you and your organization meet the civil rights requirements that come with DOJ funding.

Ensuring Access to Federally Assisted Programs

Federal laws that apply to recipients of financial assistance from the DO1 prohibit discrimination on the basis of race, color, national origin,religion, sex, or disability in funded programs or activities, not only in employment but also in the delivery of services or benefits. A federallaw also prohibits recipients from discriminating on the basis of age in the delivery of services or benefits.

In March of 2013, President Obama signed the Violence Against Women Reauthorization Act of 2013. The statute amends the ViolenceAgainst Women Act of 1994 (VAWA) by including a nondiscrimination grant condition that prohibits discrimination based on actual orperceived race, color, national origin, religion, sex, disability, sexual orientation, or gender identity. The new nondiscrimination grantcondition applies to certain programs funded after October 1, 2013. The OCR and the OVW have developed answers to some frequentlyasked questions about this provision to assist recipients of VAWA funds to understand their obligations. The Frequently Asked Questionsare available at http:liojp.gov/abouifocrhawafaqs.htm.

Enforcing Civil Rights Laws

All recipients of federal financial assistance, regardless of the particular funding source, the amount of the grant award, or the number ofemployees in the workforce, are subject to prohibitions against unlawful discrimination. Accordingly, the OCR investigates recipients thatare the subject of discrimination complaints from both individuals and groups. In addition, based on regulatory criteria, the OCR selects anumber of recipients each year for compliance reviews, audits that require recipients to submit data showing that they are providing servicesequitably to all segments of their service population and that their employment practices meet equal opportunity standards.

Providing Services to Limited English Proficiency (LEP) individuals

In accordance with DO) guidance pertaining to Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000d, recipients of federal financialassistance must take reasonable steps to provide meaningful access to their programs and activities for persons with limited Englishproficiency (LEP). See U.S. Department of Justice, Guidance to Federal Financial Assistance Recipients Regarding Tide VI ProhibitionAgainst National Origin Discrimination Affecting Limited English Proficient Persons, 67 Fed. Reg. 41,455 (2002). For more informationon the civil rights responsibilities that recipients have in providing language services to LEP individuals, please see the websiteImp:nwww.lep.gov.

Ensuring Equal Treatment for Faith-Based Organizations

The DOJ regulation, Equal Treatment for Faith-Based Organizations. 28 C.F.R. pt. 38, requires State Administering Agencies (SAAs) totreat faith-based organizations the same as any other applicant or recipient. The regulation prohibits SAAs from making awards or grantadministration decisions on the basis of an organization's religious character or affiliation, religious name, or the religious composition of itsboard of directors.

The regulation also prohibits faith-based organizations from using financial assistance from the DO) to fund inherently (or explicitly)religious activities. While faith-based organizations can engage in non-funded inherently religious activities, they must hold themseparately from the program funded by the DOJ, and recipients cannot compel beneficiaries to participate in them. The Equal TreatmentRegulation also makes clear that organizations participating in programs funded by the Dal are not permitted to discriminate in theprovision of services on the basis of a beneficiary's religion. For more information on the regulation, please sec the OCR's website atlittpnwww.ojp.usdoj.goviaboutiocriequalfbo.litrn.

SAM and faith-based organizations should also note that the Omnibus Crime Control and Safe Streets Act (Safe Streets Act) of 1968, asamended, 42 U.S.C. § 3789d(c); the Victims of Crime Act of 1984, as amended, 42 U.S.C. § 10604(e); the Juvenile Justice and DelinquencyPrevention Act of 1974, as amended, 42 U.S.C. § 5672(6); and VA WA, Pub. L. No. 113-4, sec. 3(bfi4), 127 Stat. 54, 61-62 (to be codifiedat 42 U.S.C. § 13925(6)(13)) contain prohibitions against discrimination on the basis of religion in employment. Despite thesenondiscrimination provisions, the Dal has concluded that it may construe the Religious Freedom Restoration Act (RFRA) on a case-by-case basis to permit some faith-based organizations to receive Dal hinds while taking into account religion when hiring staff, even if thestatute that authorizes the funding program generally forbids recipients from considering religion in employment decisions.Please consult with the OCR if you have any questions about the regulation or the application of RFRA to the statutes that prohibitdiscrimination in employment.

Using Arrest and Conviction Records in Making Employment Decisions

The OCR issued an advisory document for recipients on the proper use of arrest and conviction records in making hiring decisions. SeeAdvisory for Recipients of Financial Assistance (min the U.S. Department of Justice on the U.S. Equal Employment OpportunityCommission's Enforcement Guidance: Consideration of Arrest and Conviction Records in Employment Decisions Under Title VII of theCivil Rights Act of 1964 (June 2013), available at httpnwww.ojp.usdoj.govilabouVocripdfs/Useofeonviction_Advisory.pdf. Recipientsshould be mindful that the misuse of arrest or conviction records to screen either applicants for employment or employees for retention orpromotion may have a disparate impact based on race or national origin, resulting in unlawful employment discrimination. In light of theAdvisory, recipients should consult local counsel in reviewing their employment practices. If warranted, recipients should also incorporatean analysis of die use of arrest and conviction records in their Equal Employment Opportunity Plans (EEOPs) (see below).

Complying with the Safe Streets Act

An organization that is a recipient of financial assistance subject to the nondiscrimination provisions of the Safe Streets Act, must meet twoobligations: ( 1 ) complying with the federal regulation pertaining to the development of an EEOP (see 28 C.F.R. pt. 42, subpt. and (2)submitting to the OCR findings of discrimination (see 28 C.F.R. §§ 42.204(c), .205(0(5)).

Meeting the EEOP Requirement

If your organization has less than fifty employees or receives an award of less than $25,000 or is a nonprofit organization, a medicalinstitution, an educational institution, or an Indian tribe, then it is exempt from the EEOP requirement. To claim the exemption, yourorganization must complete and submit Section A of the Certification Form, which is available online athup://www.ojpandoigoviaboutiocr/pdfsicen.pdf.

If your organization is a government agency or private business and receives an award of $25,000 or more, but less than $500,000, and hasfifty or more employees (counting both full- and part-time employees but excluding political appointees), then it has to prepare aUtilization Report (formerly called an EEOP Short Form), but it does not have to submit the report to the OCR for review. Instead, yourorganization has to maintain the Utilization Report on file and make it available for review on request. In addition, your organization has tocomplete Sectton B of the Certification Fonn and return it to the OCR. The Certification Form is available athttp://www.ojp.usdoigoviaboinfocr/pdfsicen.pdt

If your organization is a government agency or private business and has received an award for 5500.000 or more and has fifty or moreemployees (counting both full- and pan-time employees but excluding political appointees), then it has to prepare a Utilization Report(formerly called an EEOP Short Fonn) and submit it to the OCR for review within sixty days from the date of this letter. For assistance indeveloping a Utilization Report, please consult the OCR's website at luip://wv.rw.ojp.usdoigovthboutiocrieeop.hun. In addition, yourorganization has to complete Section C of the Certification Form and return it to the OCR. The Certification Form is available atlutp://www.ojp.usdolgoviabotWocapdfsiccrt.pdf.

To comply with the EEOP requirements, you may request technical assistance from an EEOP specialist at the OCR by telephone at (202)307-0690, by TTY at (202) 307.2027, or by e-mail at EE0submissotergusdoj.gov.

Meeting the Requirement to Submit Findings of Discrimination

If in the three years prior to the date of the grant award, your organization has received an adverse finding of discrimination based on race,color, national origin, religion, or sex, after a due-process hearing, from a state or federal court or from a state or federal administrativeagency, your organization must send a copy of the finding to the OCR.

Ensuring the Compliance of Subrccipients

SAAs must have standard assurances to notify subrecipients of their civil rights obligations, written procedures to address discriminationcomplaints filed against subrecipients, methods to monitor subrecipients' compliance with civil rights requirements, and a program to trainsubrecipients on applicable civil rights laws. In addition, SAAs must submit to the OCR every three years written Methods ofAdministration (MOA) that summarize the policies and procedures that they have implemented to ensure the civil rights compliance ofsubrecipients. For more information on the MOA requirement, see littp://www.ojp.usdoj.govifundinWother_requiremems.him.

If the OCR can assist you in any way in fulfilling your organization's civil rights responsibilities as a recipient of federal financialassistance, please contact us.

Sincerely,

Michael L. Almon

Director

cc: Grant ManagerFinancial Analyst


)(lice of Justice Programs

Bureau of Justice Assistance

I RH tr NAME AND ADDRESS (Inehiding Zip Code)

Coy of Los Angelo200 N Spring Street SW Mezzanine, Rm. M175Los Angeles. CA 90012

GrantPAGE I OF 10

- 4. AWARD NUMBER. 2016-ZP-BX-0006

S. PROJECT PERIOD: FROM

BUDGET PERIOD. FROM

10/01/2016 TO 09/30/2018

10/01/2016 TO 09/30/2018

1 6. AWARD DATE 09/020167' ACTION1

2. GRANTEE IRSNENDOR NO.

95600071S

2b. GRANTEE DUNS NO.

037148012

3. PROJECT TITLE

Los Angelo Police Deponent FY 2016.2018 Intellectual PropertyCome Enforcement Pntgram

8. SUPPLEMENT NUMBER

I 00

O. PREVIOUS AWARD AMOUNT S

10. AMOUNT OF THIS AWARD S 314,633

1 I. TOTAL AWARD S 314,653

12. SPECIAL CONDITIONS

THE ABOVE GRANT PROJECT IS APPROVED SUBJECT TO SUCH CONDITIONS OR LIMITATIONS AS ARE SET FORTHON THE ATTACHED PAGE(S).

13. STATUTORY AUTHORITY FOR GRANT

This promo u awned under FY 16(11.1A • Eamamk/Illgh-Teth) Pub. L No. 114-113. 129 Soo 2242.2107

14 . CATALOG OF DOMESTIC FEDERAL ASSISTANCE (CPDA Number)

16.752 • Econumn High-Tea and Cyber Crime Prenedoe

IS. METHOD OF PAYMENT

GPRS

AGENCY. PPROVAL

I6. TYPED NAME AND MU OF APPROVING OFFICIAL

Enrol Virginia Munn

AssInmd Attorney General

GRANTEE ACCEPTANCE

IL TYPED NAME AND TITLE OP AUTHORIZED GRANTEE OFFICIAL

Charlie BakChief

17. SIGNATURE OF APPROVING OFFICIAL

er-rue,_0 b. ina"4„sir-__19. SIGNATURE OF AUTHORIZED RECIPIENT OFFICIAL 19A. DATE

A(INC " si. (r..120. ACCOUNTING CLASSIFICATION CODES

FISCAL FUND BUD. DIV.YEAR CODE ACT. OFC. REG. SUB. PONS AMOUNT

X 14 IP 80 00 00 314653

OW FORM 4000/2 (REV. 5.87) PREVIOUS EDITIONS ARE OBSOLETE.

OW FORM 40002 (REV. 4418)

21. RIPUGT0762



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PROJECT NUMBER 2015-IP -8X.0006 AWARD DATE 09;092016

SPECIAL CONDITIONS

I. Applicability of Pan 200 Uniform Requirements

The Uniform Administrative Requirements, Cost Principles, and Audit Requirements in 2 C.F.R. Pan 200, as adoptedand supplemented by the Department of Justice (DO)) In 2 C.F.R. Pan 2800 (together, the "Pan 200 UnifonnRequirements") apply to this 2016 award from the Office of Justice Programs (OW).

The Pan 200 Uniform Requirements were first adopted by DO) on December 26, 2014. If this 2016 awardsupplements funds previously awarded by OJP under the same award number (e.g., funds awarded in 2014 or earlieryears), the Pan 200 Uniform Requirements apply with respect to all funds under that award number (regardless of theaward date, and regardless of whether derived from the initial award or a supplemental award) that are obligated on orafter the acceptance date of this 2016 award.

For more information and resources on the Part 200 Uniform Requirements as they relate to OW awards and subawards("subgrants"). see the Office 01.111561X Programs (OJP) website atlittpllojp.govffundingtan200UniformRequirements.lum.

In the event that an award related question arises from documents or other materials prepared or distributed by OJPthat may appear to conflict with, or differ in some way from, the provisions of the Pan 200 Uniform Requirements, therecipient is to contact OJP promptly for clarification.

2. Compliance with DOJ Grants Financial Guide

The recipient agrees to comply with the Depanment of Justice Grants Financial Guide as posted on the OJP website(currently, the "2015 DO) Grants Financial Guide"), including any updated version that may be posted during theperiod of performance.

3. Required training for Point of Contact and all Financial Points of Contact

Both the Point of Contact (POC) and all Financial Points of Contact (FPOCs) for this award must have successfullycompleted an "01P financial management and grant administration training" by 120 days after the date of therecipient's acceptance of the award. Successful completion of such a training on or after January I, 2015, will satisfythis condition.

In the event that either the POC or an FPOC for this award changes during the period of performance, the new POC orFPOC must have successfully completed an "OJP financial management and grant administration training" by 120calendar days after -- (1) the date of °JP's approval of the "Change Grantee Contact" GAN (in the case of a newPOC), or (2) the date the POC enters information on the new FPOC in GMS (in the case of a new FPOC). Successfulcompletion of such a training on or after January I, 2015, will satisfy this condition.

A list of OJP trainings that OW will consider "CUP financial management and grant administration training" forpurposes of this condition is available at hupitwww.ojp.govitraining/fmts.htm. All trainings that satisfy this conditioninclude a session on grain fraud prevention and detection

The recipient should anticipate that CUP will immediately withhold ("freeze") award funds if the recipient fails tocomply with this condition. The recipient's failure to comply also may lead OJP to impose additional appropriateconditions on this award.

L

OW FORM 4000.2 (REV. 448)

of htsttcc


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PROJECT NUMBER 2016-7.P-BX-0006 AWARD DATE 0W0912014

SPECIAL CONDITIONS

4. Requirements related to "de minimis" indirect cost rate

A recipient that is eligible under the Part 200 Uniform Requirements and other applicable law to use the "de minimis"indirect cost rate described in 2 C.F.R. 200.414(0, and that elects to use the "de minimis" indirect cost rate, must advise0.1P in writing of both its eligibility and its election, and must comply with all associated requirements in the Pan 200Uniform Requirements. The "de minimis" rate may be applied only to modified total direct costs (MTDC) as definedby the Pan 200 Uniform Requirements.

5. Requirement to report potentially duplicative funding

If the recipient currently has other active awards of federal funds, or if the recipient receives any other award of federalfunds during the period of performance for this award, the recipient promptly must determine whether funds from anyof those other federal awards have been, are being, or are to be used (in whole or in pan) for one or more of theidentical cost items for which funds are provided under this award. If so, the recipient must promptly notify the DO)awarding agency (OW or OVW, as appropriate) in writing of the potential duplication, and, if so requested by DO)awarding agency, must seek a budget-modification or change-of-pruject-scope grant adjustment notice (GAN) toeliminate any inappropriate duplication of funding.

6. Requirements related to System for Award Management and Unique Entity Identifiers

The recipient must comply with applicable requirements regarding the System for Award Management (SAM),currently accessible at http:llwww.sam.gov. This includes applicable requirements regarding registration with SAM, aswell as maintaining the currency of information in SAM.

The recipient also must comply with applicable restrictions on subawards ("substants") to first-tier subrecipients(first-tier "subgranttes"), including restrictions on subawards to entities that do not acquire and provide (to therecipient) the unique entity identifier required for SAM registration.

The details of the recipient's obligations related to SAM and to unique entity identifiers are posted on the OW web siteat httpithjp.gowfundingfEzplore/SAM.htm (Award condition: System for Award Management (SAM) and UniversalIdentifier Requirements), and are incorporated by reference here.

This special condition does not apply to an award to an individual who received the award as a natural personunrelated to any business or non-profit organization that he or she may own or operate in his or her name).

7. All subawards ("subgrams") must have specific federal authorization

The recipient, and any subrecipient ("subgrantee") at any tier. must comply with all applicable requirements forauthorization of any subaward. This condition applies to agreements that -- for purposes of federal grantsadministrative requirements — OW considers a "subaward" (and therefore does not consider a procurement"contract").

The details of the requirement for authorization of any subaward are posted on the OW web site athttplthjp.gov/fundingtExplore/SubawardAuthorization.him (Award condition: Award Condition: All subawards("subgrants") must have specific federal authorization), and are incorporated by reference here.

OR FORM 4000/2 (REV. 448)

•U.S. Depathnent of Justice



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PROJECT NUMBER 2016.ZP40(4006 AWARD DATE 09/09.2016

SPECIAL CONDITIONS

8. Specific post-award approval required to use a noncompetitive approach in any procurement contract that wouldexceed S150,000

The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable requirements to obtainspecific advance approval to use a noncompetitive approach in any procurement contract that would exceed theSimplified Acquisition Threshold (currently. $150,000). This condition applies to agreements that for purposes offederal grants administrative requirements OJP considers a procurement "contract" (and therefore does not considera subaward).

The details of the requirement for advance approval to use a noncompetitive approach in a procurement contract underan OW award are posted on the OJP web site at lutp://ojp.govffunding/Explore/NoncompetitiveProcurementlum (Awardcondition: Specific post-award approval required to use a noncompetitive approach in a procurement contract (ifcontract would exceed S150,000)), and are incorporated by reference here.

9. Requirements pertaining to prohibited conduct related to trafficking in persons (including reporting requirements andOW authority to terminate award)

The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable requirements (includingrequirements to report allegations) pertaining to prohibited conduct related to the trafficking of persons, whether on thepart of recipients, subrecipients ("subgrantees"), or individuals defined (for purposes of this condition) as "employees"of the recipient or of any subrecipient.The details of the recipient's obligations related to prohibited conduct related to trafficking in persons are posted on theOW web site at http://ojp.govifunding/Explore/ProhibitedConduct-Trafficking.him (Award condition: Prohibitedconduct by recipients and subrecipients related to trafficking in persons (including reporting requirements and OWauthority to terminate award)), and are incorporated by reference here.

10. Compliance with applicable rules regarding approval, planning, and reporting of conferences, meetings, trainings, andother events

The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable laws. regulations,policies, and official DO1 guidance (including specific cosi limits, prior approval and reporting requirements, whereapplicable) governing the use of federal funds for expenses related to conferences (as that term is defined by D01),including the provision of food and/or beverages at such conferences, and costs of attendance at such conferences.

Information on the pertinent DOJ definition of conferences and the rules applicable to this award appears in the DOJGrants Financial Guide (currently, as section 3.10 of "Postaward Requirements" in the "2015 DOS Grants FinancialGuide").

I I. Requirement for data on performance and effectiveness under the award

The recipient must collect and maintain data that measure the performance and effectiveness of activities under thisaward. The data must be provided to OJP in the manner (including within the timefratnes) specified by OW in theprogram solicitation or other applicable written guidance. Data collection supports compliance with the GovernmentPerformance and Results Act (GPRA) and the GPRA Modernization Act, and other applicable laws.

12. OJP Training Guiding Principles

Any training or training materials that the recipient or any subrecipient ("subgrantee") at any tier -- develops ordelivers with OW award funds must adhere to the OW Training Guiding Principles for Grantees and Subgrantees,available at littp://Mp.gov/funding/thptrainingguidingprinciples.hun.

OJP FORM 10002 (REV. 4 No




PROJECT NI.Minft 7016.ZP.BX.00OO

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SPECIAL CONDITIONS

13. Effect of failure to address audit issues

The recipient understands and agrees that the DO) awarding agency (OW or OVW, as appropriate) may withholdaward funds, or may impose other related requirements, if (as determined by the DO) awarding agency) the recipientdoes not satisfactorily and promptly address outstanding issues from audits required by the Pan 200 UniformRequirements (or by the terms of this award), or other outstanding issues that arise in connection with audits.investigations, or reviews of DOJ awards.

14. The recipient agrees to comply with any additional requirements that may be imposed by the D0.1 awarding agency(OJP or OVW, as appropriate) during the period of performance for this award, if the recipient is designated as "high-risk" for purposes of the DO) high-risk grantee list.

15. Compliance with DO) regulations pertaining to civil rights and nondiscrimination -28 C.F.R_ Pan 42

The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable requirements of 28C.F.R. Pan 42, specifically including any applicable requirements in Subpart E of 28 C.F.R. Pan 42 that relate to anequal employment opportunity program.

16. Compliance with DO) regulations pertaining to civil rights and nondiscrimination - 28 C.F.R. Part 38

The recipient, and any subrecipient ("subgramce") at any tier, must comply with all applicable requirements of 28C.F.R. Part 38, specifically including any applicable requirements regarding written notice to program beneficiaries andprospective program beneficiaries. Pan 38 of 28 C.F.R., a DO) regulation, was amended effective May 4, 2016.

Among other things, 28 C.F.R. Pan 38 includes rules that prohibit specific forms of discrimination on the basis ofreligion, a religious belief, a refusal to hold a religious belief, or refusal to attend or participate in a religious practice.Pan 38 also sets out rules and requirements that pertain to recipient and subrecipient ("subgrantee") organizations thatengage in or conduct explicitly religious activities, as well as rules and requirements that pertain to recipients andsubrecipients that are faith-based or religious organizations.

The text of the regulation, now entitled "Partnerships with Faith-Based and Other Neighborhood Organizations," isavailable via the Electronic Code of Federal Regulations (currently accessible at lutp://www.ccfrgovrogi-bintECFR?page-browse), by browsing to Title 28-Judicial Administration, Chapter I, Pan 38, under c-CFR "current"data.

17. Restrictions on "lobbying"

Federal funds may not be used by the recipient, or any subrecipient ("subgrantee") at any tier, either directly orindirectly, to support or oppose the enactment, repeal, modification or adoption of any law, regulation, or policy, at anylevel of government.

Should any question arise as to whether a particular use of Federal funds by a recipient (or subrecipient) would ormight fall within the scope of this prohibition, the recipient is to contact 01P for guidance, and may not proceedwithout the express prior written approval of OW.

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18. Compliance with general appropriations-law restrictions on the use of federal funds (FY 2016)

The recipient, and any subrecipient ("subgrantee") at any tier, must comply with all applicable restrictions on the use offederal funds set out in federal appropriations statutes. Pertinent restrictions, including from various "generalprovisions" in the Consolidated Appropriations Act, 2016, are set out at littp://ojp.gov/funding/Explore/FY2016-AppropriationsLawRestrictions.htm, and arc incorporated by reference here.

Should a question arise as to whether a particular use of federal funds by a recipient (or a subrecipient) would or mightfall within the scope of an appropriations-law restriction, die recipient is to contact OJP for guidance, and may notproceed without the express prior written approval of OJP.

19. Reporting Potential Fraud, Waste, and Abuse, and Similar Misconduct

The recipient and any subrecipients ("subgrantees") must promptly refer to the D01 Office of the Inspector General(010) any credible evidence that a principal. employee, agent, subrecipient, contractor, subcontractor, or other personhas, in connection with funds under this award .- (I) submitted a claim that violates the False Claims Act; or (21committed a criminal or civil violation of laws pertaining to fraud, conflict of interest, bribery, gratuity, or similarmisconduct.

Potential fraud, waste, abuse, or misconduct involving or relating to funds under this award should be reported to theOIG by-- ( I) mail directed to: Office of the Inspector General. U.S. Department of Justice, Investigations Division,950 Pennsylvania Avenue, N.W. Room 4706, Washington, DC 20530; (2) e-mail to: oig.hotline@usdoigov; and/or (3)the DO1 010 hotline: (contact information in English and Spanish) at (800) 869-4499 (phone) or (202) 616-9881(fax).

Additional information is available from the DOJ 010 website at http://www.usdoj.gov/oig.

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SPEC/AL CONDITIONS

20. Restrictions and certifications regarding non-disclosure agreements and related matters

No recipient or subrecipient ("subgrantee") under this award, or entity that receives a procurement contract orsubcontract with any funds under this award, may require any employee or contractor to sign an internal confidentialityagreement or statement that prohibits or otherwise restricts, or purports to prohibit or restrict, the reporting (inaccordance with law) of waste, fraud, or abuse to an investigative or law enforcement representative of a federaldepartment or agency authorized to receive such information.

The foregoing is not intended, and shall not be understood by the agency making this award, to contravenerequirements applicable to Standard Form 112 (which relates to classified information). Form 4414 (which relates tosensitive compartmented information), or any other form issued by a federal department or agency governing thenondisclosure of classified information.

I. In accepting this award, the recipient—

a. represents that it neither requires nor has required internal confidentiality agreements or statements from employeesor contractors that currently prohibit or otherwise currently restrict (or purport to prohibit or restrict) employees orcontractors from reporting waste, fraud, or abuse as described above; and

b. certifies that, if it learns or is notified that it is or has been requiring its employees or contractors to executeagreements or statements that prohibit or otherwise restrict (or purport to prohibit or restrict), reporting of waste, fraud,or abuse as described above, it will immediately stop any further obligations of award funds, will provide promptwritten notification to the federal agency making this award, and will resume (or permit resumption of) suchobligations only if expressly authorized to do so by that agency.

2. If the recipient does or is authorized under this award to make subawards ("subgra.nts"), procurement contracts, orboth--

a. it represents that—

( 1 ) it has determined that no other entity that the recipient% application proposes may or will receive award funds(whether through a subaward ("subgrant"), procurement contract, or subcontract under a procurement contract) eitherrequires or has required internal confidentiality agreements or statements from employees or contractors that currentlyprohibit or otherwise currently restrict (or purport to prohibit or restrict) employees or contractors from reporting waste,fraud, or abuse as described above; and

(2) it has made appropriate inquiry, or otherwise has an adequate factual basis, to support this representation; and

b. it certifies that, if it learns or is notified that any subrecipient contractor, or subcontractor entity that receives fundsunder this award is or has been requiring its employees or contractors to execute agreements or statements that prohibitor otherwise restrict (or purport to prohibit or restrict), reporting of waste, fraud, or abuse as described above, it willimmediately stop any further obligations of award funds to or by that entity, will provide prompt written notification tothe federal agency making this award, and will resume (or permit resumption of) such obligations only if expresslyauthorized to do so by that agency.

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21. Compliance with 41 U.S.C. 4712 (including prohibitions on reprisal; notice to employees)

The recipient mist comply with, and is subject to, all applicable provisions of 41 U.S.C. 4712, including all applicableprovisions that prohibit, under specified circumstances, discrimination against an employee as reprisal for theemployee's disclosure of information related to gross mismanagement of a federal grant, a gross waste of federal funds,an abuse of authority relating to a federal grant, a substantial and specific danger to public health or safety, or aviolation of law, rule, or regulation related to a federal grant.

The recipient also must infonn its employees, in writing (and in the predominant native language of the workforce), ofemployee rights and remedies under 41 U.S.C. 4712.

Should a question arise as to the applicability of the provisions of 41 U.S.C. 4712 to this award, the recipient is tocontact the 001 awarding agency (OJP or OVW, as appropriate) for guidance.

22. Encouragement of policies to ban text messaging while driving

Pursuant to Executive Order 13513. "Federal Leadership on Reducing Text Messaging While Driving," 74 Fed. Reg.51225 (October I, 2009), DO1 encourages recipients and subrecipients ("subgrantees") to adopt and enforce policiesbanning employees from text messaging while driving any vehicle during the course of performing work funded by thisaward, and to establish workplace safety policies and conduct education, awareness, and other outreach to decreasecrashes caused by distracted drivers.

23. The recipient agrees to submit to BJA for review and approval any curricula, training materials, proposed publications,reports, or any other written materials that will be published, including web-based materials and web site content,through hinds from this grant at least thirty (30) working days prior to the targeted dissemination date. Any written,visual, or audio publications, with the exception of press releases, whether published at the grantee's or government'sexpense, shall contain the following statements: "This project was supported by Grant No. 2016-ZP•BX•0006awarded by the Bureau of Justice Assistance. The Bureau of Justice Assistance is a component of the Department ofJustice's Office of Justice Programs, which also includes the Bureau of Justice Statistics, the National Institute ofJustice, the Office of Juvenile Justice and Delinquency Prevention, the Office for Victims of Crime, and the SMARTOffice. Points of view or opinions in this document arc those of the author and do not necessarily represent the officialposition or policies of the U.S. Department of Justice." The current edition of the OJP Financial Guide providesguidance on allowable printing and publication activities.

24. The recipient agrees to cooperate with any assessments, national evaluation efforts, or information or data collectionrequests, including, but not limited to, the provision of any information required for the assessment or evaluation of anyactivities within this project.

25. Any Web site that is funded in whole or in pan under this award must include the following statement on the homepage, on all major entry pages (i.e., pages (exclusive of documents) whose primary purpose is to navigate the user tointerior content), and on any pages from which a visitor may access or use a Web•based service, including any pagesthat provide results or outputs from the service:

'This Web sue is funded (insert "in part," if applicable) through a grant from the (insert name of 011' component),Office of Justice Programs. U.S. Department of Justice. Neither the U.S. Department of Justice nor any of itscomponents operate, control, are responsible for, or necessarily endorse, this Web site (including, without limitation, itscontent, technical infrastructure, and policies, and any services or tools provided)."

The full text of the foregoing statement muss be clearly visible on the home page. On other pages, the statement maybe included through a link, entitled "Notice of Federal Funding and Federal Disclaimer," to the hill text of thestatement.

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•U.S. Department of Justice



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26. Approval of this award does not indicate approval of any consultant rate in excess of $650 per day. A detailedjustification must be submitted to and approved by the Office of Justice Programs (OJP) program office prior toobligation or expenditure of such hinds.

27. The recipient acknowledges that the Office of Justice Programs (OJP) reserves a royalty-free, non-exclusive, andirrevocable license to reproduce, publish, or otherwise use, and authorize others to use (in whole or in pan, including inconnection with derivative works). for Federal purposes: ( I ) any work subject to copyright developed under an awardor subaward; and (2) any rights of copyright to which a recipient or subrecipient purchases ownership with Federalsupport.

The recipient acknowledges that OW has the right to (I) obtain, reproduce, publish, or otherwise use the data firstproduced under an award or subaward; and (2) authorize others to receive, reproduce, publish, or otherwise use suchdata for Federal purposes. "Data" includes data as defined in Federal Acquisition Regulation (FAR) provision 52.227-14 (Rights in Data - General).

It is the responsibility of the recipient (and of each subrecipient, if applicable) to ensure that this condition is includedin any subaward under this award.

The recipient has the responsibility to obtain from subrecipients, contractors, and subcontractors (if any) all rights anddata necessary to fulfill the recipient's obligations to the Government under this award. If a proposed subrecipient,contractor, or subcontractor refuses to accept terms affording the Government such rights, the recipient shall promptlybring such refusal to the attention of the OJP program manager for the award and not proceed with the agreement inquestion without further authorization from the OJP program office.

28. Grantee agrees to comply with all confidentiality requirements of 42 U.S.C. section 3789g and 28 C.F.R. Part 22 thatare applicable to collection, use, and revelation of data or infonnation. Grantee further agrees, as a condition of grantapproval, to submit a Privacy Cenificate that is in accord with requirements of 28 C.F.R. Pan 22 and, in particular,section 22.23.

29. Prior to developing, producing or engaging in public outreach and education efforts, the recipient is required tocoordinate these activities with BJA's national public awareness campaign partner.

30. The recipient agrees to comply with applicable requirements to report first-tier subawards of $25,000 or more and, incertain circumstances, to report the names and total compensation of die five most highly compensated executives ofthe recipient and first-tier subrecipients of award funds. Such data will be submitted to the FFATA SubawardReporting System (FSRS). The details of recipient obligations, which derive from the Federal Funding Accountabilityand Transparency Act of 2006 (FFATA), are posted on the Office of Justice Programs web site athttp://ojp.govifunding/Explore/FFATA.htm (Award condition: Reporting Subawards and Executive Compensation), andare incorporated by reference here. This condition, and its reporting requirement, does not apply to grant awards madeto an individual who received the award as a natural person (i.e., unrelated to any business or non-profit organizationthat he or she may own or operate in his or her name).

31. Within 120 days of the award date, the recipient shall submit to the Office of Justice Programs a finalizedMemorandum of Understanding (MOW that reflects the goals and objectives of the project and lists the identities.roles, and contributions of the participating agencies. The MOU must be signed by the Chief Executive Officer of eachcollaborating agency. The grantee also agrees to notify the Bureau of Justice Assistance of any change in the status orduties of the collaborating agency partners or individuals.

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SPECIAL CONDITIONS

32. The recipient agrees to comply with OJP grant monitoring guidelines, protocols, and procedures, and to cooperate withBJA and OCFO on all grant monitoring requests, including requests related to desk reviews, enhanced programmaticdesk reviews, and/or site visits. The recipient agrees to provide to BJA and OCFO all documentation necessary tocomplete monitoring tasks, including documentation related to any subawards made under this award. Further, therecipient agrees to abide by reasonable deadlines set by BJA and OCFO for providing the requested documents.Failure to cooperate with BJA's/OCFO's grant monitoring activities may result in sanctions affecting the recipient'sDOJ awards, including, but not limited to: withholdings and/or other restrictions on the recipient's access to grantfunds; referral to the Office of the Inspector General for audit review; designation of the recipient as a DOJ High Riskgrantee; or termination of an award(s).

33. The recipient is authorized to incur obligations, expend, and draw down funds for travel, lodging, and per diem costsonly, in an amount not to exceed S15,000, for the sole purpose of attending a required OJP conference associated withthis grant award. The grantee is not authorized to incur any additional obligations, or make any additional expendituresor draw downs until the awarding agency and the Office of the Chief Financial Officer (OCFO) has reviewed andapproved the recipient's budget and budget narrative, and a Grant Adjustment Notice (GAN) has been issued to removethis special condition.

34. Recipient may not obligate, expend or drawdown funds until the Bureau of Justice Assistance, Office of JusticePrograms has received and approved the required application anachmem(s) and has issued a Grant Adjustment Notice(GAN) releasing this special condition.

35. With respect to this award, federal funds may not be used to pay cash compensation (salary plus bonuses) to anyemployee or the award recipient at a rate that exceeds 110% of the maximum annual salary payable to a member of thefederal government's Senior Executive Service (SES) at an agency with a Certified SES Performance Appraisal Systemfor that year. (An award recipient may compensate an employee at a higher rate, provided the amount in excess of thiscompensation limitation is paid with non-federal funds.)

This limitation on compensation rates allowable under this award may be waived on an individual basis at thediscretion of the OW official indicated in the program announcement under which this award is made.

OW FORM 40002 (REV. 44t0




Washington, D.C. 20531

Memorandum To: Official Grant File

From: Orbin Terry, NEPA Coordinator

Subject: Categorical Exclusion for City of Los Angeles

The Intellectual Property Enforcement Program is designed to provide national support and improve the capacityof state, local, and tribal criminal justice systems to address intellectual property criminal enforcement, includingprosecution, prevention, training, and technical assistance.Awards under this program will be used to develop national demonstration, training, and technical assistanceprograms. None of the following activities will be conducted whether under the Office of Justice Programs federalaction or a related third party action:

(1) New construction.(2) Renovation or remodeling of a property either (a) listed on or eligible for listing on the National Register ofHistoric Places or (b) located within a 100-year flood plain.(3) A renovation which will change the basic prior use of a facility or significantly change its size.(4) Research and technology whose anticipated and future application could be expected to have an effect on theenvironment.(5) Implementation of a program involving the use of chemicals.

Consequently, the subject federal action meets the Office of Justice Programs' criteria for a categorical exclusionas contained in paragraph 4(b) of Appendix D to Part 61 of the Code of Federal Regulations. Additionally, theproposed action is neither a phase nor a segment of a project which when reviewed in its entirety would not meetthe criteria for a categorical exclusion.

Los Angeles Police Department

FY 2016-2018 Intellectual Property Crime Enforcement Program Application

Reducing and Preventing Intellectual Property Crime

in the City of Los Angeles

INTRODUCTION

In 2004, the Anti-Piracy Unit (APU) was created in the Los Angeles Police Department

(LAPD), and has since served as a national role model in aggressive intellectual property (IP)

enforcement efforts and collaborations, including a successful partnership with the LA City

Attorney's Office (LACA). With new grant funding, the LAPD APU and the LACA propose to

expand and enhance current enforcement efforts by simultaneously addressing both the supply

and demand sides of counterfeiting through new data collection and analysis strategies and

enhanced public awareness of IP crime as well as adapt to the evolving methods in sales of IP

products through social media and other websites to effectively and efficiently reduce IP crime.

IP crime enforcement efforts have evolved over the years from a primarily local street level

focus to a multi-faceted local, state, national and international level, involving not only a

physical location, but also web-based transactions in which it makes it difficult to trace the origin

of the packages. This change in dynamic is making it more difficult than ever for detectives and

prosecutors to solve and prosecute IP related crimes. In addition, gangs and organized crime are

transitioning from the sales of narcotics which carry a harsher penalty if caught and can be more

dangerous to sell, to the sales of IP merchandise such as CDs, DVDs, hand bags, etc., which

result in a lesser penalty if caught as their source of income.

1. STATEMENT OF THE PROBLEM

The LAPD is the third largest police agency in the nation. With a staff of nearly 10,000

officers, the LAPD maintains public safety across 21 geographic areas covering 468 square miles

serving a population of 3,928,864 residents'. With two ports and an international airport, LA is

Census Quick Facts (2014), found at. httul/www.census.aosSauickfactsgable/PST045215/0544000.

Page 1 of 15



widely acknowledged an epicenter of counterfeit activity in the United States, particularly in the

downtown "Santee Alley" region. The International Anti-Counterfeiting Coalition ("IACC")

estimates that the annual fiscal impact of counterfeit crimes to the City of Los Angeles (LA)

totals $17 million in lost state income taxes and sales taxes? LA's flourishing black market

diverts an estimated $2 billion from the County's retail sector, costing 106,000 jobs and $5

billion in wages.3

Suspects today have evolved from blatant store front sales to more Internet based sales

making the investigation significantly more complex, utilizing more man hours to author search

warrants to retrieve subscriber and/or cell phone GPS location related information. With the use

of the Internet, the suspects mask their true identity, making it difficult for law enforcement to

investigate.

Counterfeit Supply Side

On the supply side, local law enforcement and private industry spends millions of dollars

annually combating the sale of counterfeit pharmaceuticals, apparel, electronics, and

entertainment media. Coordinated through a robust task force comprised of federal, state and

local partners, LAPD APU and LACA enforcement strategies target individuals for arrest and

employ prosecutorial strategies that involve direct criminal case filings and civil counterfeit

abatement suits. While these initiatives have succeeded disrupting the flow and sale of more

than $100 million dollars in counterfeit goods during the past three years, highly motivated

sellers (who have the potential to earn $5,000+ a day peddling counterfeit goods) have adapted

their tactics to avoid detection by constantly moving locations and creating new websites in

response to stepped up enforcement efforts. This is not just a local IP problem, it has national

Negative alive Consequences of International Intellectual Property Theft: Economic Harm, Threats to the Public Health and safety, and Links to

Organized Crime and Terrorist Organizations International Anti-Counterfeiting Coalition, Inc (2005).

'A False Bargain: The Los Angeles County Economic Consequences of Counterfeit Products Los Angeles Economic Development Corporation

(2007).

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FY 2016-2018 Intellectual Properly Crime Enforcement Program Application

and international implications as counterfeit goods sales are used to fund terrorist activities,

which in turn leads to a much larger homeland security issue.

Counterfeit Demand Side

On the demand side of the counterfeit equation, new buyers continuously enter into the

counterfeit market to save money without any knowledge of the harm nested within each

purchase. Education is an unalterable pillar associated with IP enforcement. The need for

sustained community outreach remains to educate the public regarding the risks associated with

counterfeit goods, including associated serious and potentially fatal health hazards, how

counterfeit profits relate back to organized crime, including gang crime and terrorism, and its

broader impact on legitimate businesses.

FY 2016-18 grant funding will ensure the supply and demand side of counterfeit sales is

addressed. The LAPD APU/LACA IP theft partnership will span the following:

• Chronic IP Crime Locations , Social Media sites. and Ring-Leaders

Using crime and case filing data, the LAPD APU/LACA will focus on Ring-Leaders who

have previously engaged in IP crimes. The allure of easy money and minor punitive

consequences from selling counterfeit products continues to draw primary offenders back to LA.

Detectives are finding that former IP criminals move up the supply chain and morph from small-

scale vendors into highly-organized networks — hiring more people, renting warehouse space,

becoming major distributors, and transporting whole containers. To break the cycle and stop IP

crime permanently, LA will need to enhance public and private partnerships to address these

issues and combat crime from all aspects and levels. The Anti-Piracy Unit estimates that 75% of

arrestees have prior violations (either via police arrest or cease and desist letter). Of this arrestee

Page 3 of 15

FY 2016-2018 Intellectual Property CLos Angeles Police Department

Enforcement Program Application

group, 25% move up and become more sophisticated and highly-organized criminals, involving

more people and resources to sustain the lucrative income of this criminal activity.

To illustrate this organized layer of ring-leaders, in 2012 a small tobacco shop owner was

first arrested for selling counterfeit/non-taxed cigarettes from an automobile trunk. In September

2015, during a separate tobacco / counterfeit pharmaceutical investigation, the LAPD APU

noticed several boxes containing counterfeit/non-taxed cigarettes were being distributed by the

same suspect's name. Armed with this information given by individuals who were purchasing

counterfeit/non-tax cigarettes and counterfeit pharmaceutical drugs, an investigation was

conducted on the same suspect which resulted in the discovery of a well-organized "pick house"

with evidence valued at $6 million dollars and cash recovery of over $150,000 dollars.

Surprisingly, this same individual who was arrested in 2008 was now responsible for organizing

the entire Central/Southern California network of distributing counterfeit/un-taxed cigarettes and

counterfeit pharmaceutical drugs profiting over $600,000 dollars a month.

In LA, felony IP convicts historically receive active probation instead of prison time

regardless of the amount of property recovered by police. Court sentences typically only include

community service, probation, or restitution/fines. Although LACA and the LAPD APU push for

tougher sentences, LA area courts often dismiss IP cases "in furtherance of justice" — closing out

cases in the interest of time as IP cases are typically complex and require lengthy trials. With

current overcrowding across California jails and prisons, convicted IP criminals are typically

released early as a result of Assembly Bill 109. When convicted criminals re-enter the

community, there are few, if any, legal options that will support, the lifestyle they previously

enjoyed. Detectives estimate that the average monthly income for counterfeit distributors is

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TT 2016-2018 Intellectual Property Crime Enforcement Program Application

$60,000 to $150,000. Due to these financial incentives, lax penalties, and the knowledge gained

through experience, it is not surprising that IP crimes continue to occur and flourish.

• Changing Trends in IP Crime

The LAPD APU has seen convicted offenders develop highly sophisticated, connected and

unconventional networks very quickly. Detectives believe that the lucrative financial gain in

selling counterfeit products, especially in the ongoing challenging economy, the lack of severe

punishment post-arrest and ever increasing demand for counterfeit goods from the public has led

many criminals to remain or become re-involved in IP crime. Detectives have seen numerous

examples of gangs who have moved from dealing drugs to committing IP crimes. The cost to

profit ratio is much larger in counterfeiting and the penalties much more lax than dealing drugs.

When detectives interviewed documented gang members arrested for selling counterfeit goods,

they often say selling counterfeit goods do not attract law enforcement and they could profit

more money than committing other crimes. The importance of strategic and tactical coordination

with LAPD APU IP Crime Task Force partners such as LACA and federal agencies such as the

Federal Bureau of Investigation (FBI), Homeland Security Investigations (HSI) and the U.S.

Customs and Boarder Protection (CBP), in enforcing IP laws is even more critical to cripple

criminal networks.

Victims of IP crime are not just the brand owners and businesses, but they are the community

as well in that IP crime affects the economy, quality of life, health and taxes. Piracy and

counterfeiting in LA have created an illegal underground economy that has diverted $2 billion

from the legitimate retail sector, costing 106,000 jobs, $5 billion in wages, and depriving the

State and local governments of nearly $500 million in tax revenue (2007 LA Economic

Page 5 of 15



Development Corporation study: A False Bargain). The demand side of IP crimes needs to be

addressed because IP crime would not exist if no one purchased illegal goods.

• The Expanded Marketplace for Counterfeit Goods in the LA Region.

We will expand our focus to include national as well as international crime. IP crime has

linkages to terrorist activities. The APU recently found that 1P criminals are transitioning the

shipment of counterfeit goods from the ports to the airport. Counterfeit shipments are now

coming through LA International Airport (LAX) as the Port of LA has done such an outstanding

job intercepting illegal shipments.

2. PROJECT DESIGN AND IMPLEMENTATION

The LAPD Anti-Piracy Unit working in partnership with the LACA, propose a multi-faceted

approach to continue to reduce and prevent IP crime in LA. The long-term goal of the LAPD

APU and LACA is to reduce the supply of and demand for pirated merchandise and counterfeit

activities in LA so significantly that one day, little if any IP criminal activity will take place here.

In addition, law enforcement will learn to adapt to the suspects' evolving methods in sales of IP

product through social media (Instagram, Facebook, Twitter) and other websites to effectively

and efficiently reduce IP crime.

Objective 1: Reduce the supply side of IP crime by reducing the number of repeat IP crime

offenses and the number of chronic IP crime locations or "hot spots".

The LAPD APU aims to curb recidivism by reviewing cases of individuals who were

previously arrested, but continue to engage in IP crime. In 2015, 140 people were arrested and

convicted for IP crimes city-wide, which will serve as a starting point as all are still on active

probation and at high risk of reoffending. Each case will be reexamined to extract additional

information that may help detectives prevent further repeat IP crimes. The APU, along with the

Page 6 of 15



LA County Probation Department will work together to closely monitor these 140 probationers.

If there is probable cause, more actions will be taken by the LAPD and LA County Probation to

develop new cases and/or warn probationers that they are at risk of violating their probation and

sent to prison. The LAPD APU is requesting funding for overtime for investigators to work with

the LA County Probation Department and on their own to gather intelligence on convicted IP

criminals, organize probation checks, and arrest individuals that have violated probation.

Additionally, in order to prevent new IP crime, detectives will work to 'choke' points in IP

crime distribution networks by adding an extra layer of coordinated criminal and civil

enforcement through direct and indirect IP violations filed by the LACA. This will disrupt the

supply chain of counterfeit goods through direct and indirect IP violations. The objective is to

make it financially painful for IP criminals by imposing fines and negatively affecting those in

their networks such as building owners, front companies, and employees. Once LAPD APU

detectives determine that the IP criminals are violating other laws, they will coordinate with the

LACA to address civil code violations occurring at counterfeit sales "hot spot" locations. Civil

code violations can relate to failure to adhere to employment, health, alcohol, tobacco, and

building rules and regulations. The LACA will file civil actions, known as "abatements," to

target the property owners who knowingly permit counterfeit sales to occur. These abatements

carry significant financial penalties and greatly deter counterfeit sales. Through grant funding,

the LACA will dedicate a vertical prosecutor to enforce street level counterfeit sales by filing

criminal cases. The vertical prosecutor will be centrally located and their duties will include

reviewing, filing and prosecuting IP related criminal cases arising from LAPD APU, as well as

representatives from the IP Task Force (FBI, CBP and Homeland Security) and private

investigators.

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Finally, to further reduce the supply side of IP crime, the LAPD APU detectives will

enhance information sharing with investigative and enforcement efforts through the Regional

Information Sharing Systems (RISS). The RISS allows law enforcement officers to share

information on locations, suspects, current trends and gangs at no cost to the Department. To

promote information sharing, the LAPD APU will establish a cross training program with other

IP units (i.e. NYPD Trademark Unit Detectives) to learn about other innovative techniques in

enforcing IP crimes. The LAPD APU already has an on-going ride-along training program open

to all interested law enforcement agencies to teach investigative techniques on IP crime.

Additionally, LAPD APU will partner with Investigative Consultants (a private investigative

company) to conduct several IP trainings and share current trends, investigative techniques and

technical support to other law enforcement agencies.

Performance Measures: # of hot spot IP crime locations at the start and every quarter throughout

the two years; # of IP crime offenders and number of repeat offenders; # of cases prosecuted at

local, state and federal level; value of assets seized.

Objective 2: Develop and evaluate additional strategies to address the changing trends and

kinds of IP crime and to prevent IP crime linkages to other national/international crimes.

To address the changing trends in IP crimes, law enforcement will adapt their investigations to

the suspects' new methods in sales of IP products through social media (Instagram, Facebook,

Twitter) and other enticing websites. Today's suspects have evolved from blatant store front

sales to more Internet base sales making the investigation more time consuming and complex.

To confront the growing linkage of IP crime and terrorism, the LAPD APU detectives will

continue to work with IP Task Force members who can open state and federal investigations.

Task Force members include the Federal Bureau of Investigation, State of California Board of

Page 8 of 15

FY 2016-2018 Intellectual Property 07


Enforcement Program Application

Equalization, Homeland Security Investigations (HIS/ICE) Airport and Trade-fraud, Department

of Alcoholic Beverage Control (ABC), Department of Labor Standards (DLSE), Employment

Development Department (EDD), New York Police Department (NYPD) Trademark Unit,

Assistant United States Attorney (AUSA) and the Department of Justice Office of the Attorney

General. The LAPD APU detectives have been crossed-deputized as federal U.S. Marshals under

the FBI. This allows detectives to vertically handle both State and Federal investigations related

to IP crimes.

To effectively target the pervasive and large scale counterfeit problem will also require

working a wide variety of public and private industry partners on IP crime prevention and

enforcement. Partners include: the International Anti-Counterfeiting Association, Underwriters

Laboratories, the Recording Industry Association of America, the Motion Picture Association of

America, the International Trademark Association, and various electronic, pharmaceutical and

apparel manufacturers. Partners will vary depending on the investigation and the type of

counterfeit goods investigated.

Performance Measures: Track the # of Internet investigations conducted; Track the # of new

members and new agencies/organizations represented on the Task Force; # of new private

partners working with Task Force and enforcement agencies; track and categorize types of IP

crimes and document changes/reduction; # of tips shared with other agencies; # of prosecutions.

Objective 3: Reduce the demand for IP Crime by educating the public about the economic

and personal dangers of IP crime.

The LAPD will address the demand side by influencing public opinion through education —

for youth, budget-minded consumers and business owners — to prevent, deter and identify

criminal violators of IP laws as well as alter the consumer's buying habits. The Anti-Piracy Unit

Page 9 of 15



believes that once the public is aware of the dangers that counterfeit products pose, they will be

more inclined to report IP crimes and cooperate with law enforcement, thus reducing the demand

for counterfeit products. The LAPD APU will continue to partner with Crime Stoppers and the

FBI to develop more public service announcement (PSA) for distribution on local television,

radio and in movie theaters. The 2015 PSAs addressed the use of counterfeit pharmaceutical

drugs, electronic devices, and streaming/downloading movies. The new PSAs will target the

consumers and business owners that may be unknowingly selling counterfeit goods.

The LAPD APU, in collaboration with the LACA vertical prosecutor, will develop and

implement an educational campaign to change public perception by raising awareness of the

risks of counterfeit products and consequences of participating in the counterfeit marketplace.

This information will be conveyed at local elementary and junior high schools and even to

students enrolled in the LAPD cadet/Citizen's Police Academy. Student presentations will offer

the truths of IP crime, including the transition from store front sales to Internet base sales, nexus

to gangs, organized crime and even terrorist groups. During the 2016-18 school years, the APU

will conduct presentations at middle schools, local colleges, in-service trainings, as well as to

outside agencies. LAPD APU and LACA will continue to provide training to law enforcement

and prosecutors regarding IP enforcement best practices.

Performance Measures: Track the #/kinds of groups targeted by education; #/kinds of community

activities; Collect and analyze training evaluation; # of PSAs conducted.

Objective 4: Prevent IP crime displacement by sharing best practices.

The LAPD APU and the LACA will work together to develop a final report at the end of

the grant period detailing their strategies and outcomes. The report will also include concrete

recommendations for how to train and replicate successful aspects of the LAPD model in other

Page 10 of 15



jurisdictions. In addition, these findings will be presented at national police conferences

including the International Association of Chiefs of Police forum, Police Executive Research

Forum and USDOJ meetings.

Performance Measures: # of jurisdictions receiving final report via website, mail, conferences;

# of articles about the LA program in national policing and prosecution publications;

# presentation requests

3. CAPABILITIES/COMPETENCIES

Since the establishment of the Anti-Piracy Unit in 2004, the LAPD APU has been involved

in more than 1,800 IP cases, some of which have led to the arrest and conviction of known

terrorist groups for manufacturing and sales of counterfeit products. The unit has also received

over 600 hours of training from brand owners, including, Louis Vuitton, Rolex, Underwriters

Laboratories Inc., Merck and Proctor & Gamble on various methods of identifying counterfeit

goods.

In 2010, the LAPD APU was recognized by the U.S. IP Enforcement Coordinator,

Executive Office of the President of the United States for a 192% increase in arrests from a year

prior to June 2010, through BJA grant funding. The graph summarizes accomplishments as well

as reflects a dip in the arrests and search warrants served when LAPD did not receive 2012-2013

BJA IP crime grant funding. The LAPD

APU and LACA had hoped to incorporate 160140

the costs of successfully fighting IP crime in 220100

to our respective budges, but due to the

slower than anticipated recovery throughout

the LA region from the Recession and

80 Search

Warrants60 Served

40

20 IP

0arrests

Arrests2010 2011 2012 2013 2014 2015

Page 11 of 15

Los Angeles Police DepartmentFY 2016-2018 Intellectual Property Crime Enforcement Program Application

increased health care and pension costs for City employees, we were unable to do so. In

addition, combating IP crime has become so complex and requires not only street level

enforcement and prosecution skills, but also the ability to address and combat it at the cyber level

which requires more experience, training and time and can cross the national and international

levels.

The LAPD APU successfully implemented 2014-2016 grant program that provided needed

overtime funding to the Unit for complex IP cases that resulted in the removal of $122,590,340

worth of counterfeit products from the streets of LA. This represents 811,312 pieces of products

that include CDs, DVDs, purses, wallets, clothes, food, pharmaceutical drugs, auto parts and

other intellectual property.

The LAPD APU was featured on ABC 20/20, Good Morning America, syndicated Crime

Watch Daily and several local news stories in 2015, which discussed the severity of this

lucrative crime and the financial gain criminals are profiting from. The show featured the

LAPD's APU during the service of search warrant operations targeting major distributors of

counterfeit pharmaceutical drug, apparel, and other products in the Downtown LA area.

Due to these successes, the international community recently sought the expertise of the

LAPD APU. In 2015, detectives from the unit were invited by the Dubai Police Department to

train and learn innovated techniques utilized to enforce IP crimes in LA. In 2009, detectives

from the unit were invited by the Korean Consulate in LA to train government and private

organizations in Seoul on anti-piracy tactics. In 2010, the U.S. Consulate in Brazil invited the

LAPD APU, together with FBI and NYPD, to train Brazilian law enforcement on anti-piracy

strategies in preparation for the 2014 World Cup and 2016 Summer Olympics in Rio de Janeiro.

Also, Detective Rick Ishitani, a Unit supervisor, was invited to speak at the 2015 N1J Intellectual

Page 12 of 15


Property Forum as well as actively participate in various conferences throughout the U.S. hosted

by the National White Collar Crime Center.

The LAPD has many years of experience in managing federal grants. The LAPD has been

awarded and has successfully managed grants ranging from $100,000 to $2,000,000 from

various federal entities including FEMA, NIJ and WA. The LAPD has also worked extensively

with our partners in the LA Mayor's Office and other city agencies managing Department of

Homeland Security grant funding. The LAPD Grants Unit manages and reports on over 25 active

grants.

As an agency of approximately 450 attorneys, the LACA has both civil and criminal IP

enforcement capabilities. On the criminal side, the LACA prosecutes misdemeanor violations of

state IP laws including trademark and copyright violations. Deputy City Attorneys have

reviewed more than 1,500 counterfeit related cases referred by law enforcement partners and

prosecuted in excess of 1,200 cases, with a success rate of approximately 90%. The LACA is

also a nationally recognized leader, having pioneered abatements as a powerful crime

suppression tool dating back to 1990. The California District Attorneys Association, the

National District Attorneys Association and the National Association of Community Prosecutors,

along with law enforcement agencies nationwide regularly seek LACA abatement attorneys as

featured speakers to train prosecutors and police about property abatements. The LACA has

evaluated in excess of 3,000 properties for nuisance abatement remedies and filed over 2,100

abatement lawsuits, with a 90% success rate. Since 2009, the Counterfeit Abatement Prosecutor

has secured $34,000,000 in judgments against chronic LA counterfeiters. This work has been

highlighted by the White House's Office of the US IP Enforcement Coordinator and trade

publications.

Page 13 of 15


4. IMPACT/OUTCOMES, EVALUATION AND PLAN FOR COLLECTING DATAFOR PERFORMANCE MEASURES

In addition to measuring the number of hot spot IP crime locations at the start and every

quarter throughout the two year grant period, the number of IP crime offenders, number of repeat

offenders and number of cases prosecuted at local, state and federal level, Project Manager

Detective Rick Ishitani will track the number of pieces and the value of assets seized. Additional

detailed operational day-to-day data including the number of probation checks and arrests made

will be tracked as well. All items recovered will be documented on a spreadsheet and

calculations will be made to demonstrate the effectiveness of the increased intelligence gathering

efforts. This information will be shared at monthly task force meetings and distributed on a

quarterly basis to stakeholders and federal partners in the form of a newsletter. Program

effectiveness will be measured by showing an increase in arrests made, search warrants served

and pieces recovered.

To strengthen investigation efforts, specific details of all arrestees will be collected on the

Vice Information Card ("I-Card"). This card information includes a recent photograph, personal

and employment information, criminal history, known associates and hangouts, and contact with

law enforcement and are stored in a locked file cabinet. I-Cards help investigators keep track of

potential criminal activities, behaviors, and networks after arrestees have been convicted. The

Anti-Piracy unit updates these records by cross-referencing databases such as the Consolidated

Criminal History Reporting System and from information collected by LAPD vice units.

To assess information sharing information activities and providing technical assistance to

task force members, other local and regional law enforcement entities, the LAPD APU will

document the number of meetings conducted with other law enforcement, criminal justice and

Page 14 of 15


government agencies, operations conducted with the ABC unit, entries made into the RISS

system, the agencies cross trained and the cases prosecuted at the federal level.

In order to measure the effectiveness of the goal to reduce demand, the LAPD APU will

track and document the number of presentations conducted at the local elementary and junior

high schools as well as the number of students trained through the LAPD Cadet/Citizens

Academy. In addition, the number of PSAs developed and aired on radio and television will be

tracked.

5. SUSTAINMENT

The LAPD will continue to work with the LA Police Foundation to aggressively pursue

external grant funding in order to sustain our accomplishments in future years. The LA Police

Foundation is an independent, not-for-profit organization that provides critical resources and

vital support to the LAPD. The LA Police Foundation will assist in continuous airing of the

PSAs and work to acquire additional in-kind media donations for IP crime reduction and

prevention efforts.

LA is slowly catching up to the rest of the nation's successful recovery from the Recession

and anticipates being able to incorporate the costs of our successful IP crime fighting strategies

in the Fiscal Year 2017 LAPD budget to attempt to sustain the same productivity attained while

operating under the grant. When our long term goal of making it unprofitable to engage in IP

crime in LA comes to fruition and the number of IP crimes decline, staffing in the IP unit will be

reassessed.

Page 15 of 15

OMB APPROVAL NO. 1121-0188EXPIRES 3-2013 (Rev. 1/97)

Budget Detail WorksheetPurpose: The Budget Detail Worksheet may be used as a guide to assist you in the preparation of

the budget and budget narrative. You may submit the budget and budget narrative using this form or in

the format of your choice (plain sheets, your own form, or a variation of this form). However, all

required information (including the budget narrative) must be provided. Any category of expense not

applicable to your budget may be deleted.

A. Personnel - List each position by title and name of employee, if available. Show the annual

salary rate and the percentage of time to be devoted to the project. Compensation paid for employees

engaged in grant activities must be consistent with that paid for similar work within the applicant

organization.

Name/Position Computation

LARD Supervisor (1) overtime

LAPD Investigators (5) overtime

Deputy City Attorney II

$100/hour x 4.729 hours/month x 24 months

$78/hour x 24 hours/month x 24 months x 5

$91,876 x 42.809% (.42809 FTE) x 2 years

Cost

$11,350.00

$224,640.00

$78,663.00

SUB-TOTAL $314,653.00

B. Fringe Benefits - Fringe benefits should be based on actual known costs or an established

formula. Fringe benefits are for the personnel listed in budget category (A) and only for the

percentage of time devoted to the project.

Name/Position Computation Cost

SUB-TOTAL $0.00

Total Personnel & Fringe Benefits $314,653

OJP FORM 7150/1 (5-95)

C. Travel - Itemize travel expenses of project personnel by purpose (e.g., staff to training, field

interviews, advisory group meeting, etc.). Show the basis of computation (e.g., six people to 3-day

training at SX airfare, $X lodging, $X subsistence). In training projects, travel and meals for trainees

should be listed separately. Show the number of trainees and the unit costs involved. Identify the

location of travel, if known. Indicate source of Travel Policies applied, Applicant or Federal Travel

Regulations.

Purpose of Travel Location Item Computation Cost

TOTAL $0.00

D. Equipment - List non-expendable items that are to be purchased. Non-expendable equipment

is tangible property having a useful life of more than two years and an acquisition cost of $5,000 or

more per unit. (Note: Organization's own capitalization policy may be used for items costing less than

$5,000). Expendable items should be included either in the "supplies" category or in the "Other"

category. Applicants should analyze the cost benefits of purchasing versus leasing equipment, espe-

cially high cost items and those subject to rapid technical advances. Rented or leased equipment costs

should be listed in the "Contractual" category. Explain how the equipment is necessary for the success

of the project. Attach a narrative describing the procurement method to be used.

Item Computation Cost

TOTAL $0.00

E. Supplies - List items by type (office supplies, postage, training materials, copying paper, andexpendable equipment items costing less that $5,000, such as books, hand held tape recorders) andshow the basis for computation. (Note: Organization's own capitalization policy may be used foritems costing less than $5,000). Generally, supplies include any materials that are expendable orconsumed during the course of the project.

Supply Items Computation Cost

TOTAL $0.00

F. Construction - As a rule, construction costs are not allowable. In some cases, minor repairs orrenovations may be allowable. Check with the program office before budgeting funds in thiscategory.

Purpose Description of Work Cost

TOTAL $0.00

G. Consultants/Contracts - Indicate whether applicant's formal, written Procurement Policy orthe Federal Acquisition Regulations are followed.

Consultant Fees: For each consultant enter the name, if known, service to be provided, hourly or dailyfee (8-hour day), and estimated time on the project. Consultant fees in excess of $450 per day requireadditional justification and prior approval from OJP.

Name of Consultant Service Provided Computation Cost

Subtotal$0.00

Consultant Expenses: List all expenses to be paid from the grant to the individual consultants inaddition to their fees (i.e., travel, meals, lodging, etc.)

Item Location Computation Cost

Subto al $0.00

Contracts: Provide a description of the product or service to he procured by contract and an estimateof the cost. Applicants are encouraged to promote free and open competition in awarding contracts.A separate justification must be provided for sole source contracts in excess of $100,000.

Item Cost

Subtotal $0.00

TOTAL $0.00

H. Other Costs - List items (e.g., rent, reproduction, telephone, janitorial or security services,and investigative or confidential funds) by major type and the basis of the computation. For example,provide the square footage and the cost per square foot for rent, or provide a monthly rental cost andhow many months to rent.

Description Computation Cost

TOTAL $0.00

I. Indirect Costs - Indirect costs are allowed only if the applicant has a Federally approved indirectcost rate. A copy of the rate approval, (a fully executed, negotiated agreement), must be attached. Ifthe applicant does not have an approved rate, one can be requested by contacting the applicant'scognizant Federal agency, which will review all documentation and approve a rate for the applicantorganization, or if the applicant's accounting system permits, costs may be allocated in the direct costscategories.

Description Computation Cost

TOTAL$0.00

Budget Summary- When you have completed the budget worksheet, transfer the totals for each

category to the spaces below. Compute the total direct costs and the total project costs. Indicate the

amount of Federal requested and the amount of non-Federal funds that will support the project.

Budget Category Amount

A. Personnel$314,653.00

$0.00B. Fringe Benefits

$0.00C. Travel

$0.00D. Equipment

$0.00E. Supplies

$0.00F. Construction

$0.00G. Consultants/Contracts

$0.00H. Other

$314,653.00Total Direct Costs

$0.00I. Indirect Costs

$314,653.00TOTAL PROJECT COSTS

Federal Request$314,653.00

$0.00Non-Federal Amount

intradepartmental correspondence october 13, 2016 … · office of justice programs office of the...

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