FINLAND: 2006 ANNUAL TRAFFICKING-IN-PERSONS REPORT

UNCLAS SECTION 01 OF 09 HELSINKI 000182

SIPDIS

SENSITIVE

STATE FOR G/TIP, G, INL, DRL, PRM, IWI, AND EUR/NB

E.O. 12958: N/A
TAGS: PHUM SOCI SMIG PGOV KCRM ELAB KWMN ASEC KFRD PREF FI
SUBJECT: FINLAND: 2006 ANNUAL TRAFFICKING-IN-PERSONS REPORT

REF: A. STATE 03836


B. 05 HELSINKI 01277

C. 05 HELSINKI 00353


1. (SBU) The following responses are keyed to the checklist
in ref A. Embassy Helsinki's point of contact on TIP is
Political Officer David Allen Schlaefer;
SchlaeferDA2@state.gov; 358-09-6162-5482 or
358-050-322-7923. The Embassy estimates that 80 hours of
time were spent preparing this report.

Overview of Trafficking in Finland
--------------

2. (SBU) A: Finland is a transit and destination country
for trafficked men, women, and children; it is not a source
country. There are no reliable estimates as to the actual
incidence of TIP in Finland, and there have been no
systematic studies of the phenomenon. The GoF has agreed to
fund a comprehensive IOM survey of trafficking in Finland;
IOM expects to begin this project in the summer of 2006.
Past estimates of the incidence of TIP in Finland appear to
have been inaccurate due to conflation of organized
prostitution/trafficking, and to circular reporting within
the GoF and the NGO community. The GoF identified 15 likely
TIP victims during the reporting period; however, it is
believed that the number of victims trafficked through
Finland to elsewhere in Europe (and, in some cases, even the
United States) may be higher. Most victims trafficked
through Finland are probably women and girls destined for
western Europe's commercial sex industry and come from
Russia, China, and, to a lesser extent, Moldova and the
Caucasus.


3. (SBU) B: There is strong political will at the highest
levels to combat TIP. Law enforcement officials believe
trafficking patterns through Finland have changed in recent
years. The Criminal Intelligence Division of Finland's
National Bureau of Investigation (NBI) reports that Estonian
organized crime syndicates formerly engaged in trafficking
and prostitution are no longer active in these areas;
however, they remain active in narcotics smuggling. Finnish
officials attribute this to Estonia's entry into the EU and
pending entry into the Schengen region, as well as economic
development within Estonia. Overall, the number of Estonian
women working as prostitutes in Finland has dramatically
decreased. Russian organized crime syndicates remain active
in trafficking and prostitution. Although there are no "red
light" districts in Finland, there are a handful of
nightclubs and casinos in larger cities such as Helsinki,
Turku, and Tampere that are run by or associated with the
Russian mafia. Russian women work as prostitutes inside
these nightclubs. Finnish authorities and NGOs believe some
of the women working in these clubs may have been trafficked;
the women were aware that they were coming to Finland to work
as prostitutes, but after arrival the "rules" are changed and
they receive less compensation and are pressured to see more
clients than anticipated. It is believed that economic
coercion and exploitation of women with limited financial
resources plays a larger role than physical coercion in the
recruitment and retention of these women by the crime
syndicates.


4. (SBU) B, cont.: Despite the presence of Russian
criminal organizations in Finland, the actual number of TIP
victims inside the country appears low. However, Finnish
police are increasingly concerned about the transit dynamic,
particularly trafficking from Asia. According to police,
Chinese snakehead gangs have begun to use expanded air routes
to Helsinki's Vantaa Airport from Beijing, Shanghai, and
Bangkok for human smuggling and trafficking. Migrants and
TIP victims then change planes and fly to their destinations
elsewhere in the Schengen Region. Since the travellers
usually have valid visas for their onward destinations and --
even in TIP cases -- are often uncooperative when referred to
secondary inspection, it is difficult for Finnish Frontier
Guard and Customs officials to intercept them. More than 100
presumed smuggled migrants have been stopped at Vantaa
Airport during the past year and referred to asylum and
refugee processing centers. (NOTE: These migrants have an
opportunity to claim asylum before deportation proceedings).
Since Finnish reception centers are "open," almost all of the
referred Chinese persons subsequently disappeared from the
shelters, usually within 24 hours of arrival. It is presumed
that they continued on toward their destination by ferry.
Ten Asians (Chinese and Thai) were intercepted at Vantaa and
presumed to be TIP victims. Seven of the 10 were minors.
These victims were taken into protective custody and housed
in separate facilities at a government refugee reception
center. After having been given an opportunity to remain at
least temporarily in Finland, they chose to return to China.


5. (SBU) B, cont.: The March-April 2005 case (see ref C)
of a busload of Georgian women attracted considerable
attention in Finland and Georgia. The bus was intercepted at
the Finnish-Russian border, and the women on board were
subsequently housed at a reception center run by the Labor
Ministry until their return to Georgia. The women were
uncooperative with police and, although offered the
opportunity to remain at least temporarily in Finland, asked
to be returned immediately to Georgia. Georgian (and some
Finnish) media criticized the GoF's handling of the case,
accepting the women's' claim that they were tourists
travelling to Italy, and alleging that they would now face
stigmatization and humiliation in Georgia as presumed
prostitutes. Finnish officials maintain that the women were
illegal migrants being smuggled to Italy to work as
domestics, and that the bus in question was only the latest
in a series of similar incidents in which tourist buses were
used to transport both smuggled migrants and TIP victims
through Finland and into the EU. Subsequent to the incident,
Finnish authorities report that the "Georgian bus" phenomenon
has ceased, and that the organizers and traffickers have
apparently chosen to bypass Finland and attempt alternate
routes into the EU.


6. (SBU) B, cont.: Labor Ministry officials are concerned
about labor trafficking to Finland. The incidence of such
activity is unknown, but the GoF believes that some smuggled
workers in the construction industry could be exploited after
arrival in Finland. The ministry has formed a special
working group together with trade union officials to
investigate the situation. The group's initial report is due
in May 2006. The GoF also believes a smaller number of
Asians may be forced to work in unacceptable conditions in
restaurants and as domestic workers (employed by Asians,
often with family ties to the victims). Finnish police
report that investigating such cases is very difficult
because of the closed nature of the small Asian community in
Finland, language barriers, and the unwillingness of victims
or witnesses to cooperate with Finnish authorities.


7. (SBU) C: Corruption is not a problem in Finland. Law
enforcement and legal authorities suffer from some
underfunding due to budget constraints.


8. (SBU) D: The GoF has an interagency TIP working group
that meets regularly and monitors all aspects of the
government's anti-TIP efforts. The working group is
currently monitoring the implementation of the 2005 National
Action Plan (NAP). The GoF releases periodic statements
about its anti-TIP efforts, as well as disseminating
information through multilateral organizations like the
Nordic-Baltic Task Force Against Trafficking. GoF
representatives brief NGO-sponsored seminars and meetings on
trafficking.


Prevention
--------------

9. (SBU) A: The GoF acknowledges the trafficking problem
and has taken proactive steps to combat it.


10. (SBU) B: The GoF's interagency working group is
composed of representatives from the Ministries of Foreign
Affairs, Labor, Interior, Justice, Social Affairs, and
Education, and from the Frontier Guard, Customs Service, and
National Bureau for Investigation. The Labor and Interior
Ministries have the lead and rotate every six months as
chair. Mervi Virtanen, the Director of International
Relations at the Labor Ministry, is the current chairperson.


11. (SBU) C: Within Finland, the Social Affairs Ministry
has the lead on domestic prevention programs. The programs
are primarily geared toward demand reduction, especially
Finns who might travel abroad to engage in sex tourism.
During the reporting period, posters and other media
targeting clients and challenging the view that sex tourism
is a "victimless" crime have been displayed at
ports-of-entry, post offices, and other locations. A
separate information campaign running from 2003-2006 in
northern Finland aims to discourage clients and advise
Russian women that they can seek help from Finnish
authorities. Similar campaigns are underway in Finnish
Karelia and in Oulu. The Education Ministry includes
education about trafficking in its curriculum for high school
students. The GoF also funds an NGO-operated hotline for TIP
and domestic violence victims.


12. (SBU) C, cont.: Finland's largest prevention projects
are outside its borders, aimed at creating economic
opportunities for at-risk women and girls before they are
caught up in the trafficking dynamic. Projects that are
currently being funded by the GoF include:

Russia:

-- Finland is a main contributor to a Nordic-Baltic Task
Force Against Trafficking project in Murmansk focused on
providing education, information, and economic opportunities
for at-risk women.

-- In St. Petersburg, Finland has funded a 400,000 Euro
ILO-IPEC (International Program for the Elimination of Child
Labor) program to combat the abuse of homeless children
preyed on by traffickers and sexual predators. The program
runs from 2005-2007.

-- In Moscow, Finland has funded a similar 300,000 Euro
ILO-IPEC program to combat the abuse of homeless children
at-risk for trafficking. The program also runs from
2005-2007.

-- In Kaliningrad, Finland has funded a 151,040 Euro IOM
project called "Trafficking Assessment and
Counter-trafficking Capacity Building for the Kaliningrad
Oblast." The aim of the project is to prepare an extensive
study on human trafficking in the region and promote
cooperation among local judicial, police, and NGO actors to
combat TIP. The project runs through the end of 2006.

-- In Russian Karelia, Finland is currently financing an
anti-TIP project parallel to the one described in para 11 on
the Finnish side of the border.

Ukraine:

-- Finland is currently financing an NGO project that
includes a hotline and video spots targeting TIP victims.
Informational seminars were also conducted by the same
project in several areas of the country, including video
presentations at schools. To date, the GoF has provided
32,376 Euro for the project, operated by the "La Strada
Ukraine" NGO.

Moldova:

-- In 2004, Finland provided 1 million Euro to IOM for an
ongoing multi-year anti-trafficking project; the grant was
the single-largest grant to an NGO in Finnish history.

-- Finland is currently financing a project by the
International Helsinki Foundation (IHF) that aims to combat
human trafficking through a combination of police training
and education campaigns for women's rights.

Multilateral Prevention Efforts:

-- In addition to the above projects, Finland plays an
active role in the anti-TIP efforts of the Nordic-Baltic Task
Force Against Trafficking, the Council of Baltic Sea States,
the Barents Euro Arctic Council, and provides additional
funding to these organization's projects.


13. (SBU) D: See response in para 12 above.


14. (SBU) F: Finland is a social welfare state where the
government is expected to assume responsibility for many
services that elsewhere are largely provided by NGOs. As a
result, there are no NGOs exclusively working on TIP, and
only a few that address it among other issues of concern to
women. Finnish NGOs receive almost all of their funding from
the GoF with few restrictions on their activity; however,
Finnish NGOs in the past have been critical about the GoF's
response to the problem. This began changing in 2004-2005
when NGOs were invited to participate in drafting the
country's National Action Plan on TIP. Relations have now
considerably improved. The Labor Ministry has formed a
partnership with two NGOs to refer victims whenever possible
from government-run shelters to NGO-run shelters. NGO
representatives are also participating in police training
programs on victim identification. Finn Church Aid, the
Finnish Lutheran Church's assistance organization, has formed
a particularly close collaborative relationship with the GoF.


15. (SBU) G: Finnish law enforcement authorities monitor
immigration patterns and screen applicants at ports-of-entry
for TIP victims. Given the close geographic proximity of St.
Petersburg to the Finnish border, Finnish consular officers
face a difficult task in screening visa applicants. Russian
applicants with modest resources may still credibly claim
they intend to make a short, inexpensive visit to Finland for
shopping or to visit friends, making adjudication tricky. In
response, the MFA in late 2005 designed a training program to
teach Finnish officers to better detect trafficking
situations as well as how to follow up when TIP is suspected
(rather than simply refuse the visa). The program was
developed in cooperation with the Frontier Guard.


16. (SBU) H: See para 10 above.


17. (SBU) J: Finland's National Action Plan was formally
adopted in April 2005. The interagency working group is
responsible for its implementation. The plan calls for a
victim-centered approach to TIP. NGOs were a part of the
working group that drafted the plan. The NAP has been widely
disseminated in Finnish society and was kicked off with a
press conference by Foreign Minister Erkki Tuomioja. As part
of the overall implementation process, each agency
represented in the working group in late 2005 developed its
own internal implementation plan for its areas of
responsibility.

Investigation and Prosecution of Traffickers
--------------

18. (SBU) A: Trafficking-in-persons for both sexual
exploitation and forced labor is illegal. The definition of
trafficking used in the law mirrors that of the Palermo
Protocol. The maximum penalty for trafficking is up to 7
years, allowing Finnish law enforcement authorities to use
electronic surveillance techniques when investigating TIP
cases. Trafficking of minors is considered an aggravated
offense, and penalties could be higher. Related offenses
such as human smuggling, kidnapping, pimping, pandering, and
child rape can and have been used to prosecute traffickers.
Finnish prosecutors have successfully prosecuted Finnish
citizens who travelled abroad to have sex with minors
(Thailand and Estonia). These laws are adequate to cover the
full scope of trafficking.


19. (SBU) B: See para 18 above.


20. (SBU) C: The maximum penalty for rape is 7 years, the
same as that for trafficking. An aggravated offense could
carry a longer penalty.


21. (SBU) D: Prostitution is legal, but the sale and
purchase of sex in public is illegal. The law is interpreted
in such a way that brothels or other clubs with sex on
premises are prohibited. There are no "red light" districts
in Finland. Pimping, pandering, and organized prostitution
are illegal. The laws are generally enforced in practice,
and there are periodic raids on nightclubs where prostitutes
are known to operate to enforce the prohibition on public
commercial sex. Most "Finnish" prostitution is facilitated
through the internet and takes place in hotel rooms or
private apartments. Foreign prostitutes, chiefly Russian,
meet their clients at nightclubs and casinos. The GoF in
late 2005 introduced legislation to criminalize prostitution
along the Swedish model, but it is still unclear how soon
such a law might be approved by Parliament owing to
opposition by feminist organizations that support legalized
prostitution.


22. (SBU) E: According to the Prosecutor-General's Office,
there were three convictions during the reporting period for
offenses related to trafficking. In all three cases,
prosecutors believed the essential elements of trafficking
were present and initially sought trafficking convictions,
but ultimately pursued related charges in order to obtain
more punitive convictions quickly. All three were "transit"
cases, two involving Chinese nationals and one involving a
Russian national. The convicted traffickers are currently in
prison in Finland. Prosecutors also attempted to bring
charges against two Russians who fled the country before
arrests could be made. The NBI reports that as of February,
there were several ongoing investigations that could result
in charges being brought against additional individuals in

2006.


23. (SBU) E, cont.: Finnish prosecutors are eager to use
new anti-TIP laws to prosecute traffickers, but admit that
they lack the training and experience to do so effectively.
Most trafficking cases in Finland involve individuals
transiting through the country to elsewhere in Europe.
Transit-trafficking cases are difficult to prove since the
victims are intercepted in "mid-stream" and have not reached
their final destination. The GoF is taking steps to remedy
this. A training seminar for TIP prosecutors was held in
Tampere in December, and another is scheduled for May. The
Embassy is also working with the Finns to increase their
effectiveness. Our Legatt will accompany three FBI profilers
specializing in TIP to Finland in early April for training
seminars with prosecutors and law enforcement personnel on
victim identification and interviewing methods, and
interrogatory techniques with trafficking suspects. Our POL
and PAS Sections are also working with the
Prosecutor-General's Office to arrange a VOLVIS program in
early fall putting Finnish prosecutors together with
experienced American counterparts.

24. (SBU) F: Trafficking to and through Finland is
believed to be controlled by large Russian and Chinese
organized crime syndicates. The organizers typically remain
outside of Finland, although lower-level operatives may
accompany victims. Travel agencies and marriage brokers are
not involved. The government is not involved.


25. (SBU) G: Finland actively investigates trafficking.
As part of its internal action plan, the National Bureau of
Investigation formed a dedicated anti-trafficking unit.
Finnish liaison officers with anti-trafficking responsibility
are now stationed in Murmansk, Petrozavorsk, St. Petersburg,
Moscow, Tallinn, The Hague, Lyon, Malaga, and as of April
2006, Beijing. Finland also participates in the "Nordic
Cooperation Network," a network of Finnish, Swedish, Danish,
Norwegian, and Icelandic law enforcement liaison officers
scattered throughout Europe, Asia, and the Middle-East.
Maximum sentences for traffickers are sufficient (7 years) to
allow law enforcement to use electronic surveillance
techniques when investigating trafficking rings.


26. (SBU) H: See para 15 for a description of the MFA's
training program for Finnish consular officers; and para 23
for a description of Justice and Interior Ministry training
programs for prosecutors and law enforcement personnel. In
addition, the NBI in December began an awareness and victim
identification training program for police, and since April
2005 approximately 400 Frontier Guards have cycled through a
victim-identification training course designed by Major Ilkaa
Herranen, a 2005 anti-trafficking IV participant. Plans call
for 1000 Frontier Guards to have completed the course by the
end of 2006.


27. (SBU) I: The GoF cooperates with other governments in
the investigation and prosecution of trafficking cases.
Finnish officials are currently involved in several regional
investigations, and in 2004-2005 played a major role in
breaking up a regional Baltic trafficking ring that led to
successful prosecutions in Latvia (including a Finn, who also
faces additional charges in Finland when he is released from
jail in Latvia).


28. (SBU) J: Finland will extradite persons charged with
trafficking to any country with which it has an extradition
treaty. Finland will extradite its own nationals on a case
by case basis to other countries with which it has an
extradition treaty, provided that the individual would not be
subject to the death penalty if convicted of an offense.
Finland has ratified the EU Arrest Warrant.


29. (SBU) K: Government officials are not involved in
trafficking.


30. (SBU) M: Finland is not a source or destination
country for child sex tourism. At least two Finns have been
prosecuted for having sex with minors abroad (Estonia and
Thailand).


31. (SBU) N: Finland is a signatory to the listed ILO,
CRC, and UN conventions.


Protection and Assistance to Victims
--------------

32. (SBU) A: Trafficking victims are taken to reception
centers for refugees and asylum seekers operated by the Labor
Ministry. The system has a capacity for 2,539 persons
country-wide, and operates at any point in time at 60%-80%
capacity. Two centers have been designated as "preferred"
TIP shelters, one in Helsinki and another near the Russian
border. TIP victims are housed in separate units within the
centers. Finnish reception centers are open (residents can
come and go),but visitors are screened by officials and not
allowed to contact residents without their consent. Victims
receive legal counseling, medical and psychological services,
and monthly stipends. Recently, after urging from IOM and
other NGOs, the GoF has revised its policy and is now
encouraging victims to leave the reception centers as soon as
possible for private NGO-run shelters. There are several
shelters for victims of domestic abuse that have expanded
their services to include counseling and care for trafficking
victims. Through February, 8 of the 15 TIP victims
identified during the past year were sheltered in a Labor
Ministry-run reception center.


33. (SBU) A, cont.: Finnish officials admit that the
current system could be improved. The reception centers are
clean and well-run, and medical services are adequate, but
counseling services remain a work in progress. Psychologists
from Finland's national health system have experience with
victims of domestic abuse, but little to no experience with
trafficking victims. The GoF plans to address this training
shortfall this year by pooling resources with other Nordic
countries to sponsor a seminar(s) for counselors working with
victims. The language barrier can also be a problem. There
are few Chinese or Thai speakers in Finland, and Asian TIP
victims may have difficulty communicating with Finnish
caregivers. Finally, the open nature of the reception
centers can be problematic. Finnish officials do not want to
"detain" TIP victims, but several presumed victims left
reception centers shortly after arrival and "disappeared"
into Finnish society; it is unclear whether they attempted to
reconnect with the traffickers that brought them to Finland,
left the country on their own, or stayed in Finland as
illegal migrants. Dozens of smuggled persons brought to
reception centers have also "disappeared" over the past year.


34. (SBU) B: The GoF provides the majority of funding to
Finnish NGOs for victim services. The GoF also provides
funding to IOM for work inside Finland and elsewhere.


35. (SBU) C: The GoF in early 2006 began to refer and
transfer victims from government reception centers to NGO-run
shelters whenever possible. This is only done in cases where
government and NGO officials believe it is safe and in the
best interest of the victim. The IOM Office in Helsinki told
the Embassy that after some initial hesitation, the GoF
adopted this policy as a "best practice" that is successful
in many other countries. Finnish hesitation stems from the
country's welfare-state culture that emphasizes the state's
role in providing health, social and protective services.


36. (SBU) D: The rights of TIP victims are now generally
respected. In the past, the police were quick to arrest and
deport foreign prostitutes without screening to identify TIP
victims. Law enforcement officials now emphasize the
screening process, and Finland intentionally adopted a
victim-centered model to eliminate further trauma for
possible TIP victims.


37. (SBU) E: The government encourages victims to assist
in the investigation and prosecution of trafficking. Police
and prosecutors have an informal system in place to protect
victims that cooperate with investigations; the Interior
Ministry is currently working on a formal witness protection
program.

38. (SBU) F: In addition to the open reception centers
described in para 32, the GoF also uses "closed" centers to
provide greater protection for persons deemed at-risk. Seven
of the 15 TIP victims identified during the reporting period
were housed in these secure facilities, including all of the
identified minors. The same medical and psychological
services described above are available to those in protective
custody, but no outside contacts are allowed (other than
medical, legal, and consular visits, etc.),and information
about residents is protected. Victims who testified at
trials would be sheltered in such facilities. Victims in
protective custody are not allowed to leave the facility
without supervision (if at all). The GoF emphasizes that it
uses protective custody arrangements only when absolutely
necessary, and that any victims who choose to return to their
country of origin will be allowed to do so as soon as
arrangements can be made. TIP victims are kept in separate
units, and minors are kept in sex-segregated juvenile
facilities apart from adults.


39. (SBU) See paras 15,23, and 26 for a description of GoF
training initiatives.


40. (SBU) H: There are no known cases of Finnish
trafficking victims.


41. (SBU) I: Major NGOs addressing trafficking (in
addition to other issues) include: IMO, Finn Church Aid,
League of Finnish Feminists, Pro-tukipiste, MonikaNaiset, the
Refugee Advice Center, and the National Council of Women in
Finland. Several of these NGOs operate shelters that provide
assistance and counseling to TIP victims. Pro-tupikiste
operates a phone hotline. Some NGOs are also active in
demand reduction efforts. All Finnish NGOs receive the bulk
of their funding from the GoF. NGOs participated in drafting
the National Action Plan and are regularly consulted by the
GoF on TIP issues. Most recently, the Labor Ministry has
worked with NGOs to develop a referral system to get TIP
victims out of government-run reception centers and into NGO
shelters whenever possible. NGOs will also participate in an
April law enforcement seminar on victim identification.

A Finnish Hero
--------------

42. (SBU) Major Ilkaa Herranen of Finland's Frontier Guard
has played an instrumental role in influencing Finland's
proactive victim-centered approach to combating TIP. There
has been a real sea change in official and public attitudes
toward trafficking since 2002 in Finland. Many Finns tended
to downplay the seriousness of the phenomenon, seeing TIP as
a "foreign problem" that didn't occur in or affect Finland.
Finnish officials--especially law enforcement
officials--generally shared this perspective. Herranen
stepped in to help change this. First, he educated himself,
taking advantage of opportunities like EU conference and
training seminars and an Embassy-funded IV program to
increase his understanding of the problem. Next, he
patiently and persistently worked within the system to change
the political culture of the law enforcement community.
Herranen did this at considerable risk to his career;
trafficking was seen as a "soft" issue in law enforcement
circles, and some supervisors and colleagues scoffed at his
initial attempts to raise TIP's profile. Eventually his work
paid off. As more officials were influenced by his growing
expertise, and as senior opinion leaders like President Tarja
Halonen spoke out against TIP, attitudes changed. Finnish
law enforcement today is committed to combating the problem,
and Herranen is a big part of the reason why.


43. (SBU) Major Herranen has also influenced public
attitudes toward trafficking. Herranen has spoken at
literally dozens of seminars, conferences, and smaller
meetings, as well as appearing on television news coverage of
trafficking. Examples of his public outreach include remarks
before the Orthodox and Lutheran Church hierarchies, before
Parliament, at several NGO meetings including a roundtable of
virtually all Finnish NGOs addressing women's issues, at
several schools, and on a major television news magazine's
expose of trafficking in the Nordic-Baltic region. Shifting
public opinion has enabled policymakers to secure the
necessary resources to implement the National Action Plan.


BEST PRACTICES
--------------

44. (SBU) Finland's National Action Plan to combat
trafficking was adopted in 2005. An inter-agency working
group co-chaired by the Labor and Interior Ministries was set
up to oversee the NAP's implementation, providing horizontal
integration to the process. In addition, the working group
required each ministry and agency to draft an "internal
action plan" that mirrored the NAP's structure and style.
Progress and problems related to the internal plans are
regularly reported to the main working group. This formal
structural requirement--internal plans for all agencies with
equity in the TIP process--has increased agency
accountability and compliance, and enhanced the effectiveness
of the national-level working group as a coordinating body.

WARE