Operational-search Counteraction to Crimes Committed in the

Institutions of the Penal System using Information and

Communication Systems

Andrey Nikolaevich Fedorov

and Eldar Faritovich Naruslanov

The Scientific Research Institute of the Federal Penitentiary Service of Russia, Ph.D. in Law, Moscow, Russian Federation

Keywords: Operational-search activity, information systems, communications, means of communication, fraud,

counteraction, penal system, investigation of crimes.

Abstract: The need for widespread use of criminological knowledge in the development of theory and practice to

increase the efficiency of detecting fraud committed using mobile telephone communications is impossible

without deep comprehensive scientific research, legal, organizational and tactical measures of a covert

operational-search nature. The specifics of the disclosure of fraud committed using mobile telephone

communications, which includes such components as the detection, prevention, suppression of these crimes,

has not been and is still relevant, including its penitentiary component. These circumstances indicate the need

for develop and implement adequate measures to disclose fraud committed using communications, and

determine the relevance of the topic of the article. In this work, the authors made an attempt to analyze the

current set of measures to improve operational-search activities to disclose fraud committed using

communications, as well as to determine the most effective ways of its development. Purpose of the study:

generalization of knowledge that allows to develop complex scientifically grounded measures to improve

operational-search activities to disclose fraud committed using communications. Objectives of the research:

to investigate the current state of the operational-search activity to disclose fraud committed using

communication means; to develop scientifically grounded recommendations and proposals for improving the

organization of operational-search activities to disclose fraud committed using mobile telephone

communications. Methodology: analysis of the current legislation, as well as scientific materials touching

upon the issues on the topic of this study, conducting questionnaires and interviews with existing employees

of institutions of the penal system, as well as communications workers. Results achieved: recommendations

were formulated to improve the operational and investigative counteraction to crimes committed in prisons

with the help of information and communication systems that can reduce the number of telephone fraud cases

carried out on the territory of places of deprivation of liberty, as well as ensure an effective fight against

telephone fraud without attracting additional forces and funds.

1 INTRODUCTION

JUSTIFICATION OF NOVELTY,

HYPOTHESIS

In modern realities, informatization is one of the most

actively progressing directions in the development of

society. Information systems, including those that

ensure the communication needs of mankind, have

now been widely implemented in various spheres of

life, thereby forming a high-tech and at the same time

public space, taking one of the dominant places in

people's lives (Melnikov., 2015).

https://orcid.org/0000-0002-6024-845X

Such a rapid development of information

networks seems to be a completely understandable

phenomenon, primarily due to a number of factors

(Miroshnikov, 2015):

simplicity and availability;

the possibility of interaction between subscribers

to exchange information regardless of the distance of

their location relative to each other;

the absence of interstate restrictions and this

applies to both users and service providers.

The considered aspect of the development of

society is undoubtedly a positive global achievement

that brings into people's lives an unhindered

176

Fedorov, A. and Naruslanov, E.

Operational-search Counteraction to Crimes Committed in the Institutions of the Penal System using Information and Communication Systems.

DOI: 10.5220/0010633100003152

In Proceedings of the VII International Scientiﬁc-Practical Conference “Criminal Law and Operative Search Activities: Problems of Legislation, Science and Practice” (CLOSA 2021), pages

176-182

ISBN: 978-989-758-532-6; ISSN: 2184-9854

opportunity for communication and exchange of

information, however, thanks to the functions

described above, informatization becomes the object

of attention of the criminals, and when it seems in the

hands of criminals, it turns into an “instrument” of

committing crime encroachments (Meshkova, 2003).

The emergence and development of mobile

telephone communications led not only to the

intensive development of modern society in the field

of its informatization, but also to the introduction of

the achievements of science and technology when

committing fraudulent actions.

The negative consequences of fraud committed

using mobile telephone communications means, in a

broad sense, include the threat to the information

security of the state, information and psychological

security of the individual, wide opportunities for the

use of disinformation and manipulation of

consciousness, the widespread use of information

systems and networks in illegal activities

(Merzogitova, Mayorova, 1998). The information

space is an ideal environment for the activities of

criminals, since access to it is extremely easy, the

potential environment for illegal activities is

significant, and it is easy to ensure the anonymity of

users, it is not controlled by anyone and is extremely

poorly controlled (Zharova, 2019).

Technological schemes developed and applied by

criminal groups using mobile telephony are

distinguished by a high degree of thoughtfulness and

organization, can be both fairly simple and multi-

stage, spatially separated and lasting in time. At the

same time, different areas of illegal activity in various

areas are interconnected and synchronized with each

other in the process of preparing and committing a

crime (Sukhodolov, Ivantsov, Borisov, Spasennikov,

2017).

It should be emphasized that the problem of

disclosing fraud committed using communication

means is one of the most urgent in the field of

combating ordinary and penitentiary crime. It is

determined by the high latency of these crimes and

the fact that 93.7% of people living in Russia use

mobile telephone services, which makes them

potential victims of "telephone scams".

Since mid-2008, "telephone fraud" has spread in

prisons as well. This is due to the fact that the

specifics of staying in institutions of the Penal System

of the Russian Federation (hereinafter - PS)

predetermines an extremely high degree of demand

for communication services for suspects, accused and

convicted persons.

The surge in mobile phone fraud has naturally

attracted the attention of science. In recent years,

dissertation research has been carried out on issues

affecting the designated problems (M.N. Bogdanov,

S.V. Gorobchenko, S.N. Kazinskaya, B.A. Kurinov,

V.V. Malygina, I.M. Mishina, A.N. Rozin, A.A.

Nuzhdina). However, their analysis shows that they

are dedicated to:

the study of general issues of fraud investigation

methodology;

prepared taking into account the specifics of

certain areas of activity (banking, housing, etc.).

As for the issues of operational and investigative

counteraction to crimes committed in the institutions

of the penal system using information and

communication systems, they were not the subject of

independent scientific research.

In this regard, the purpose of the study described

in this article is to generalize knowledge that allows

the development of comprehensive scientifically

grounded measures to improve operational-search

activities to disclose fraud committed using

communications.

Achievement of the set research goal necessitated

the formulation and solution of the following tasks:

1) to investigate the current state of operational

and investigative activities to disclose fraud

committed using communication means;

2) develop scientifically grounded

recommendations and proposals for improving the

organization of operational-search activities to

disclose fraud committed using mobile telephone

communications.

Thus, this article will consider the problematic

issues of operational-investigative counteraction to

crimes committed using information and

communication systems, including by persons held in

penal institutions.

2 MATERIALS AND METHODS

The methodology and methods of research represent

a system of general scientific and special legal means

and methods of cognition that ensure objectivity and

comparativeness in the study of operational-search

activities to disclose fraud committed using

communications. Among them, in the process of

work, the comparative legal method, general

scientific methods of analogy and statistics, induction

and deduction, sociological methods of questioning,

interviewing, content analysis, and other research

tools of modern socio-humanities were used, which

make it possible to comprehensively study the stated

topic of the article. Analyzed the current legislation,

Operational-search Counteraction to Crimes Committed in the Institutions of the Penal System using Information and Communication

Systems

177

as well as scientific materials raising issues on the

topic of this study.

3 RESULTS AND DISCUSSION

It should be noted that the operational-investigative

counteraction to crimes committed in the institutions

of the penal system using information and

communication systems is complicated by the fact

that today there are a number of problematic issues in

places of deprivation of liberty that do not allow to

fully exclude the commission of remote frauds

committed by suspects accused and convicted. These

issues include:

 lack of funding for the purchase of technical

means to suppress radio signals used by mobile

operators within the boundaries of penal institutions.

The approximate cost of the equipment of 1

institution of the penal system is 15-20 million rubles.

The equipment of all institutions of the Russian penal

system requires more than 14 billion rubles.

However, even if there is the necessary amount of

funding, this equipment, after a certain time, needs to

be updated in view of the improvement of

communication services. At the same time, according

to the position of the Ministry of Telecom and Mass

Communications of the Russian Federation, the

setting of intentional radio interference for civilian

purposes is not allowed, since it will lead to the

creation of unacceptable interference with the

operation of existing mobile radio communication

networks, at the same time, guaranteed blocking of

cellular communication signals throughout the

institution is not ensured. In addition, these devices

do not block 3G / 4G cellular networks;

 the absence in the Federal Penitentiary Service

of Russia of normative documents establishing the

norms for the position and the procedure for the use

of blockers;

 lack of normative consolidation of the

obligation of mobile network operators to exclude

communication services on the territory of

institutions of the Federal Penitentiary Service of

Russia. Amendments to the Federal Law of

07.07.2003 No. 126 - FL "On Communications" are

required;

 lack of interest of mobile operators in the

exclusion of the territories of institutions of the PS of

Russia from the coverage area of their base stations.

In addition, in practice, there are cases when

criminals who are outside the institutions of the penal

system, acting in order to mislead the bodies of the

preliminary investigation about their whereabouts,

commit remote fraud near the institutions of the

Federal Penitentiary Service of Russia, for example,

while in motor transport, thereby falling into a single

coverage area base station of a mobile operator, as the

institution of the PS. As a result of such activities of

criminals, in 2019, cases of documenting the facts of

remote fraud from the territory of former institutions

of the penal system, liquidated or transferred to other

departments, were identified. In such cases, the

process of identifying suspects requires additional

time required to carry out operational-search

activities.

On the part of the Federal Penitentiary Service of

Russia, at various government commissions and

coordination meetings, topical issues of the need to

exclude the possibility of using mobile

communications by persons held in penal institutions

are regularly raised.

It should be noted that telecom operators each

year suffer losses associated with mobile fraud on a

global scale of about $ 25 billion. Unfortunately,

domestic mobile operators prefer not to advertise

their losses from this criminal activity. As for users,

we note that as a result of a survey of Russian

subscribers, it was found that 78 % of respondents are

aware of telephone fraud, and 15 % noted that their

relatives and friends have suffered from the actions of

fraudsters who used mobile telephony.

In these conditions, it is important not only to

organize and purposefully carry out security, but also

operational-search measures to uncover fraud

committed using mobile telephony facilities in penal

institutions. The problem of increasing the efficiency

of the operational-search support of their disclosure

has acquired the character of a most important

intersectoral, interdisciplinary scientific and practical

problem. At the same time, its system is complex and

requires deep scientific understanding, a clear

definition of its subjects and objects, the delineation

of competence and responsibility between the

subjects of operational-search activity.

One of the most effective areas of activity of

operational units for detecting qualified crimes

related to telecommunications is the integrated

processing of information about subscribers and the

communication services provided to them, data from

automated payment systems for communication

services and technical, in-system information

characterizing the operation of communication

systems (billing information) (Kirilenko, Alekseev,

2020).

The primary data necessary for carrying out

measures for analytical support of the activities of

operational units of the FPS can be obtained:

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 during the examination of telephones seized

from persons held in penal institutions or transferred

to them;

 by analyzing data on the connections of

telephones operating on the territory of the penal

system institutions or in the areas where crimes are

committed by persons held in the penal system.

The proposed approach is based on the fact that

when preparing and committing a fraud committed

using mobile telephone communications, mobile

telephones is used from the territory of the penal

system at the stage of preparing and committing a

crime. Therefore, solving the problem of identifying

their subscribers who took part in the preparation and

commission of a crime corresponds to solving the

problem of identifying persons involved in the crimes

being committed and establishing the facts of their

illegal activities (Stepanenko, Bakhteev, Evstratova,

2020).

Moreover, in the conditions of an almost complete

absence of data on users of communication networks,

the rapid change of subscriber numbers and terminal

numbers, as well as the use of one-time or session

SIM-cards, identification and binding of control

objects to communication means in most cases is

possible only during the analysis of technical or

intrasystem data, the acquisition and analysis of

which is possible only with the use of both special

hardware and software complexes, and specialized

software tools or packages of application programs

for general use (Ammar, 2019.).

Prevention, however, often comes down to only

measures of criminal repression (Lavorgna, 2019), on

which most of the interviewed employees of

operational units still rely, believing that the only

effective measure to prevent new crimes is the arrest

and conviction of a fraudster. Therefore, the most

serious attention should be paid to the prevention of

cases of criminal fraud, suppression of the active

activity of professional fraudsters, and neutralization

of factors that facilitate their illegal actions

(Galakhov, 2001). So, organizing the prevention of

fraud committed using mobile telephony means, you

need to:

 identify factors contributing to the

commission of fraud and take measures to eliminate

them;

 determine the circle of persons who may be

capable of carrying out fraud, and take appropriate

measures in order to prevent its commission;

 to identify ways of committing planned or

planned crimes, conditions and other circumstances

that fraudsters intend to use (Paramonov, 1998).

General preventive measures are aimed at

identifying, eliminating and neutralizing the causes

and conditions that contribute to fraudulent

manifestations. Measures of this nature are based on

the analysis of negative factors contributing to the

manifestation of fraud, the available operational-

search information.

Analysis of information, depending on the tasks at

hand, allows you to have information about the

effectiveness of preventive measures, to have an idea

of the negative factors that contribute to fraud, to take

timely measures to eliminate them based on the

rational use of available forces and means. In

addition, in the process of studying operational

materials, changes and trends in the psychology of

fraudsters and their tactics are revealed, which is one

of the conditions for the correct organization of the

work of persons assisting operational units in order to

disclose fraud (Gurov, 1986).

Operations staff can, using overt and covert

methods:

 to establish the circle of accomplices of fraud

and the role in the crime of each of them;

 to identify the nature of actions for the

preparation and implementation of criminal

intentions, ways of committing fraud;

 to actively influence the persons involved in

such crimes in order to persuade the latter to abandon

illegal actions, to exert a preventive effect on them, to

remove from the negative influence of criminals and

other persons with a less persistent criminogenic

motive;

 successfully identify persons who may be

witnesses, victims, as well as various objects and

documents of evidentiary value;

 to identify persons who are aware of crimes,

methods and circumstances of their commission;

 detect places of shelter of property and

valuables obtained as a result of committing

fraudulent activities;



participate in the verification of operational

and other information;

 control the channels of information exchange

between persons held in penal institutions and their

accomplices who are at large, block (interrupt) the

operation of communications on the territory of penal

institutions.

The essence of the suppression of fraud is

characterized, as it were, by a logical continuation of

measures to prevent contemplated or planned crimes

and comes down to the arrest of those being checked

red-handed at the time of the crimes. The conditions

for the successful implementation of such detention

are:

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 high-quality information support of ongoing

activities (it is necessary to have information about

when, where, in what way and in what composition

the criminals intend to act, etc.);

 conducting a study of the object at which the

fraudsters intend to commit a crime;

 determination of the forces, means necessary

for the operation, briefing and placement of

employees of operational units and other services

carrying out the arrest of criminals red-handed;

 high secrecy of the conducted OSM.

The practice of disclosure shows that the activities

of persons who specialize in fraudulent actions

committed using mobile telephone means are

distinguished by a high degree of criminal

professionalism and legend of their illegal actions

(Martin, Munksgaard, Coomber, Demant, Barratt,

2020). As a rule, the objects of investigation use

several sets of SIM-cards used in the preparation and

commission of crimes. Therefore, in the areas where

crimes are committed, some subscriber numbers are

used, and in everyday activities, others. At the same

time, separate terminals can be used for everyday

SIM cards. At the same time, in a number of cases,

during the commission of a crime, criminals also have

everyday mobile phones with them, on which they

can receive calls or SMS messages. These telephones

are identified by building time-space models and

identifying multiple numbers simultaneously located

in the same areas (Kemp, 2020).

The main feature of the operation of such sets of

mobile phones is the use of terminals with several

SIM-cards and the interconnected operation of

several mobile phones in space and time. For complex

processing of data obtained from several sources, a

system of semantic-statistical processing of

heterogeneous information can be used.

When conducting operational-search measures in

relation to fraudsters, the following tasks are solved:

 identification and thorough examination of all

participants in the commission of fraud, including the

use of citizens who provide assistance to operational

units;

 establishing the true role of each accomplice

in committing fraud;

 establishing the facts of the criminal activity

of criminals;

 documenting criminal acts;

 non-admission (suppression) of criminal acts;

 identification of the accomplices of fraudsters,

as well as persons included in their circle of

communication;

 taking measures aimed at compensation for

material damage caused by the criminal actions of the

inspected persons;

 identification and arrest of fraudsters red-

handed;

 identification and elimination of the reasons

and conditions conducive to the commission of fraud

committed using the means of mobile telephone

communications.

In the process of verification activities in relation

to persons suspected of committing fraud as part of a

group, it becomes necessary to document the criminal

activity of the entire group of fraudsters. To

accomplish this task, it is advisable to use the

capabilities of specialized technical units, since with

the help of their employees, the members of the

criminal group, their roles, previously unknown

episodes are established; places of storage and sale of

money, jewelry and things acquired as a result of

fraud, etc.

The analysis shows that the effectiveness of

processing the information obtained in the course of

technical measures depends on the level of interaction

of the interested services. This relationship is largely

due to the specifics of the tasks solved by the

departments of technical measures, which consist in

documenting criminal activity (Caneppele, 2019).

In the legal literature, based on an analysis of the

practice of combating crime in general, an opinion

has been expressed about the possibility of using two

main tactics when documenting criminal activity,

which can be successfully used when documenting

fraudulent actions:

1. Identification and recording of actions that are

criminal in accordance with the current criminal code,

and committed by leaders and participants of criminal

fraudulent structures;

2. Collection and recording of factual data

confirming the existence and activities of a criminal

community (criminal organization), an organized

group.

In the context of the above, special attention

should be paid to the issues of documenting the illegal

actions of organizers and other leaders of criminal

fraudulent groups. In this regard, one of the main

tasks of documentation is to establish the activities of

their leader in organizing specific crimes and guiding

the activities of their members. Among the main

actions of the organizers associated with their direct

participation, the creation and management of a

criminal group of fraudsters, we will include the

following:

 selection of members of the fraudulent group,

distribution of their roles and responsibilities;

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 formation of a unified attitude and correct

understanding of the criminal purpose among persons

participating in fraudulent activities;

 supplying direct perpetrators of fraudulent

actions with means of committing crimes;

 development of forms for reporting ordinary

fraudsters to their leader and ways to maintain

intragroup discipline;

 involvement of new members into the criminal

group of fraudsters, prevention of the exit from the

formation of individual participants;

 determination of the vector of the group's

activities, including tactical and strategic aspects;

 determination of the scope of the criminal

offense, as well as the search for a potential victim;

 building a latent system of corrupt

relationships with government agencies;

 organization of counteraction to law

enforcement structures (Meshkov, 2003).

Identification and fixation in the course of

documenting the above actions will make it possible

to establish the fact of the creation and management

of the activities of an organized criminal structure,

and the circle of its members.

When documenting the actions of the organizers

of fraud, it is necessary to record the presence of

corruption ties that provide the criminal structure with

a certain level of security (Bordilovsky, 1993).

An analysis of the experience of combating

fraudsters with corrupt connections shows that in the

course of identifying corrupt officials and

documenting their illegal activities, it is necessary to

establish data indicating such facts and circumstances

as (Kornoukhov, 1995):

 direct participation of officials of state

authorities and administration in criminal activities;

 use of official position to cover up fraudulent

activities.

Documenting in this case involves the

identification, verification and consolidation of data

objectively confirming the action or inaction in

connection with which the fraud was carried out

(Ryabkov, 2001). Through tacit opportunities or with

the help of technical means, it is also necessary to find

out in whose interests the transfer (or transfer) of the

bribe is supposed to be.

4 CONCLUSIONS

In conclusion, it should be emphasized that only the

comprehensive use of the capabilities of law

enforcement agencies, tactically competent and

qualified and justified use of both public and private

capabilities of units carrying out operational-search

activities, can achieve positive results in disclosing

fraud committed using communications.

The results obtained in the course of the study

allow us to formulate a number of recommendations

for practitioners and heads of institutions and

authorities of the penal system involved in direct

counteraction to telephone fraud:

It is necessary to conduct a survey of the territory

of each institution of the penal system, in which

suspects and those accused of committing crimes are

kept, as well as those sentenced to imprisonment are

serving a criminal sentence. As part of the survey,

identify premises that are suitable for committing

crimes related to telephone fraud.

Strengthen surveillance in the premises identified

during the survey by installing permanent video

surveillance.

If it is possible to exclude access to the premises

of the risk group for persons included in the circle of

potential fraudsters.

On the part of the PS authorities, there should be

constant monitoring of persons who have access to

premises suitable for committing crimes related to

telephone fraud.

The introduction of the formulated

recommendations into the practice of the institutions

and bodies of the PS will significantly reduce the

number of cases of telephone fraud carried out from

their territory, as well as ensure an effective fight

against telephone fraud without attracting additional

forces and funds.

REFERENCES

Ammar, J., 2019. Cyber Gremlin: social networking,

machine learning and the global war on Al-Qaida-and

IS-inspired terrorism. In International Journal of Law

and Information Technology. 27(3). pp. 238-265.

Bordilovsky, E. I., 1995. Operational-search support of the

crime investigation process: lecture. p. 5.

Caneppele, S., 2019. Crime Drop or Police Recording Flop?

On the Relationship between the Decrease of Offline

Crime and the Increase of Online and Hybrid Crimes.

In Policing: A Journal of Policy and Practice.13(1). pp.

66-79.

Galakhov, S. S., 1989. Fundamentals of crime prevention

by units of the criminal police: author. dis. 21 p.

Gurov, A. I., Yurko, E. I., 1986. Combating fraud in

transport: a tutorial. 38 p.

Kemp, S., 2020. The Dark Figure and the Cyber Fraud Rise

in Europe: Evidence from Spain. In European Journal

on Criminal Policy and Research. 26(3). pp. 293-312.

Kirilenko, V. P., Alekseev, G.V., 2020. Harmonization of

Russian criminal legislation on countering cybercrime

Operational-search Counteraction to Crimes Committed in the Institutions of the Penal System using Information and Communication

Systems

181

with the legal standards of the Council of Europe. In All

- Russian Criminological Journal. 14(6). p. 901.

Lavorgna, A., 2019. Cyber-organized crime. A case of

moral panic? In Trends in Organized Crime. 22(4). pp.

357-374.

Martin, J., Munksgaard, R., Coomber, R., Demant, J.,

Barratt, M. J., 2020. Selling Drugs on

DarkwebCryptomarkets: Differentiated Pathways,

Risks and Rewards. In British Journal of Criminology.

60(3). pp. 559-578.

Melnikov, D. A., 2015. Organization and security of

information and telecommunication networks and

systems. p. 598.

Merzogitova, Yu. A., Mayorova, E. I., 1998. Qualifications

of an organized criminal community (criminal

organization). pp. 14-15.

Meshkova, B. C., 2003. Exposing the leader (organizer) of

a criminal group in its creation and management of

criminal activity: author. dis. pp. 12-13.

Miroshnikov, B. N., 2015. Network factor. Internet and

Society. p. 288.

Paramonov, I. M., 1998. Prevention and disclosure of fraud

by criminal investigation apparatus: stock lecture. p. 24.

Presser, L., Sandberg, S., 2019. Narrative Criminology as

Critical Criminology.

Ryabkov, E. M., 2001. Neutralization of counteraction in

the field of operational-search activities of internal

affairs bodies (legal, organizational and tactical issues):

dis.

Stepanenko, D. A., Bakhteev, D.V., Evstratova, Yu. A.,

2020. Use of artificial intelligence systems in law

enforcement. In All-Russian criminological journal.

14(2). p. 212.

Sukhodolov, A. P., Ivantsov, S.V., Borisov, S.V.,

Spasennikov, B. A., 2017. Actual problems of

preventing crimes in the economic sphere, committed

using information and telecommunication networks. In

All-Russian Criminological Journal. 11(1). p. 16.

Kornoukhov, V. E. and others. The course of criminalistics.

pp. 109-117.

Yakovlev, A. M., 2017. Theory of criminology and social

practice. p. 248.

Zharova, A. 2019. Ensuring the Information Security of

Information Communication Technology Users in

Russia. In International Journal of Cyber Criminology.

13 (2). pp. 255-269.

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