Testimony of Gary M. Bald, Acting Assistant Director Counterterrorism
Division, FBI
Before the Senate Caucus on International Narcotics Control
March 4, 2004
"Coordination of the United
States' Efforts to Combat Money Laundering and Terrorist
Financing"
Good
morning Mr. Chairman and members of the United States Senate
Caucus on International Narcotics Control. On behalf of
the Federal Bureau of Investigation (FBI), I would like
to express my gratitude to you for affording us the opportunity
to participate in this forum and to provide comments on
the FBI's achievements, together with our partners in the
war on terror, in the effort to identify, dismantle and
disrupt sources of terrorist financing and money laundering.
I also appreciate the opportunity to highlight our efforts
with regard to interagency cooperation in the battle against
terrorist financing.
The fight against terrorist financing is a major front in
our war on terror. We recognize that terrorists, their networks
and support structures require funding in some form to exist
and operate. Whether the funding and financial support is
minimal or substantial, it often leaves a financial trail
that can be traced, tracked, and exploited for proactive
and reactive purposes. Being able to identify and track
financial transactions and links after a terrorist act has
occurred or a terrorist activity has been identified is
important, but the key lies in exploiting financial information
to identify previously unknown terrorist cells, recognizing
potential terrorist activity or planning, and predicting
and preventing potential terrorist acts. To this end, the
FBI has bolstered its ability to effectively combat terrorism
through the formation of the Terrorist Financing Operations
Section (TFOS).
TFOS was created in April, 2002 to combine the FBI's traditional
expertise in conducting complex criminal financial investigations
with advanced technologies and the critical legislative
tools provided through the USA PATRIOT Act. TFOS has built
upon these established mechanisms by developing cooperation
and coordination among law enforcement and intelligence
agencies, both domestic and foreign, to form the preeminent
terrorist financing investigative operation. In the past
several months, TFOS has demonstrated its capabilities by
conducting near real-time financial tracking of a terrorist
cell and providing specific and identifiable information
to a foreign intelligence agency, which resulted in the
prevention of six, potential deadly terrorist attacks.
The TFOS mission includes: conducting full financial analysis
of terrorist suspects and their financial support structures
in the US and abroad; coordinating joint participation,
liaison, and outreach efforts to exploit financial resources
of private, government, and foreign entities; utilizing
FBI and Legal Attachéé expertise and relationships
to fully develop financial information from foreign law
enforcement and private agencies, including the deployment
of TFOS personnel abroad to locations such as Iraq; working
jointly with the intelligence community to fully exploit
intelligence information to further terrorist investigations;
working jointly with prosecutors and with the law enforcement
and regulatory communities; developing predictive models
and conducting data analysis to facilitate the identification
of previously unknown or "sleeper" terrorist suspects;
and providing the financial component to classified counterterrorism
investigations in support of the FBI's counterterrorism
responsibilities.
Achievements towards the identification, dismantlement and
disruption of sources of terrorist financing:
Before addressing some specific, investigative accomplishments
in the fight against terrorist financing since 9/11/01,
it is important to mention our progress in broad areas.
For instance, international awareness and cooperation on
the problem of terrorist financing has reached unparalleled
levels. Outreach with, and cooperation from, the private
sector has been outstanding and continues to develop--particularly
the level of two-way interaction between law enforcement
and the private sector. The resulting ability of FBI to
access and obtain information in a timely fashion has significantly
enhanced the FBI's ability to identify, investigate, and
resolve immediate threat situations involving potential
terrorist activity. Moreover, the ability to conduct near
real-time monitoring of specifically identified financial
activity has been invaluable not only to investigations
ongoing in the US, but to foreign law enforcement and intelligence
agencies in related investigations.
As an example of our successful liaison and outreach efforts,
extensive training and support of international investigations
by TFOS has resulted in Agent visits, exchanges and training
programs involving countries in Europe, Southeast Asia,
the Middle East, Africa and South America. In support of
specific high profile joint terrorist financial investigative
matters, a number of countries and agencies, including the
United Kingdom, Switzerland, Canada and Europol, have detailed
investigators to TFOS on a temporary duty basis.
TFOS has engaged in extensive coordination with authorities
of numerous foreign governments in terrorist financing matters,
leading to joint investigative efforts throughout the world.
These joint investigations have successfully targeted the
financing of several overseas Al-Qa'ida cells. Furthermore,
through the assistance of relationships established with
the central banks of several strategic countries, successful
disruptions of Al-Qa'ida financing have been accomplished
in countries such as the UAE, Pakistan, Afghanistan, Philippines
and Indonesia.
As part of this effort, TFOS has developed a specific terrorist
financing and money laundering crimes curriculum for international
training that includes topics such as: acquiring and handling
evidence in document intensive financial investigations,
major case management techniques, forensic examination tools,
and methods of terrorist financing. At
the request of the US Department of State, TFOS and the
Internal Revenue Service have provided this curriculum to
ten countries in just the past year, and are scheduled to
provide it to approximately 38 countries overall, identified
by the National Security Council as needing law enforcement
training on conducting terrorist financing investigations.
Needless to say, access to foreign banking records is often
critical to effectively following terrorist money. Through
these training and outreach initiatives, TFOS has been able
to obtain direct access to records provided by foreign central
banks in numerous countries. In return, TFOS has also been
able to assist these and other countries with the reciprocal
sharing of terrorism related financial information.TFOS
has cultivated and maintains a contact database of private
industry and government sources and persons who can provide
financial data, including near real-time monitoring of financial
transactions. Many of these contacts can be reached or accessed
on a 24 hour/7 days a week basis, allowing TFOS to respond
rapidly to critical incidents.
Through these contacts, with appropriate legal process,
and pursuant to FBI investigative guidelines, TFOS has access
to data and information from a variety of entities including:
Banking Institutions, the Credit/Debit Card Sector, Money
Services Businesses, the Securities/Brokerages Sector, Insurance
Companies, Travel Agencies, Internet Service Providers,
the Telecommunications Industry, Law Enforcement, State/Federal
Regulatory Agencies, Public and Open Source Data Providers,
the Intelligence Community, and International Law Enforcement
and Intelligence Contacts. Access to this type of information
is governed by the Right to Financial Privacy Act, Fair
Credit Reporting Act, and other applicable statutes. The
timeliness and accessibility of the data from these sources
is contingent on a variety of factors, including whether
the acquisition of the information requires legal process,
the search capabilities of the data provider, and the size
and depth of the data request. Nevertheless, as I've noted,
the ability to access and obtain this type of information
in a time sensitive and urgent manner has significantly
enhanced the FBI's ability to identify, investigate and
resolve immediate threat situations involving potential
terrorist activity.
INTERAGENCY
COOPERATION
Organizational
changes have taken place within the Executive Branch with
respect to the investigation of terrorism financing, including
the execution of a Memorandum of Agreement (MOA) between
the Department of Justice (DOJ) and the Department of Homeland
Security (DHS) concerning terrorist financing investigations.
The MOA addressed the importance of waging a seamless, coordinated
law enforcement campaign against terrorist sources of financing.
Signed by Attorney General Ashcroft and Homeland Security
Secretary Ridge on May 13, 2003, it designates the FBI as
the lead terrorist financing investigations and operations
agency, and enables DHS to focus its law enforcement activities
on protecting the integrity of US financial systems. To
this end, DHS implemented "Operation Cornerstone",
led by Immigration and Customs Enforcement (ICE), to identify
vulnerabilities in financial systems through which criminals
launder their illicit proceeds, bring them to justice and
work to eliminate financial infrastructure vulnerabilities.
Former US Customs Service "Operation Green Quest"
criminal cases having no nexus to terrorism were converted
to "Operation Cornerstone", while those cases
having a nexus to terrorism were transitioned to the appropriate
FBI Joint Terrorism Task Force (JTTF) where participating
ICE Task Force members continue to play significant roles.
Ongoing and future "Operation Cornerstone" investigations
that develop links to terrorism will be referred to the
FBI through TFOS. ICE and TFOS are coordinating investigative
initiatives that will enable ICE to identify financial systemic
vulnerabilities, and which will enable TFOS to identify
ties to terrorism and terrorist financing. In addition,
there is a liaison from ICE assigned to TFOS, and investigators
from ICE are assigned to the JTTFs. The FBI has reciprocated
by assigning an FBI Agent Unit Chief to the ICE offices
in Washington, D.C.
In the various 84 JTTFs throughout the United States, ICE
and FBI Agents are working side by side on numerous joint
investigations. The exact number of ICE and FBI Agents varies
from city to city and depends largely upon the workload
at each JTTF. The JTTF does not only include ICE and FBI
Agents, but representatives from State and Local law enforcement
agencies, and other federal agencies such as the Internal
Revenue Service, Department of Defense, Department of the
Treasury, Central Intelligence Agency, Postal Inspection
and the Environmental Protection Agency. Every Agency has
an open-ended invitation to participate in the JTTF, and
FBI Special Agents In Charge are particularly encouraged
to promote interagency cooperation through the JTTFs.
Information sharing is critical to all of our efforts. The
intelligence community, including the FBI, produces and
obtains tremendous amounts of classified intelligence information.
While much of the information can be of significant value
in terrorist finance investigations, the value will not
be realized or maximized absent the ability to filter the
information, analyze it, and disseminate it in an appropriate
manner to those who can make the best use of the information.
Toward this end, TFOS participates in joint endeavors with
the Treasury Department, the Department of Justice, and
the Department of Homeland Security involving potential
terrorist related financial transactions. TFOS also has
personnel detailed to the CIA's Counter Terrorism Center,
and personnel from there work directly with TFOS on financial
intelligence matters.
In
addition, the National Security Council (NSC) formalized
the Policy Coordinating Committee (PCC) on Terrorist Financing
at the end of 2001. The NSC chairs the PCC, which generally
meets at least once a month to coordinate the United States
government's campaign against terrorist financing. The meeting
generally focuses on ensuring that all relevant components
of the federal government are acting in a coordinated and
effective manner to combat terrorist financing.
The Departments of State, the Treasury, Homeland Security
and Justice also participate in an interagency Terrorist
Financing Working Group, chaired by the State Department,
to coordinate government efforts to identify, prioritize,
assess, and assist those countries whose financial systems
are vulnerable to terrorist exploitation. Groups of experts,
including DOJ money laundering prosecutors, interagency
law enforcement and regulatory members, have provided extensive
on-the-ground assessments of such countries' vulnerabilities
in an effort to develop and provide targeted training and
technical assistance to those countries identified as most
vulnerable.
EXAMPLES
OF INVESTIGATIONS
In
addition to these developments, the FBI, working in coordination
with other entities of the US government, has participated
in the following successes pertaining to terrorist financing:
The
FBI conducted a detailed financial investigation/analysis
of the19 hijackers and their support network, following
the September 11th attacks. This investigation initially
identified the Al Qa'ida funding sources of the 19 hijackers
in the UAE and Germany. The financial investigation also
provided the first links between Ramzi Binalshibh and the
9/11/01 terrorist attacks. A continuing investigation, in
coordination with the PENTTBOMB Team, has traced the origin
of the funding of September 11th back to financial accounts
in Pakistan, where high-ranking and well-known Al Qa'ida
operatives played a major role in moving the money forward,
eventually into the hands of the hijackers located in the
US. As part of the 9/11/01 financial investigation, thousands
of individuals and organizations were investigated in the
US and abroad to determine whether they played any part
in supporting the hijackers or the operation. Although the
vast majority of these individuals and organizations were
cleared of culpability, this process of elimination resulted
in numerous other quality terrorism investigations being
initiated, as well as criminal charges against hundreds
of individuals for fraud and other criminal activity.
In
2001, an FBI Joint Terrorism Task Force in Charlotte, North
Carolina, utilized racketeering statutes to obtain criminal
convictions and, thus, disrupt and dismantle a Hizballah
procurement and fundraising cell. Twenty-four individuals
were arrested for crimes including immigration fraud, visa
fraud, cigarette smuggling, interstate transportation of
stolen property, fraud, bank fraud, bribery, money laundering,
racketeering, and providing material support to a designated
terrorist organization, with the final conviction delivered
in 2003. Sentences imposed range up to more than 150 years.
In
2002, the FBI coordinated with the Treasury Department's
Office of Foreign Asset Control (OFAC) to justify the blocking
of Holy Land Foundation for Relief and Development (HLF)
assets and the closing of its US offices, shutting down
Hamas' largest fund-raising entity in the US. The HLF had
been linked to the funding of Hamas terrorist activities,
and in 2000, raised $13 million.
In
October 2002, the FBI and other US government agencies assisted
German authorities in identifying and taking legal action
against Hamas in Germany. Through the efforts of the FBI,
including TFOS, exchanges with Germany led to the closure
of the Al Aqsa Foundation in Germany, a suspected Hamas
fundraising organization.
In
December 2002, a federal grand jury in Dallas returned an
indictment against a senior leader of Hamas, Mousa Abu Marzouk,
for conspiring to violate US laws that prohibit dealing
in terrorist funds. Also charged and arrested by the FBI
were Ghassan Elashi, the chairman of the Holy Land Foundation
for Relief and Development, a charitable organization designated
as a terrorist organization by the US Treasury Department's
Office of Foreign Asset Control because of its fundraising
activities on behalf of Hamas. Elashi and four of his brothers,
all of whom are employees of the Richardson, Texas-based
InfoCom Corporation, were charged with selling computers
and computer parts to Libya and Syria, both designated state
sponsors of terrorism. The indictment alleged that the Elashi
brothers disguised capital investment from Marzouk, a specially
designated terrorist for his admitted leadership role with
Hamas, for their telecommunications company, InfoCom. The
indictment and subsequent arrests have disrupted a US based
business, which was conducting its activities with a known
Hamas leader and state sponsors of terrorism.
In
January 2003, the FBI, working in conjunction with German
law enforcement, arrested Mohammed Al Hasan Al-Moayad, a
Yemeni national, on charges of conspiring to provide material
support to Al Qa'ida and Hamas. Al-Moayad was a significant
financial contributor to Al Qa'ida and Hamas, and boasted
he had provided over $20 million dollars to Usama Bin Laden.
Al-Moayad participated in several fund raising events at
the Al Farouq Mosque in Brooklyn, NY. Al-Moayad was arrested
during an undercover operation where he believed that he
was to receive a large financial contribution, which he
advised an FBI source would be used to support mujahideen
fighters of Al Qa'ida and Hamas. Along with Al-Moayad, several
of his associates in New York were arrested for violating
banking reporting requirements by structuring over $300,000
in several bank accounts in the United States.
Offices
of the Benevolence International Foundation (BIF), a US
based charity, were shut down and its assets and records
blocked following an OFAC and FBI investigation which determined
the charity was being used to funnel money to Al Qa'ida.
In February 2003, Enaam Arnaout, the head of BIF, pleaded
guilty to racketeering conspiracy, admitting he fraudulently
obtained charitable donations in order to provide financial
assistance to persons engaged in violent activities overseas.
A
criminal case against Sami Al Arian, the alleged US leader
of the Palestinian Islamic Jihad (PIJ), and the World Islamic
Studies Enterprise forced the closure of several front companies
suspected of funneling money to support PIJ operations against
Israel. In August 2002, the investigation led to the deportation
of Mazen Al-Najjar, the brother-in-law of Sami Al Arian
and a known PIJ member. In February of 2003, following a
50-count indictment for RICO and Material Support of Terrorism
violations, the FBI arrested Al-Arian and three other US-based
members of the PIJ, including Sameeh Hammoudeh, Hatim Naji
Fariz, and Ghassan Ballout. The FBI also executed seven
search warrants associated with this action.
In
February of 2004, the FBI executed search warrants on the
Ashland, Oregon office of Al Haramain Islamic Foundation,
Inc. (AHIF). AHIF is one of Saudi Arabia's largest non-governmental
organizations (NGO) with offices located throughout the
world. AHIF's stated mission is to provide charitable services
and Islamic education around the world. Based upon AHIF's
claim to be a public benefit corporation organized exclusively
for religious, humanitarian, educational and charitable
purposes, the IRS granted AHIF tax-exempt status. The warrants
were executed to further the investigation of criminal violations
of Currency and Monetary Instrument reporting requirements
by AHIF principals and subscribing to a false informational
tax form. The investigation specifically focuses on a series
of transactions involving traveler's checks cashed out of
country and the mischaracterization of funds received by
AHIF.
TFOS
is assisting coalition forces in Iraq in efforts to identify,
disrupt, and dismantle the financial infrastructure of terrorist
groups that are, or are planning to, attack coalition forces.
TFOS
has provided operational support to FBI Field Divisions
and JTTFs across the United States to enhance their intelligence/criminal
investigations of individuals and groups associated with,
or providing material support to, terrorist organizations
and activities. This assistance is provided in the form
of conducting intelligence/criminal financial investigations,
financial analytical support, major case management, financial
link analysis, and the deployment of teams of experts to
develop investigative plans to analyze large volumes of
documents and data. TFOS has provided this type of operational
support in Al Qa'ida cases in Buffalo and Portland, as well
as in the Richard Reid, John Walker Lindh, Al Haramain,
PIJ, and Mohamed Al-Moayad cases, among many others. This
type of operational support has also been provided to Divisions
investigating non-governmental organizations (NGOs), such
as the Holy Land Foundation for Relief and Development,
Benevolence International Foundation and the Global Relief
Foundation.
Since
9/11, the U.S. Government has blocked $36.3 million in terrorist
assets located domestically, while the international community
has blocked over $136 million, for a total of over $172
million. The FBI has provided assistance to both its U.S.
Government partners and the international community by showing
the definitive links to known terrorist organizations.
The
Treasury and State Departments have issued blocking orders
on the assets of more than 340 terrorists, terrorist organizations,
and terrorist supporters, many of them identified by the
FBI, effectively denying them access to the US financial
system.
Federal
law enforcement officials, working with the FBI in the JTTFs,
have arrested over 61 individuals, indicted 47 and convicted
14 in connection with terrorist financing investigations.
US
Government agencies, to include the FBI's TFOS, deployed
trainers and advisers on missions to countries around the
world to assist with the drafting of legislation to combat
terrorist financing, strengthen bank supervision in identifying
suspicious transactions, and address other financial crimes
and corruption. Since 9/11/01, over 80 countries have introduced
new terrorist-related legislation and approximately 84 countries
established Financial Investigation Units.As previously
noted, TFOS has conducted near real-time financial tracking
of a terrorist cell and provided specific and identifiable
information to a foreign intelligence agency, which resulted
in the prevention of six, potential deadly terrorist attacks.It
should be noted that the above examples do not include the
many classified intelligence successes that have directly
contributed to the prevention or disruption of terrorist
activities.
The use of information technology to better identify and
isolate suspicious transactions related to terrorist financing:
The FBI has a responsibility to be not only reactive but
proactive, and to think strategically about potential threats
and future case development. Accordingly, TFOS, together
with the Counter-Terrorism Section, Criminal Division of
the Department of Justice, has begun a number of proactive
initiatives to identify potential terrorists and terrorist
related financing activities.The overriding goal of these
projects is to proactively identify potential terrorists
and terrorist related individuals, entities, mechanisms
or schemes through the digital exploitation of data. To
accomplish this, TFOS seeks to 1) identify potential electronic
data sources within domestic and foreign government and
private industry providers; 2) create pathways and protocols
to legally acquire and analyze the data; and 3) provide
both reactive and proactive operational, predictive and
educational support to investigators and prosecutors.Utilizing
the latest computer technology available, the Counterterrorism
Division serves as a proactive, financial intelligence investigative
management and support team. TFOS generates leads for other
FBI components and proposes and conducts proactive financial
intelligence initiatives and projects. TFOS works closely
with other operational units and document exploitation initiatives
to ensure financial intelligence is being fully exploited
and disseminated.
TFOS has conducted an extensive review of data mining software
and link analysis tools currently utilized by other governmental
and private industries for consideration of use by the FBI.
TFOS also participates in the FBI's SCOPE Intelligence Data
Warehouse (IDW) User Management Group and has been involved
in the development and planning for future enhancements
to the IDW. TFOS's Proactive Exploitation Group (PEG) has
created an interactive, computer playbook generator that
can assist investigators in determining data sources to
be queried, based upon the quantity and quality of their
investigative data.TFOS has initiated several projects to
integrate data from its internal financial database, open/public
source data and FBI and other government data sources onto
a central query platform. Through this process, and in concert
with contract vendors working for the SCOPE IDW Project,
TFOS has developed a process whereby it can batch query
multiple databases. This has the potential to save the FBI
hundreds, if not thousands, of hours of data input and query
time on each occasion it is utilized. Furthermore, it facilitates
rapid acquisition and sharing of information with other
agencies. Through the sophisticated tools being utilized,
and the matching protocols developed, TFOS can ensure each
query is properly conducted and done to a best practices
query standard. Recently, TFOS utilized the batch process
it developed to exploit over three thousand identifiers.
The batch process accomplished in hours what would have
taken TFOS personnel and FBI Field Offices over 4,300 man-hours
to conduct. Furthermore, because TFOS conducted the queries
in batch form, and has global access to all of the search
results, previously unidentified links, patterns and associates
among the data can now be extracted. Absent the batch process,
this would have been extremely difficult, if not impossible,
to accomplish.
TFOS
has initiated a variety of proactive data mining projects
to identify potential terrorists and terrorist financing.
The projects were conceived in 2002 and now, with the advent
of certain software tools and data access, are either being
implemented or will begin shortly.
An example of this is the Terrorist Risk Assessment Model
(TRAM), which seeks to identify potential terrorist and
terrorism financing activity through the use of targeted,
predictive pattern recognition algorithms. The project entails
the compilation of past and current known data regarding
individual and group terrorist activity, methodologies,
demographics, financial patterns, etc., to form a predictive
pattern recognition program.
It is important to understand that these projects and similar
initiatives by TFOS seek only to more fully exploit information
already obtained by the FBI in the course of its investigations
or through the appropriate legal process, and where there
is an articulated law enforcement need. TFOS does not seek
access to personal or financial information outside these
constraints.
National Money Laundering StrategyWith respect to the 2003
National Money Laundering Strategy, the FBI concurs with
the strategy's goals and objectives. The blocking of terrorist
assets worldwide, establishing and promoting of international
standards for adoption by other countries to safeguard their
financial infrastructures from abuse and facilitating international
information are several key objectives which must be achieved
if law enforcement and regulatory agencies are to have any
success in stemming the flow of illegal funds throughout
the world. Within the FBI, the investigation of illicit
money flows crosses all investigative program lines.
The number one priority of the FBI is prevention of terrorism.
To prevent terrorist acts, all investigative and analytical
tools of the U.S. Government must be strategically applied,
in a cohesive manner, through the JTTFs.
Our efforts to combat terrorism have been greatly aided
by the provisions of the PATRIOT Act and, pursuant to the
2003 National Money Laundering Strategy, the FBI is ensuring
its vigorous and appropriate application. It has already
proven extraordinarily beneficial in the war on terrorism.
Most importantly, the PATRIOT Act has produced greater collection
and sharing of information within the law enforcement and
intelligence communities.
Title III of the Act, also known as the International Money
Laundering Anti-Terrorist Financing Act of 2001, has armed
us with a number of new weapons in our efforts to identify
and track the financial structures supporting terrorist
groups. Past terrorist financing methods have included the
use of informal systems for transferring value in a manner
that is difficult to detect and trace. The effectiveness
of such methods should be significantly eroded by the Act,
which establishes stricter rules for correspondent bank
accounts, requires securities brokers and dealers to file
Suspicious Activity Reports or SARS, and money transmitting
businesses, which include any person who engages as a business
in the transmission of money, to register with the Financial
Crimes Enforcement Network (FinCEN) and file SARS.
There are other provisions of the Act that have considerably
aided our efforts to address the terrorist threat including:
strengthening the existing ban on providing material support
to terrorists and terrorist organizations; the authority
to seize terrorist assets; and the power to seize money
subject to forfeiture in a foreign bank account by authorizing
the seizure of funds held in a US correspondent account.The
FBI has utilized the legislative tools provided in the USA
PATRIOT Act to further its terrorist financing investigations.
It is important for the Committee and the American people
to know that we are using the PATRIOT Act authorities in
a responsible manner. We are effectively balancing our obligation
to protect Americans from terrorism with our obligation
to protect their civil liberties.
Terrorism represents a global problem. The FBI is committed
to its U.S. and international partnerships and to effectively
sharing information to protect our nation from terrorism.
To meet this goal, the FBI has formed the International
Terrorism Financing Working Group (ITFWG), which includes
law enforcement and intelligence agency representatives
from the United Kingdom, Canada, Australia and New Zealand,
and addresses the international aspect of terrorist financing
investigations.
Alternate Financing Mechanisms
In its latest report assessing the use of alternate financing
mechanisms by terrorists, GAO recommended that, "The
Director of the FBI should systematically collect and analyze
data concerning terrorists' use of alternative financing
mechanisms". The FBI has already implemented some measures
to address the GAO's recommendation, and plans to implement
additional measures by April 30, 2004 which address concerns
identified in the GAO report.
The FBI has established specifically defined intelligence
requirements used to guide the Bureau's collection efforts
within its Office of Intelligence. As a result, we developed
specific intelligence requirements, which are tied to various
known indicators of terrorist financing activity.
TFOS has developed statistical queries in the FBI's CT Annual
Field Office Report (AFOR) pertaining to terrorist financing.
Included in this reporting are responses to the tracking,
locating, and monitoring of subjects of terrorism investigations
through the identification of emerging trends pertaining
to terrorist financing techniques, including alternative
financing mechanisms discovered through other criminal investigations.
TFOS has established the Program Management and Coordination
Unit (PMCU), which will be responsible for, among other
things, tracking various funding mechanisms used by many
different subjects in ongoing investigations - to include
alternative financing mechanisms. The PMCU will be well
positioned to identify emerging trends across the spectrum
of terrorist financing.
Measures to collect and analyze data concerning terrorists'
use of alternative financing mechanisms will greatly enhance
our ability to recognize, respond to, and ultimately disrupt
or dismantle terrorist organizations reliant upon them.
Through the international partnerships that we have established,
additional sources from which to obtain similar information
regarding alternative financing mechanisms are of great
mutual benefit. The FBI intends to maintain and encourage
liaison and relationships with our law enforcement colleagues
both in the United States and all over the world to ensure
that new methods of terrorism financing, as well as current
ones, are accurately tracked and monitored.
Again, I offer my gratitude and appreciation to you, Chairman
Grassley, as well as the distinguished members of this Caucus,
for dedicating your time and effort to this issue, and I
would be happy to respond to any questions you may have.
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