Testimony of Dennis M. Lormel, Chief, Financial Crimes Section,
FBI
Before
the House Committee on Financial Services, Subcommittee
on Oversight and Investigations
February 12, 2002
Good
afternoon Madam Chairman and members of the Subcommittee on
Oversight and Investigations. On behalf of the Federal Bureau
of Investigation (FBI), I would like to express my gratitude
to the Subcommittee for affording us the opportunity to participate
in this forum and to update the Subcommittee on what the FBI
has learned since the September 11, 2001, terrorist attacks
about the patterns of financing associated with Al Qaeda and
global terrorist networks, and the extent to which U.S. anti-money
laundering statutes provide the necessary tools to detect
and disrupt those patterns.
As this
Subcommittee is well aware, the FBI, in conjunction with law
enforcement and intelligence agencies throughout the U.S.
and the world, is engaged in the largest, most complex and
perhaps the most critical criminal and terrorism investigation
in our history. The FBI continues to dedicate considerable
resources to this investigation and remains committed to determining
the full scope of these terrorist acts, identifying all those
involved in planning, executing and/or assisting in any manner
the commission of these acts and others, and bringing those
responsible to justice. The investigation does not end at
the events surrounding September 11th, our mission extends
far beyond that in the FBI's key leadership role in the global
war on terrorism. First and foremost among our priorities,
however, is taking all possible steps to prevent the occurrence
of any additional acts of terrorism.
The war
on terrorism will be a long-term battle. It will not be won
overnight nor will it be won without the highest levels of
cooperation and coordination among law enforcement and intelligence
agencies around the globe. Terrorism knows no borders or boundaries.
The threat is not limited to any one region of the world.
Law enforcement and intelligence agencies throughout the world
possess tremendous resources and expertise. Allying these
resources against the common enemy of terrorism is the key
to dismantling these organizations and eliminating the threat
they pose. Make no mistake about it, even with the combined
resources and expertise possessed by law enforcement, the
threat posed by terrorism is grave. Terrorists do not play
by the rules of a civilized society, nor do they respect human
decency. They will stop at nothing to commit acts of terror.
Fighting the war on terrorism requires powerful tools. The
FBI appreciates the powerful tools provided by this Subcommittee
and all of Congress in enacting the USA PATRIOT ACT, including
Title III enhancements, the International Money Laundering
Abatement and Financial Terrorism Act of 2001, and believes
they will play a key role in addressing terrorist financing
matters.
Success in the war on terrorism cannot be measured merely
in the form of assets seized or funds blocked, but in the
ability of law enforcement to prevent future acts of terrorism.
Whether it be through prosecution, disruption, blocking/freezing
of funds, or allowing a funding mechanism to remain in place
in order to further an investigation, prevention remains the
overarching focus. Different circumstances demand different
approaches. The best strategy in any given circumstances can
only be determined from an overall perspective. It demands
careful coordination with and the cooperation of all law enforcement
and intelligence agencies involved in an investigation. The
FBI and the Department of Justice (DOJ) have primary jurisdiction
in all terrorism related investigations, whether they pertain
to past terrorist acts, terrorist related intelligence investigations,
or terrorist financing investigations. The acts of terrorism
on September 11th highlighted the need for a comprehensive
law enforcement response to international terrorism. With
the help of Congress, the FBI had previously established joint
terrorism task forces (JTTF) in key areas of the country which
brought together the combined expertise and resources of other
local, state, and federal law enforcement agencies. By the
end of 2003, we expect to have a JTTF in each of the FBI's
56 field offices.
Identifying,
tracking, and dismantling the financial structure supporting
terrorist groups is critical to successfully dismantling the
organization and preventing future terrorist attacks. As is
the case in so many types of criminal investigations, identifying
and "following the money" plays a critical role
in identifying those involved in the criminal activity, establishing
links among them, and developing evidence of their involvement
in the activity. In the early stages of the investigation
into the events of September 11, it was financial evidence
that quickly established direct links among the hijackers
of the four flights and helped identify co-conspirators.
Financial
Review Group
In order
to provide a comprehensive analysis of the financial evidence,
the DOJ and FBI established an inter-agency Financial Review
Group (FRG) operating out of FBI Headquarters. Other participants
in the FRG include representatives of the Central Intelligence
Agency, National Security Agency, Defense Intelligence Agency,
Drug Enforcement Agency, and components of the Treasury Department
including the U.S. Customs Service, Internal Revenue Service,
Bureau of Alcohol, Tobacco and Firearms, Office of Foreign
Asset Control (OFAC), United States Secret Service and Financial
Crimes Enforcement Network, U.S. Postal Inspection Service,
National Drug Intelligence Center, the Federal Reserve, and
the Inspector General Community. From the initial focus on
the events of September 11th, the mission of the FRG has evolved
into a broader strategy to investigate, prosecute, disrupt,
and dismantle all terrorist-related financial and fund-raising
activities. In the days immediately following September 11th,
the FRG was formed with a two-fold mission. On one track,
a comprehensive financial analysis of the 19 hijackers was
conducted to link them together and to identify their financial
support structure within the U.S. and abroad. Collateral to
this was the development of a template for pro-active, preventive,
and predictive terrorist financial investigations. The FRG
has taken a leadership role in coordinating the financial
investigative effort, and it is a comprehensive, far reaching
effort. To accomplish our mission, the FRG has implemented,
and continues to implement, strategies and initiatives to
address all aspects of terrorist financing and explore all
options. Among these are efforts to organize, catalog, and
review vast amounts of personal and business records, develop
linkage and time lines concerning terrorist cells and groups,
facilitate Mutual Legal Assistance Treaty requests and Letters
Rogatory, develop financial and investigative leads in support
of terrorism investigations, identify criminally-related fund-raising
activities by terrorist organizations, utilize the resources
and expertise of the financial services community, develop
a centralized financial database, and develop predictive analysis
models. By bringing together participating agencies' databases
and expertise, the FRG is focusing a powerful array of resources
at the financial structure of terrorist organizations. Throughout
this process, the FRG has worked closely with the Department
of Treasury, which has primary responsibility for the blocking
and freezing of terrorist assets.
Through the FBI's historical involvement with the intelligence
community, the FBI and CIA quickly coordinated and further
combined their resources to investigate terrorist funding
mechanisms. This relationship facilitates a seamless interaction
between the FBI and intelligence community, and is in addition
to other key personnel the CIA and FBI each currently have
assigned to the other's headquarters. The FBI in its intelligence
capacity also obtains considerable intelligence information
through Foreign Intelligence Surveillance Act orders. The
FRG works closely with this aspect of the FBI's Counterterrorism
program in assessing and applying proper utilization of such
information, pursuant to Attorney General Guidelines and the
orders of the Foreign Intelligence Surveillance Court.
The FRG
has created and continues to develop a centralized terrorist
financial database in concert with coordinating and assisting
in the financial investigation of over 250 individuals and
groups who are suspects of FBI terrorist investigations. To
date, the FRG has cataloged and reviewed over 321,000 financial
documents obtained as a result of numerous financial subpoenas
pertaining to over 10,500 individuals and accounts. Over 104,000
of these documents have been verified as being of investigatory
interest and have been entered into the terrorist financial
database for linkage analysis. The FRG has obtained financial
information from 54 FBI Field Divisions and 11 Legal Attache
Offices, and has reviewed and documented over 66,000 financial
transactions. These records include over 149 foreign bank
accounts and over 5,300 foreign wire transfers.
The FRG is both an operational and coordinating entity with
pro-active and reactive responsibilities. There are any number
of approaches that can be utilized in investigating these
networks. Success lays in careful coordination of these approaches.
By way of example, various FBI Field Offices have launched
criminal financial investigative initiatives geared at fraud
schemes with a potential nexus to terrorist financing. The
FRG is coordinating these initiatives as I will discuss later
in my statement. As an operational body, the FRG conducts
national and international investigations from its headquarters
in Washington, D.C., while collecting information and directing
leads to the JTTFs located in each Judicial District, as well
as leads to other FBI Field and Legal Attache Offices around
the world.
As a participant on the National Security Council's Policy
Coordinating Committee (PCC) on terrorist financing, chaired
by Treasury Department General Counsel David Aufhauser, the
FRG continues to function in a leadership role in the efforts
to target Non-Governmental Organizations (NGOs) believed to
provide financial support to known Foreign Terrorist Organizations
(FTO) and other affiliated terrorist cells. The FRG is currently
actively involved in the coordination of twelve multi-jurisdictional
NGO investigations. In order to disrupt the terrorist financing
channels, the FRG has coordinated these and other FBI terrorist
investigations with the terrorist designation and asset freezing
efforts of the Department of Treasury's Office of Foreign
Assets Control (OFAC) and Operation Green Quest. These efforts
have resulted in the freezing of millions of dollars in foreign
and U.S. bank accounts. Specifically, the joint efforts targeting
Al-Barakaat, the Holy Land Foundation for Relief and Development,
the Global Relief Foundation, and the Benevolence International
Foundation have resulted in the execution of numerous search
warrants and the disruption of the fund-raising and money
remittance operations of these and other NGOs. Financial investigations
of these entities have revealed that approximately $200 million
in contributions passed through these organizations each year.
The FRG will also coordinate with the Department of the Treasury
in its other initiatives in order to help ensure their success.
The FRG
has conducted an aggressive national and international outreach
initiative in an effort to share information regarding terrorist
financing methods with the financial community and law enforcement.
The review group has built upon long-established relationships
with the banking, debit, credit and financial services communities
in the United States and abroad. The international outreach
initiative is coordinated through the network of FBI Legal
Attache Offices located in 44 key cities worldwide, providing
coverage for over 200 countries, territories, and islands.
The FRG has become an international model for investigating
the financial components of terrorism. As a result, the FRG
has assisted several foreign countries in their efforts to
establish a financial terrorist investigative component that
mirrors the structure of the FRG.
A significant focus of the FRG is predictive/preventive analysis.
In this capacity, the FRG conducts data mining and financial
profiling to identify common characteristics of terrorist
financing. The FRG has developed numerous data mining projects
in order to provide further predictive abilities and maximize
the use of both public and private database information. This
information will be used to identify terrorist cells operating
in the U.S. and abroad in an effort to prevent further terrorist
acts. Through the FRG's aggressive national and international
outreach and liaison efforts, appropriate information regarding
patterns and profiling is shared and coordinated with appropriate
private and public sector entities. For example, the FRG meets
regularly with representatives from the banking community
and the financial services industry to share such information
and to jointly develop and refine methods to detect and identify
potential terrorist and/or terrorist activity. The FRG is
also reviewing and conducting additional financial analysis
of prior terrorist acts in an effort to identify links and
patterns that would complement current and future terrorism
investigations.
The FRG directly supports the FBI's Counterterrorism Division
through financial analysis of terrorism investigations. While
the FRG plays a key role in the overall Counterterrorism effort,
it is but one piece of the big picture. Accordingly, careful
coordination at all times is critical to ensure financial
investigations complement the overall strategy and do not
adversely impact other efforts. Based on the FRG's role in
the FBI's Counterterrorism Division, its international investigative
abilities, and its close association with the intelligence
community, the review group is in a unique position to coordinate
anti-terrorism financial investigations domestically and internationally,
and to ensure those investigations are in harmony with the
overall goals and objectives of the United States' Counterterrorism
program.
Anti-terrorism
financial investigations represent a comprehensive labor intensive
long-term commitment. It is anticipated that in order to prepare
predictive analysis in support of this effort, tens of millions
of financial documents (bank records, travel records, credit
card, and retail receipts, etc.) will need to be collected,
thoroughly analyzed, and placed in a central database for
relevant financial evidence. This evidence can then be integrated
with other terrorist evidence collected by law enforcement
and others. As I previously stated, the FRG has initiated
a number of data mining projects in order to fully exploit
the growing financial database and pro-actively identify and
target potential terrorists and terrorist activity. This includes
the use of predictive pattern recognition algorithms.
Given
the enormity of the task and the long-term nature of the effort,
I cannot sit here today or next week and tell you we have
all the answers. It will take time to effectively and pro-actively
address terrorism financing. This is not to say that progress
hasn't been made. In conjunction with pro-active long-term
efforts, the FRG continues to aggressively conduct intensive
financial investigations as circumstances arise; dedicating
necessary resources to react immediately to new information
and evolving events. The FRG has made substantial progress
in our efforts and I would like to offer this Subcommittee
a brief summary of this progress, subject of course to restrictions
related to the disclosure of information that might compromise
or undermine ongoing criminal investigations.
We have
focused our financial investigations in four main areas: (1)
mission specific terrorist cells such as the 19 hijackers,
(2) so called "sleeper" cells that are more loosely
organized but blend into communities easier through legitimate
employment, (3) terrorist groups that fund their terrorist
activity through fraud schemes, and (4) the funding of terrorist
organizations through Non-Governmental Organizations (NGO)
and charities. I would like to focus the remainder of my statement
on describing what we are doing in these areas and what progress
has been made.
Mission
Specific Terrorist Cells
Through
financial information, we have established how the hijackers
responsible for the September 11 attacks received their money,
details of their flight training, where they lived, and details
concerning individuals associated with the hijackers. The
19 hijackers opened 24 domestic bank accounts at four different
banks. The following financial profile was developed from
the hijackers' domestic accounts:
ACCOUNT
PROFILE
- Accounts
were opened with cash/cash equivalents in the average amount
of $3,000 to $5,000.
- Identification
used to open the accounts were visas issued through Saudi
Arabia or the U.A.E.
- Accounts
were opened within 30 days after entry into the U.S.
- All
accounts were normal checking accounts with debit cards.
- None
of the hijackers had a social security number.
- They
tended to open their accounts in groups of three or four
individuals.
- Some
of the accounts were joint accounts with other
- Addresses
used usually were not permanent (i.e. mail boxes, etc.)
and changed frequently.
- Hijackers
would often use the same address/telephone numbers on the
accounts.
No savings accounts or safe deposit boxes were opened.
- Hijackers
would open their accounts at branches of large well known
banks.
- The
majority of hijackers (12) opened accounts at the same bank.
TRANSACTION
PROFILE
- Some
accounts would directly receive/send wire transfers of small
amounts to foreign countries - UAE, Saudi Arabia, Germany.
- Hijackers
would make numerous attempts of cash withdrawals which often
would exceed the limit of the debit card.
- High
percentage of withdrawals were from debit cards vs. low
percentage of checks written.
- Numerous
balance inquiries were made.
- Hijackers
would often travel domestically.
There was a tendency to use Western Union to wire money.
- One
deposit would be made and then the money would trickle out
a little at a time.
- Account
transactions did not reflect normal living expenses for
rent, utilities, auto payments, insurance, etc.
- There
was no normal consistency with timing of deposits/disbursements.
- Funding
for normal day to day expenditures was not evident from
transactions.
- Overall
transactions are below reporting requirements.
- Funding
of the accounts dominated by cash and overseas wire transfers.
- ATM
transactions occur where more than one hijacker present
(uninterrupted series of transactions involving several
hijackers at the same ATM).
- Use
of debit cards by hijackers who did not own affected accounts.
INTERNATIONAL
ACTIVITY
- Three
of the hijackers supplemented their financing by opening
foreign checking accounts and credit card accounts at banks
located in the UAE.
- While
in the U.S., two of the hijackers had deposits made on their
behalf by unknown individuals.
- Hijackers
on all four flights purchased traveler's checks overseas
and brought them to the U.S. These traveler's checks were
partially deposited into their U.S. checking accounts.
- Three
of the hijackers (pilots/leaders) continued to maintain
bank accounts in Germany after moving to the U.S.
- Two
of the hijackers (pilots/leaders) had credit cards issued
by German banks and maintained those after moving to the
U.S.
- It
is suspected that other unknown foreign accounts exist that
were opened by the hijackers to further supplement the financing
of the September 11, 2001, attacks.
- One
of the hijackers (pilot/leader) received substantial funding
through wire transfers into his German bank account in 1998
and 1999 from one individual.
- In
1999, this same hijacker opened an account in the UAE, giving
power of attorney over the account to this same individual
who had been wiring money to his German account.
- More
than $100, 000 was wired from the UAE account of the hijacker
to the German account of the hijacker in a 15-month period.
NON-FINANCIAL
PROFILE
- Hijackers
ranged in age from early 20s to mid 30s.
- Born
in Middle Eastern country.
- Limited
use of the English language.
- They
mainly used bank branches located in high Muslim areas.
- Usually
came into bank in groups to open accounts.
- Usually
there was one spokesman for the group.
- May
not want to deal with women bank personnel.
- Wanted
to deal with one person at bank.
Sleeper
Cells
One pattern
of terrorist financing that has emerged involves Al Qaeda
cells in Europe. Financial investigation has identified cells
that derive income from legitimate employment/businesses within
the European country in which the cell exist. For example,
one company run by cell members provided home repairs involving
masonry, plumbing, electrical wire, etc., and hired mujahadin
arriving from areas of conflict, such as Bosnia. Another enterprise
operated by cell members purchased dilapidated automobiles,
repaired them, and resold them. The cars were purchased in
one European country and resold in the country where the cell
was located. Other investigations have identified cell members
transferring money between accounts with little attempt to
hide the transactions. Accounts have been funded by salaries
and government payments for students, and members of the cell
were supported by family members to some extent. They appeared
to be living day to day and not funneling funds through their
accounts. Terrorist funds were deposited into the accounts
either by cash or wire transfer. Most of the money went through
one or two persons' accounts. Not all members of the cell
were receiving monies. Money was spent from the accounts through
ATM or other cash disbursements. The German terrorist cell
operated in much this same fashion.
The FRG has conducted extensive analysis related to the Al
Qaeda cell that was based in Germany which included among
its members Ramzi Bin al-Shibh and hijackers Mohamed Atta
and Marwin Al-Shehhi. This analysis was instrumental in linking
the hijackers and their ties to Al Qaeda, determining the
support it provided to the events of September 11th, and establishing
other ties to the Al Qaeda organization. It also established
links between the German cell, the hijackers and Zacarias
Moussaoui that contributed to the indictment of Moussaoui
for his role in the September 11th attacks. This analysis
included tracing wire transfers from Bin al-Shibh to Moussaoui.
FRG financial investigation has also helped establish links
between Moussaoui and an Al Qaeda cell in Malaysia. Authorities
in Malaysia have arrested and charged a number of the members
of this cell. It should be noted that Bin al-Shibh was one
of the five terrorists appearing in videos recovered from
an Al Qaeda location in Afghanistan which were recently released
by the DOJ. The videos appear to show Bin al-Shibh and the
others discussing preparations to commit terrorist acts. The
FRG is conducting financial investigations on the other four
terrorists featured in the videos in order to help track them
down.
In addition,
the FRG is conducting financial investigations involving hundreds
of subjects associated with terrorism investigations being
conducted in various foreign countries in an effort to identify,
track, and locate associates, funding sources, other cell
members, etc.
Terrorist
Funding Through Criminal Activity
Another
pattern of terrorist financing involves funding of terrorist
cell activities through various criminal activity. Al Qaeda
has been known to encourage and instruct terrorist cells in
terrorist training camps in Afghanistan in ways they can fund
their terrorist activities through various criminal activity.
For example, Ahmed Ressam, the Algerian extremist convicted
in the terrorist plot to place bombs at Los Angeles International
Airport among other locations, was instructed in these camps
to engage in criminal activity such as bank robberies and
fraud schemes to fund his terrorist activities. As another
example, investigation has identified a terrorist cell based
in Spain with ties to Al Qaeda that used stolen credit cards
in fictitious sales scams and for numerous other purchases
for the cell. They kept purchases below amount where identification
would be presented. They also used stolen telephone and credit
cards for communications back to Pakistan, Afghanistan, Lebanon,
etc. Extensive use of false passports and travel documents
were used to open bank accounts where money for the mujahadin
movement was sent to and from countries such as Pakistan,
Afghanistan, etc. In addition, the cell relied upon street
crimes such as home burglary, car theft, and car burglary
to fund their cell activities.
NGOs
The funding
of terrorist organizations such as Al Qaeda and Hamas through
NGOs and charitable organizations represents a significant
challenge to law enforcement and is a prime focus of terrorist
financial investigations. International radical fundamentalist
terrorist organizations have increasingly utilized NGOs as
fund-raising vehicles for their terrorist activities. NGOs
may also offer terrorists logistical support in the form of
cover employment, false documentation, travel facilitation,
and training. Financial investigation conducted prior to September
11th and since identified the Holy Land Foundation for Relief
and Development (HLFRD), a Texas based charity, as an alleged
North American "front" for the terrorist organization
Hamas. On December 4, 2001, the President, along with the
Attorney General and the Secretary of the Treasury, announced
the designation and blocking action against HLFRD. NGOs may
be large international organizations which can be exploited
by individual employees sympathetic to terrorist causes through
local branch offices; they may be private NGOs which exist
solely to support a militant cause; or they may be closely
affiliated with a state sponsor of terrorism. One of the challenges
in investigations involving terrorist fund-raising through
NGOs is distinguishing terrorist fund-raising activities from
legitimate or what may appear to be legitimate charitable
fund-raising. The line is often blurred. It should be noted
that it is illegal to knowingly provide any form of financial
or material support to a group designated as a foreign terrorist
organization, even if the provider intends such support to
be used by the terrorist organization for non-terrorist purposes.
Fund-raising on the part of terrorist groups which on the
surface appear to be efforts to "help the poor"
or fund-raising for charitable, humanitarian, or other legitimate
purposes actually falls squarely in the realm of logistical
support for terrorist activity. Another trend that has been
identified involves the funneling and/or laundering of terrorist
funds raised outside the U.S. through the U.S. on its way
to the Middle East.
Terrorist financing methods range from the highly sophisticated
to the most basic. There is virtually no financing method
that has not at some level been utilized by terrorists and
terrorist groups. Traditionally, their efforts have been aided
considerably by the use of correspondent bank accounts, private
banking accounts, offshore shell banks, Hawalas, bulk cash
smuggling, identity theft, credit card fraud, and other criminal
operations such as illegal drug trafficking. We are optimistic
that provisions of the USA PATRIOT Act enacted by this Congress
will significantly erode the effectiveness of many of these
methods.
One of
the means by which terrorists and terrorist organizations
seek to avoid detection is by operating in a manner that does
not raise red flags, thereby falling below the financial radar
screen. The FRG has assumed a leading role in coordinating
the efforts of the financial services industry to assist in
the terrorism investigations. The FRG has built upon long-established
relationships with the banking, debit, credit, and financial
services community in the U.S. and abroad. The level of cooperation
by U.S. financial institutions has been outstanding, and nothing
short of extraordinary. These institutions possess considerable
resources and expertise. In all respects, they have gone all
out to provide subpoenaed information as expeditiously as
possible, and have done everything possible within the legal
framework to provide cooperation. In return, the FRG has utilized
our aggressive national and international outreach initiative
in an effort to regularly share information regarding terrorist
financing methods with the financial community. This has provided
new red flags and patterns of which the financial community
should be aware.
Another
example reflecting the significantly expanded FRG role involves
terrorists' attempts to fund their terrorist activities through
fraud schemes. Recognizing that terrorist cells may fund terrorist
activity through various fraud schemes and that such activity
could potentially fall beneath the financial radar screen,
a number of FBI Field Offices have launched comprehensive
initiatives to address this threat. These initiatives, which
are being coordinated and assisted by the FRG, seek to target
fraud schemes being committed by organized groups having a
potential nexus to terrorist financing. Targeting this type
of activity and pursuing the links to terrorist financing
will likely result in the identification and dismantlement
of previously unknown terrorist cells. Prior to September
11, and the formation of the FRG, this type of terrorist financing
often avoided law enforcement scrutiny. No longer. The FBI
and FRG will leave no stone unturned in our mission to cut
off the financial lifeblood of terrorists.
U.S.
authorities possess powerful tools to detect and disrupt terrorist
financing, aided considerably by the provisions of the USA
PATRIOT Act. While we are optimistic the provisions of the
Act will have strong impacts, it is too early to judge their
full usefulness at this stage. Eagerness to utilize the new
tools provided in the Act must be tempered by the need for
law enforcement and the DOJ to gain a complete understanding
of the provisions, develop guidelines and protocols for their
appropriate use, and educate investigators and prosecutors.
In addition, many of the provisions require the Department
of Treasury to issue new regulations and rules. While all
of this is being done as expeditiously as possible, the full
impact of the tools provided by the PATRIOT Act are yet to
be seen. In regards to any remaining loopholes in our statutory
and regulatory regimes, the FBI will defer to our colleagues
from the DOJ.
CONCLUSION
Cutting
off the financial lifeblood of individuals and organizations
responsible for acts of terrorism is a vital step in dismantling
the organization and preventing future terrorist acts. The
FBI is leading law enforcement efforts to accomplish this
mission. The USA PATRIOT Act has provided law enforcement
with powerful new tools to assist in accomplishing this mission.
The FBI welcomes the opportunity to work with this Subcommittee
and others to ensure that law enforcement efforts can be the
most effective. I would welcome any questions you may have
at this time. Thank you.
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