A 1995 Department of Justice memorandum states that the procedures her memorandum put in place for the investigation of the 1993 WTC bombing "go beyond what is legally required...[to] prevent any risk of creating an unwarranted appearance that FISA is being used to avoid procedural safeguards which would apply in a criminal investigation." The wall intentionally exceeded the requirements of FISA (the Foreign Intelligence Surveillance Act of 1978) for the purposes of criminal investigations, as well as the then-existing federal case law. These rules were, shortly after their creation, expanded to regulate such communications in future counter-terrorism investigations.