JSOU Report 08-3 Disrupting Threat Finances Anderson
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Resident Senior Fellows

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Fletcher School, Tufts University 

and JSOU Senior Fellow

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Fellow

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Security Policy, U.S. Army War 

College and JSOU Associate Fellow
On the cover. Undated photo shows an Al Qaeda member in 

Algeria. In the first week of September 2007, two major suicide

attacks struck Algeria, and one of them targeted President 

Bouteflika’s motorcade. Photo by Balkis Press, used by permission of Newscom. 

JSOU Report 08-3

The JSOU Press

Hurlburt Field, Florida

2008

Disrupting

Threat Finances

Using Financial Information

to Disrupt Terrorist Organizations

Wesley J.L. Anderson
Comments about this publication are invited and should be forwarded 

to Director, Strategic Studies Department, Joint Special Operations 

University, 357 Tully Street, Alison Building, Hurlburt Field, Florida

32544. Copies of this publication may be obtained by calling JSOU at

850-884-1569; FAX 850-884-3917.

*******

The Strategic Studies Department, JSOU is currently accepting written 

works relevant to special operations for potential publication. For more 

information please contact Mr. Jim Anderson, JSOU Director of Research, 

at 850-884-1569, DSN 579-1569, james.d.anderson@hurlburt.af.mil.

Thank you for your interest in the JSOU Press. 

*******

This work was cleared for public release; distribution is unlimited.

ISBN 1-933749-19-9
The views expressed in this publication are entirely those of 

the author and do not necessarily reflect the views, policy

or position of the U.S. Government, Department of Defense, 

United States Special Operations Command, or the Joint 

Special Operations University.
Recent Publications of the JSOU Press

Narcoterrorism in Latin America, April 2006,

Alvaro de Souza Pinheiro

The Changing Nature of Warfare, the Factors Mediating Future 

Conflict, and Implications for SOF, April 2006, John B. Alexander

Civil-Military Operations and Professional Military Education, 

May 2006, James F. Powers, Jr.

Blogs and Military Information Strategy, June 2006,

James Kinniburgh and Dorothy Denning

2006 JSOU/NDIA SO/LIC Chapter Essays, June 2006

One Valley at a Time, August 2006, Adrian T. Bogart III

Special Operations Aviation in NATO, September 2006,

Richard D. Newton

Beyond Draining the Swamp: Urban Development and 

Counterterrorism in Morocco, October 2006, Stephen R. Dalzell

Filling Special Operations Gaps with Civilian Expertise,

December 2006, James F. Powers, Jr.

Educating for Strategic Thinking in the SOF Community,

January 2007, Harry R. Yarger

The Israeli Approach to Irregular Warfare and Implications for the U.S.,

February 2007, Thomas H. Henriksen

Psychological Operations: Learning Is Not a Defense Science Project,

March 2007, Curtis D. Boyd

2007 JSOU and NDIA SO/LIC Division Essays, April 2007

Hunting Leadership Targets in Counterinsurgency and Counterterrorist

Operations, June 2007, Graham H. Turbiville, Jr.

Executive Report, JSOU Second Annual Symposium (30 April–3 May 2007)

A Theory of Special Operations, October 2007, Robert G. Spulak, Jr.

Block by Block: Civic Action in the Battle of Baghdad, November 2007,

Adrian T. Bogart III

Private Security Infrastructure Abroad, November 2007,

Graham H. Turbiville, Jr. 

Intelligence in Denied Areas, December 2007, Russell D. Howard

Is Leaving the Middle East a Viable Option, January 2008,

Thomas H. Henriksen

Retaining a Precarious Value as Special Operations Go Mainstream, 

February 2008, Jessica Glicken Turnley
vii

Contents

Foreword ............................................................................... ix

About the Author ................................................................... xi

Acknowledgements.............................................................. xiii

1. Introduction........................................................................ 1

2. Background ........................................................................ 3

Terrorist States, Organizations, Networks, and Individuals..................... 3

Terrorist Financing................................................................................. 4

Importance of Terrorist Finances............................................................ 6

Economic Strategies and Efforts Against Terrorist Financing.................... 8

Effects of U.S. and International Efforts Against Terrorist Financing....... 10

3. Mechanics of Terrorist Financing....................................... 13

Functional Analysis of Terrorist Financing .............................................13

Sources and Movement of Terrorist Funds ............................................16

4. Organizations with Mandates 

 to Disrupt Terrorist Financing ............................................ 17

United States Organizations.................................................................17

International Organizations..................................................................20

Weaknesses within the U.S. and 

International Organizational Framework...............................................22

5. Legal Considerations......................................................... 23

International Conventions....................................................................23

United Nations Security Resolutions.....................................................24

U.S. Laws and Federal Regulations.......................................................27
viii

6. Recommendations and Desired Effects.............................. 31

Designate an Organization with the Mandate 

and Funding Authority to Direct Actions ..............................................31

Enhanced Multilateral Information and Intelligence Sharing..................33

An Integrated and Collaborative 

Information and Intelligence Sharing Network......................................36

DoD Policy and Way Ahead.................................................................38

7. Conclusion ....................................................................... 45

Endnotes............................................................................... 47

Appendix A. FTO Locations and 

the Original Pan-Islamic Caliphate........................................ 57

Appendix B. Alternative Financing Mechanisms.................... 59

Appendix C. U.S. Organizations and 

Efforts to Disrupt Terrorist Financing...................................... 61

Appendix D. International Organizations 

and Efforts to Disrupt Terrorist Financing ............................... 81

Appendix E. International Resolutions and Conventions........ 93

Appendix F. U.S. Laws, Federal Regulations, Federal Register 

Notices, and Miscellaneous Sources of DoD Authority........ 105

Appendix G. Worldwide Information

and Intelligence Network (WIIN) ........................................ 119

Appendix H. Acronyms and Terms...................................... 125
ix

Foreword

Terrorist financing is a critical issue in the current fight against

transnational terrorist networks or groups. Conceptually, this 

issue is considered one of numerous types of terrorist support activities; however, as the author argues quite persuasively, it

may be the most important of these activities. Major Wesley Anderson 

initially developed the concept for this paper while a student at the 

Army Command and General Staff College and with the School for 

Advanced Military Studies (SAMS) at Fort Leavenworth, Kansas. SAMS 

published an original version of this monograph electronically in April 

2007. Joint Special Operations University (JSOU) asked the author to

adapt his work to JSOU’s monograph requirements for adding to its

series of works on terrorist networks and their support structures. 

Major Anderson provides an excellent overview of terrorist financing and expands upon how it fits into the broader construct of threat

financing. He articulates the significant challenges any government

faces in trying to interrupt the terrorist networks use of the global 

financial system. The sheer immensity of this system provides ample

opportunity for terrorists to operate undetected or unhindered. He 

also highlights that the very international nature of the global economic system presents enormous challenges in trying to coordinate 

amongst the almost 200 sovereign states that comprise the current

world order. 

In addition, each of these nations face an internal challenge 

similar to that facing the U.S.—how do the individual country’s 

internal security, legal, and financial governmental organizations

work together to meet the significant threat that terrorist networks

pose to national sovereignty. In the U.S., we describe this situation 

as the interagency process, but it is a challenge facing any bureaucracy, and all governments are a bureaucracy in some fashion. As 

one reads this monograph, many of Major Anderson’s recommended 

solutions hinge upon the requirement for significant overhaul in the

U.S. national security system and, by implication, systems in many 

of the world’s countries. 

The reader will find the appendices quite informative. Major Anderson compiled an exhaustive survey of terrorist financing mechanisms,

U.S. authorities and legal statutes, and a listing of both U.S. and 
x

international organizations involved in combating terrorist financing. These appendices, combined with his insightful analysis of the 

current antiterrorist financing campaign and potential improvement

areas, provide a superb overview and summary for someone new to 

the fight or an excellent reference tool for those already waging it.

Readers can obtain the author’s original work, released for public use, 

at the Defense Technical Information Center’s Public Scientific and

Technical Information Network (http://stinet.dtic.mil). 

Michael C. McMahon, Lt Col, USAF

Director, JSOU Strategic Studies Department
xi

About the Author

Major Wesley Anderson began his Army service in 1988 as

an enlisted medic in the Army Reserves. In 1993, he was

commissioned as a Distinguished Military Graduate from the 

Creighton University ROTC Program and served as a medical-surgical 

nurse and critical care 

nurse at Fitzsimons Army 

Medical Center, Aurora, 

Colorado and the Institute of Surgical Research, 

Brooke Army Medical 

Center, San Antonio, 

Texas. 

After completing his 

Special Forces training in 

2000, Captain Anderson

was assigned to the 10th

Special Forces Group 

Airborne SFG (A), Fort 

Carson, Colorado. As 

detachment commander for Operational Detachment Alpha 045, he was

tasked to Bosnia as the J3 for the Combined Joint Special Operations 

Task Force for Operation Joint Forge, and he deployed with ODA 045

in conjunction with A Company, 10th SFG (A) to Kosovo for Operation

Joint Endeavor. As commander for Headquarters and Headquarters

Company (HHC), Captain Anderson deployed the company in support 

of Operation Iraqi Freedom (OIF I).

Major Anderson’s following assignment was as a current operations 

officer, Special Operations Division and as a defense planner for the

Bi-National Planning Group, U.S. Northern Command, Peterson AFB, 

Colorado. He is currently assigned to the Surgical Trauma Intensive 

Care Unit, as the head nurse, at Brooke Army Medical Center, San 

Antonio, Texas. 

Major Anderson holds a Bachelors of Science Degree in Nursing 

from Creighton University, an Executive Masters Degree in Business 

Administration from Benedictine College, and a Masters Degree in 

Military Arts and Sciences from the Command and General Staff 

Major Anderson, left, with ODA 045 at Joint 

Combined Exchange Training in Lithuania, 2001. 
xii

College. He is a graduate of the United States Army Medical Basic 

Officer Course, Infantry Officer’s Advanced Course, Special Operations

Qualification Course, Command and General Staff Officer Course,

Advanced Operators Warfighters Course, and the Advanced Military

Studies Program. 
xiii

Acknowledgments 

I would like to thank all the individuals and organizations that 

assisted me in completing this paper. Without everyone’s time 

and energy this monograph would never have been accomplished. 

In addition, I would like to offer my gratitude to Simone Ledeen, 

Christopher Burdick, Lieutenant Colonel Charles Vance (Retired) 

and Dr. James Schneider for going above and beyond with their help, 

insight, and patience with regard to this project. Finally, I would like 

to thank my wife and children for their support and understanding 

during this endeavor. 

De Oppresso Liber

Major Wesley J.L. Anderson, U.S. Army

1

Anderson: Disrupting Threat Finances 

1. Introduction

There are two things a brother must always have for jihad,

himself and money. 

Al Qaeda Operative1

This paper investigates whether or not the disruption of terrorist 

financing as part of an integrated and holistic approach is an

effective way to enhance United States (U.S.) security, disrupt 

terrorist operations, and mitigate terrorist effects on U.S. strategic 

interests. Too often, individuals around the world talk about winning 

the war on terrorism and defeating terrorist organizations, such as Al 

Qaeda; however, as long as there are intolerant and violent humans

on this earth, terrorism will not be defeated. Unfortunately, terrorism, 

prostitution, and drugs are criminal ventures with long histories, and 

they will probably always be present.2

The focus of counterterrorism efforts, therefore, should not be 

on the elusive goal of “defeating terrorism,” but instead should be on 

understanding the underlying grievances, organizational structure, and 

vulnerabilities associated with terrorist organizations and networks.3

Once the U.S. gains these understandings, it should focus on disrupting 

terrorist organizations and making it more dangerous and costly for 

them to conduct their operational, logistical and financial activities.

Since the terror attacks of 11 September 2001, detecting and

preventing terrorist activities have been top priorities for the United 

States Government (USG).4 One of the goals of President George W. 

Bush’s Global War on Terrorism (GWOT) is to deny terrorist groups 

access to the international 

financial system, to impair

their ability to raise funds, 

and to expose, isolate, and 

incapacitate their financial

networks.5 Like most organizations, terrorist groups 

need financing to organize, recruit, train, and equip adherents.6 If 

the U.S. is going to be effective in its fight against terrorist organizations, however, it must expand President Bush’s financial dimension

of the fight beyond the role of trying to deny terrorist access to financing and progress into the realm of using financial information as the

[The U.S.] must expand President Bush’s 

financial dimension of the fight...into 

the realm of using financial information 

as the “string” that leads to all aspects 

of terrorist operations. 
2

JSOU Report 08-3

“string” that leads to all aspects of terrorist operations. By disrupting access to financial resources and, more importantly, following

its trail, the USG—through coordinated intelligence, investigations, 

prosecutions, sanctions, and diplomacy within the Interagency (IA) 

community, private sector, allies, and partner nations—can enhance 

U.S. security, disrupt terrorist operations, and mitigate terrorist effects 

on U.S. strategic interests. 

Although extensive information has been published on the subject of terrorist financing, the author believes that the Department

of Defense (DoD) current contributions to this effort fall short in the 

areas of IA facilitation and integration along with the advancement of 

nonkinetic options outside the realm of classified plans and congressional testimony. The author attributes DoD’s lack of rigor on the 

subject of terrorist financing to four factors:

a.	 The disruption of terrorist financing is seen as a nontraditional

role (nonkinetic option). 

b. No policy statement has been developed. 

c. No way ahead has been developed. 

d.	 The DoD has no defined authorities under U.S. law and regulations with regard to threat financing nor does DoD have an

overarching directive.

Without extensive IA facilitation and integration and advancement of 

all viable options to disrupt terrorist organizations, DoD is not fully 

leveraging its massive capabilities and resources. 

This paper examines the hypothesis that the effects of terrorist 

organizations on U.S. strategic interests can be disrupted and mitigated through:

a. Giving an existing organization the mandate and funding 

authority to coordinate and direct the actions of all USG 

agencies (without stifling their flexibility or resources) against

terrorist organizations. 

b. Enhancing multilateral cooperation and information sharing 

with IA, private sector, allies, and partner nations. 

c. Utilizing commercial off the shelf (COTS) technology to create 

an integrated communication network between the IAs, private 

sector, allies, and partner nations. 

d. Establishing a DoD policy and way ahead. 
3

Anderson: Disrupting Threat Finances 

2. Background

This morning, a major thrust of our war on terrorism began 

with the stroke of a pen. Today, we have launched a strike 

on the financial foundation of the global terror network...

we will direct every resource at our command to win the 

war against terrorists: every means of diplomacy, every tool 

of intelligence, every instrument of law enforcement, every 

financial influence. We will starve the terrorists of funding, 

turn them against each other, rout them out of their safe hiding 

places and bring them to justice.

 President George W. Bush, 24 September 20017

Terrorist States, Organizations, Networks, and Individuals

As used in this monograph, the term terrorist state includes 

the five countries currently designated as State Sponsors of

Terror by the Secretary of State pursuant to three laws, the 

term terrorist organization includes the 42 organizations currently

designated as Foreign Terrorist Organizations (FTOs) by the Secretary of State, and the term terrorist includes the 426 individuals and

organizations designated as Specially Designated Global Terrorists 

(SDGTs).8 In addition, terrorist includes any person or organization 

that intends to carry out or aid, assist, or support an act of domestic 

or foreign terrorism as those terms are defined by Title 18 United

States Code (USC), sections 2331(1) and (5).

The FTOs (shown in Appendix A) confronting the U.S. are nonmonolithic, transnational movements of extremist organizations, networks, 

and individuals—and their state and nonstate supporters.For example, 

Al Qaeda currently functions as the terrorist movement’s vanguard and 

remains, along with its affiliate groups and those inspired by them,

the most dangerous present manifestation of the enemy. What unites 

the Al Qaeda movement is a common vision and set of ideas about the 

nature and destiny of the Islamic world. These terrorists are fueled 

by a radical ideology. They seek to expel Western power and influence

from the Muslim world and establish regimes that rule according to 

a violent and intolerant distortion of the Islamic faith.9
4

JSOU Report 08-3

Terrorist Financing

For the purposes of this monograph, the term terrorist financing is 

defined as any form of financial support of terrorism or financial support of those who encourage, plan, or engage in terrorism. The term 

fund refers to financial holdings, cash accounts, securities, and debt

obligations.10

The sources, movement, and storage of the various alternative 

financing mechanisms used by terrorist organizations (see Appendix B)

to finance their networks are as diverse as the many different cultures

of the world. Some terrorist organizations such as those in Europe, 

East Asia, and Latin America rely on common criminal activities such 

as extortion, kidnapping, narcotics trafficking, counterfeiting, and

fraud to support their operations. Other terrorist organizations, such 

as those in the Middle East, tend to rely on not-for-profit organizations,

donations from individuals and businesses (both witting and unwitting), and funds skimmed from charitable organizations. Still other 

terrorist organizations rely on State Sponsors of Terror, although this 

method of funding appears to be decreasing in recent years.11

Regardless of the method terrorist organizations use to fund their 

operations, two facts should be remembered: 

a. Terrorists, like all criminals, focus on crimes of opportunity 

in vulnerable locations throughout the world.

b. Terrorists will continue to adapt and create new methods of 

financing their organizations in order to avoid detection and

maintain a viable financial infrastructure to facilitate their end

state.12

Efforts to determine the scope of the problem with regard to terrorist financing meet with two primary difficulties:

a. The USG has not determined with any precision how much 

money terrorist organizations such as Al Qaeda raise, or from 

whom, or how they spend their money. 

b. Most of the Al Qaeda and other Islamist terrorist groups funding 

originates and is disbursed outside the U.S. and its jurisdiction.13

Based on the extrapolation of current data available, however, 

terrorist organizations are experiencing minor difficulties in raising

funds for their organizations and operations. For example, the Central 

Intelligence Agency (CIA) estimates that it cost Al Qaeda, which was 
5

Anderson: Disrupting Threat Finances 

the major sponsor of the Taliban in Afghanistan, about $30 million per 

year to sustain its operations before 9/11, an amount raised almost

entirely through donations. In 2001, The U.S. seized $264,935,075

in assets belonging to the Taliban that were under U.S. jurisdiction.14

These numbers show that Al Qaeda had eight years, nine and one 

half months worth of operating expenses under the jurisdiction of one 

country in support of one organization. Although the U.S., its allies, 

and partner nations have made significant strides since 9/11, it is

premature to assume that terrorist organizations are having difficulty

funding their organizations and operations. What is important is that 

the global effort against terrorist financing has made it more expensive

and more difficult to raise and move funds.

Like other criminal 

organizations, terrorist 

organizations such as Al 

Qaeda adapt quickly and

effectively, creating new 

challenges with respect to understanding their financing mechanisms.

However, unlike the pre-9/11 Al Qaeda model of a single organization

raising money that is then funneled through a central source (finance

committee), the U.S. is now contending with an array of loosely affiliated groups, each raising funds on its own initiative.15

Financial facilitators are at the core of terrorist organizations’ 

revenue stream. Although there is little question that the arrests and

deaths of several important facilitators have decreased the funds terrorist organizations have at their disposal, they still have the ability to 

fund their operations. Based on the moderate success against financial

facilitators, terrorist organizations are beginning to rely more on the 

physical movement of money and other informal methods of value 

transfer, which can pose significant challenges for those attempting

to detect and disrupt terrorist financing.16 Because of the complexity 

and variety of ways to collect and move small amounts of money in 

a vast worldwide financial system, gathering intelligence on terrorist organizations financial flows will remain an elusive target for the

foreseeable future.17

Terrorist organizations appear to be migrating toward a) alternative 

financing mechanisms such as cash couriers, alternative remittance

systems, stored value cards, digital currency, and Islamic banking; b)

not-for-profit organizations, including front organizations and charities;

Like other criminal organizations, terrorist 

organizations such as Al Qaeda adapt 

quickly and effectively...
6

JSOU Report 08-3

and c) criminal activity, including trade- and commodities-based 

schemes and benefits fraud.18 It is important to remember, however, 

that although there appears to be a current trend toward certain 

methods of moving funds, terrorists still use other less favorable or 

even unknown methods to support their organizations.19

Importance of Terrorist Finances

Actual terrorist operations require only comparatively modest funding.20

Louise Richardson, Executive Dean of Radcliff Institute of Advanced 

Studies, argues “that terrorist organizations can exist on very little 

funding...because their most important resource is that they have 

an ideology that is able to win them recruits. They have an argument 

that they’re making successfully about depicting us [U.S.] as their 

enemy. And we’re letting them make that argument.” 21

However, international terrorist groups need significant amounts

of money to organize, recruit, train, and equip new adherents and to

otherwise support their infrastructure.22 Terrorist organizations must 

have financing to pay for protection (such as safe havens), to bribe

corrupt public officials, for recruiting, for indoctrination and training,

for general operational expenses and equipment, to provide logistical

support, to communicate, to increase their organizations infrastructure, to support operatives’ families, to provide support to families of 

martyrs, to fund humanitarian efforts, and for various other sundry 

items.23 In short, terrorist organizations require considerable amounts

of funds to be raised, moved, and stored through various means to 

conduct operations. These funds leave identifiable and traceable

footprints in the global financial systems, and these footprints must

be pursued both downstream, to identify future perpetrators and 

facilitators, and upstream, to identify funding sources and disrupt 

supporting entities and individuals.24

The DoD Dictionary of Military and Associated Terms defines a decisive point as “a geographic place, specific key event, critical factor, or

function that, when acted upon, allows commanders to gain a marked 

advantage over an adversary or contribute materially to achieving success.” 25 Based on the fact that terrorist organizations require financing

to operate, finances are a critical factor, and disrupting finances will

contribute to the U.S., its allies, and partner nations’ success in the 

fight against terrorism.
7

Anderson: Disrupting Threat Finances 

After the 9/11 attacks, the U.S. and its allies quickly recognized

the urgent need to detect, dismantle, and deter terrorist financing

networks around the world.26 The 9/11 attacks could never have

been executed without the logistical assistance of a sophisticated and 

well-entrenched support network. The 9/11 Commission Report demonstrates that the 19 hijackers were funded and facilitated by dozens

of individuals, cells, front organizations, and affiliates that provided

essential logistical support. Long-term logistical planning also went 

into the earlier bombings of the United States Ship (USS) Cole and the 

embassies in East Africa. Accordingly, an individual, group, or state 

that provides funds, travel documents, training, or other support for 

terrorist activity is no less important to a terrorist network than the 

operative who executes the attack. A key lesson learned from 9/11 is

that counterterrorism efforts must target financial and logistical cells

with the same vigor as operational cells.27

The DoD Dictionary of Military and Associated Terms defines a node

as “an element of a system that represents a person, place, or physical thing.” 28 A close examination of terrorist networks reveals there 

are key nodes in their organizations that have become the preferred 

conduits used by terrorists to fund and facilitate attacks.29 If, therefore, the world is serious about disrupting the terrorists’ operating 

environment, countries need to look at key nodes in the network, such 

as financing, which terrorist’s organizations use to raise, launder, and

transfer funds.30 

One of the advantages of 

focusing on financial nodes

is that many of them are not 

peculiar to one terrorist group. 

For example, the International 

Islamic Relief Organization (IIRO) finances the activities of a diverse

cross section of international terrorist groups. From 1986 to 1994,

Osama bin Laden’s brother-in-law, Muhammad Jamal Khalifa (killed 

in 2007), headed the IIRO’s Philippines office, through which he channeled funds to Al Qaeda affiliates, including Abu Sayyaf and the Moro

Islamic Liberation Front (MILF). In 1999, an IIRO employee in Canada

was linked to the Egyptian Islamic Jihad. More recently, official Palestinian documents seized by Israeli forces in April 2002 established

that the IIRO donated at least $280,000 to Palestinian charities and

organizations that U.S. authorities have linked to Hamas.31

One of the advantages of focusing on 

financial nodes is that many of them 

are not peculiar to one terrorist group. 
8

JSOU Report 08-3

By redirecting additional assets toward financial intelligence to

enhance the monitoring of funds through the financial nodes of various

terrorist networks, the U.S., its allies, and partner nations can increase 

the amount of actionable intelligence for the consumer—which will 

further assist in the disruption of terrorist operatives, sympathizers, 

financiers, and future actions.32 However, attempting to understand 

and monitor terrorist financial nodes to garner actionable intelligence

is hindered by several ongoing challenges, such as: 

a. Speed, diversity, and complexity of the means and methods 

terrorists use for raising and moving funds

b. Commingling of terrorist money with legitimate funds

c. Many layers and transfers between donors and the ultimate 

recipients of the funds

d. Existence of unwitting participants

e.	 Lack of a clearly defined and integrated chain of authority and

oversight within the U.S.

f. Lack of a common communications architecture, familiarity with the information, and process for sharing within and 

between the U.S., its allies, and partner nations.33

Although financial information can create actionable intelligence

by establishing a solid and reliable link between individuals, networks, 

and organizations, taking disruptive action is not always the most 

desirable course of action.34 Rather than starve terrorists of funding, 

as was the approach early in the fight against terrorists, the current

intelligence community approach appropriately focuses on using 

financial transactions, in close coordination with other types of intelligence, to identify and track terrorist groups.35 By using these passive and synergistic intelligence techniques, countries improve their

analyses of how terrorist organizations raise, move, and utilize their 

financial assets and develop a better understanding of their overall

organizational structure, in addition to their interrelationship with 

other organizations and networks. 

Economic Strategies and Efforts Against Terrorist Financing

Since 1995, the USG has used economic sanctions as a tool against

international terrorist organizations, which was a significant departure

from the traditional use of sanctions against countries or regimes. The 
9

Anderson: Disrupting Threat Finances 

scope of U.S. sanctions against terrorist organizations significantly

expanded immediately following the events of 9/11 when President

Bush issued Executive Order (EO) 13224.36 President Bush’s combination of EO 13224 and other programs targeting terrorist organizations

and governments that support terrorists constituted a wide ranging 

assault on international terrorism, its supporters, and financiers.37

The U.S. strategy against terrorist financing has evolved considerably since the early days of EO 13224. While diminishing terrorist funds remains the most visible aspect of the U.S. approach, it is 

no longer the only, or even most important, aspect.38 USG efforts to 

combat terrorist financing both at home and abroad include a number

of interdependent activities: 

 a. Terrorist designation. First, the USG designates terrorists and 

then blocks or passively monitors their assets and financial

transactions, and supports the similar efforts of other countries 

in this regard. In addition, the United Nations generally designates those same terrorist organizations internationally under 

such United Nations Security Council Resolutions (UNSCRs) 

as 1267, 1373, and 1617 in an attempt to isolate them from

the global financial network.

b. Intelligence and law enforcement. Second, U.S. intelligence and 

law enforcement personnel conduct operations and investigations, and exchange information and evidence with each other 

and their respective counterparts abroad. 

c. Setting international standards. Third, U.S. agencies work through 

international entities, such as the United Nations and the 

intergovernmental Financial Action Task Force (FATF), to help 

facilitate international standards which assist in disrupting 

terrorist financial nodes (see Appendix E).

d. International training and technical assistance programs. Finally, 

the USG provides training and technical assistance directly 

to vulnerable countries and works with its allies and partner 

nations to leverage resources to facilitate these efforts.39

Since terrorist organizations often operate internationally, a key 

component of the fight against terrorists is to build effective and

integrated international cooperation. Diplomacy is one of the critical 

aspects for winning the political commitment from which cooperation in 

other areas originates, and the U.S. State Department (DoS), through 
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JSOU Report 08-3

its embassy teams, plays a vital role in that effort (see Appendix D).

Through enhanced cooperation and complete integration with intelligence activities, law enforcement officials will develop a better understanding of the situation and ultimately enhance the U.S. disruption 

of terrorist organizations.40 Through active integration and cooperation that entails a clearly defined chain of authority and oversight,

a shared communications architecture, and enhanced utilization of 

resources, the U.S., its allies, and partner nations will be successful 

in detecting, disrupting, and dismantling terrorist financial networks

throughout the world.

Effects of U.S. and International 

Efforts Against Terrorist Financing 

The U.S. and the international community have achieved successes in 

disrupting the financial underpinnings of terrorist networks. Raising

and moving funds are now harder, costlier, and riskier for terrorist 

organizations. The U.S., its allies, and partner nations have frozen and 

seized terrorist assets; exposed, monitored, and dismantled known

channels of funding when warranted; deterred donors; arrested key

facilitators; and built higher hurdles in the international financial

system to prevent abuse by terrorists’ organizations.41

As of 31 December 2005, according to the U.S. Treasury Department Terrorist Asset Report, the total value of blocked assets totaled 

$13,793,102.42 In addition, more than $471 million in assets relating

to five designated State Sponsors of Terrorism is located within U.S.

jurisdiction. Of that amount, $368 million was blocked pursuant to

economic sanctions imposed by the U.S. and administered by the 

Office of Foreign Assets Control (OFAC). The remaining balance of 

$102,600,000 in assets represents nonblocked funds of individuals

and entities from Iran and Syria.43

The amount of assets blocked under the public designation process 

is not, however, a primary measure of effectiveness of antiterrorism 

programs. Countries that have been declared as supporters of terrorist activities whose assets are not currently blocked by a sanctions 

program are extremely reluctant to hold assets in the U.S.44 In addition, the blocking of terrorist organizations’ assets, with the notable 

exception of the Taliban, tends to be a small amount of funds. 
11

Anderson: Disrupting Threat Finances 

The usefulness of public designation process lies in four results 

that are less direct than the amount of assets blocked in the U.S. 

Public designation: 

a. Encourages other countries to take their own actions against 

suspected terrorist financing networks.

b. Discourages less ardent supporters from wittingly funding 

terrorist organizations for fear of being designated a terrorist 

and having their bank accounts frozen. 

c.	 Facilitates the dismantling of entire terrorist financial networks, making it more difficult for terrorist organizations to

raise funds and finance terrorist operations

d. Causes terrorists to resort to other nontraditional, more costly 

and uncertain, but still serviceable mechanisms for moving 

assets globally.45

While freezing the funds of terrorists can be used as a tool against 

terrorist organizations, it is by no means the only or most effective 

means to disrupt these organizations. 

13

Anderson: Disrupting Threat Finances 

3. Mechanics of Terrorist Financing

For more than 2,000 years, military strategists have recognized 

the truism that armed conflict cannot be waged until it has 

been financed. 

Todd M. Hinnen, director for Combating

Terrorism, National Security Council46

Functional Analysis of Terrorist Financing

Terrorist organizations use a variety of alternative financing

mechanisms to raise, move, and store their funds based on 

factors that are similar to other criminal organizations.47

Terrorist organizations’ goals are to operate in relative obscurity, use 

mechanisms involving close knit networks, and move their funds 

through industries and mechanisms that lack transparency and are 

poorly regulated.48

Due to the criminal nature of terrorist organizations and the lack 

of systematic data collection, analysis, and sharing of intelligence 

within the USG, the actual extent of alternative financing mechanisms

by terrorist organizations is not known. In the past, U.S. law enforcement agencies, in particular the Federal Bureau of Investigation (FBI) 

which leads terrorist financing investigations, did not systematically

collect and analyze data on alternative financing mechanisms.49 This 

lack of data collection hindered the FBI and other IA from conducting 

systematic analysis of trends and patterns focused on terrorist financing. Without rigorous data collection, the FBI and, more importantly, 

the USG lacked the capability to conduct analyses that would have 

helped assess risk and prioritize U.S. efforts and limited resources. 

Moreover, despite an acknowledged need by most government agencies 

for further data collection, analysis, and the sharing of financial intelligence, few rigorous studies have been conducted in this area.50

Terrorist Organizational Structure. The U.S. can no longer afford to 

assume terrorist organizations use simple chain or line network structures (see Figure 1), with perfect circles that do not bleed or cross

over into one another.51

The principal international terrorist organization today is best described 

as a full-matrix network (see Figure 2)—the most highly developed network
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JSOU Report 08-3

structure—in which all of its members are connected to, and can 

communicate with, all other members.52 This full-matrix relationship 

between terrorists who belong to one or another group is what makes 

the threat of international terrorism so dangerous today. For example, 

while there are no known headquarters-to-headquarters links between

Al Qaeda and Hezbollah, the two groups are known to have held seniorlevel meetings over the past decade and to maintain ad hoc, personto-person ties in the areas of training and logistical support.53

Too often, the USG pigeonholes terrorists as members of one group 

or another, as if operatives carry membership cards around in their 

wallets. Today’s terrorists are better defined as belonging to a network 

of networks, which is both informal and unstructured.54 For instance, 

not every Al Qaeda operative has pledged an oath of allegiance (bayat) 

to Osama bin Laden, and many terrorists maintain affiliations with

members of other terrorist groups and facilitate one another’s activities.55 Even though terrorist organizations tend to maintain the cellular structure at the tactical level for security purposes, one of their 

critical vulnerabilities at the operational and strategic level lies in the 

area of terrorist financing and logistical support due to the overlap

and cooperation between terrorist groups and facilitators within their 

network of networks. 

The DoD Dictionary of Military and Associated Terms defines command and control as “the exercise of authority and direction by a 

properly designated commander over assigned and attached forces in 

the accomplishment of the mission. Command and control functions 

are performed through an arrangement of personnel, equipment, communications, facilities, and procedures employed by a commander in 

planning, directing, coordinating, and controlling forces and operations

Figure 1. Example terrorist organization hierarchal structure. Adapted from the 

unpublished work of Major Grant Morris and the School of Advanced Military 

Studies Program Special Operations Elective. 

L

L L

P I O S $ V

L

S

O

$

P

I

V

Command & Control

Operations

Support

Finance

Personnel

Intelligence

Virtual
15

Anderson: Disrupting Threat Finances 

in the accomplishment of the mission.” 56 Unfortunately, terrorist 

networks do not use the same definition for command and control

as the U.S. and many of its allies and partner nations. The implication of this fact is the increased need for the U.S. and its partners to 

maintain flexibility and perhaps even adapt their own command and

control architecture to better enhance their disruption efforts.

Full matrix, high tech. The full-matrix network represents the greatest 

potential threat to traditional hierarchical organizations and established 

governments like the U.S., especially as information technologies such 

as the Internet enhance communication among network members.57

The full-matrix network’s flat organizational architecture means

that there may be no single leader. This is the case with Al Qaeda, 

contrary to popular belief, and it is why the organization is capable of 

conducting operations with or without the leadership of Osama bin 

Laden. Decision making and tactical operations are instead distributed 

among autonomous terrorist networks that share overarching principles, beliefs, and end states, such as the return of the caliphate.58

Figure 2. Example evolution to a full-matrix network. Adapted by the author 

from the unpublished work of Major Grant Morris and the School of Advanced 

Military Studies Program Special Operations Elective.

L

L L

P I O S $ V

L Command & Control

O Operations

S Support

$ Finance

P Personnel

I Intelligence

V Virtual

O O

S S S

I

P

$

S

V

O

O

S

I

I

I

I

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P $

$

$

$ $ $

V

V

V

V

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S

P I

S

O V $ L

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L

L L

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S

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$

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2-D, Current Model

3-D, Nodal-Based Model

System of Systems Analysis 

(SoSA)

Understanding Global Links

•	Failed &

Failing States

•	Ungoverned

Space

• Convergence

	 of Convenience

•	Temporary

Relationships

•	Opportunists
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JSOU Report 08-3

Maintenance of such shared principles, beliefs, and end states does, 

however, require the means for mutual consultation and consensus

building among network nodes. Information technologies play a vital 

role in providing this means of information sharing among terrorist 

networks, but personal contact among node members is still necessary at times.59

Although information can be shared in many different ways and 

forms, one of the most common, safest, and effective means between 

terrorist networks is the Internet.60 Terrorists use the Internet to 

develop and disseminate propaganda, recruit new members, raise 

and transfer funds, train members on weapons use and tactics, plan 

operations, and share documents and stored information with other 

terrorists throughout the world.61 Terrorists can also access the vast 

wealth of information available on the Internet to facilitate operations, 

logistics, and financial support.

Sources and Movement of Terrorist Funds

Terrorist organizations raise funds through a variety of sources, 

including not-for-profit organizations, witting and unwitting; individual

contributors, witting and unwitting; criminal activity; corporate contributors, witting and unwitting; operating businesses; state sponsors;

and legal employment.62 These funds provide the interchangeable, easily 

transportable means to secure all other forms of material support.

Once the funds are raised, terrorist organizations move the funds 

through several mechanisms, including cash couriers; alternative

remittance systems “informal value transfer,” such as hawalas and 

hundis; stored value cards; digital currency; Islamic banking systems;

financial facilitators; trade- and commodities-based methods; the

Internet, through casinos and auctions; wire transfers; and formal

international banking systems.63 If the U.S. and its partners are going 

to succeed in the fight against terrorists, they must deprive terrorists

of the material support they require by disrupting and monitoring the

various funding sources and by interdicting the different movement 

mechanisms currently available. However, disrupting and monitoring 

terrorist funds without stifling the legal movement of funds remains

a major challenge. 
17

Anderson: Disrupting Threat Finances 

4. Organizations with Mandates to 

 Disrupt Terrorist Financing

United States Organizations

The National Security Strategy of the United States of America, 

2002 calls upon several different departments and agencies

within the USG to disrupt terrorist financing by identifying

and blocking the sources of their funding and denying them access 

to the international financial system.64 To that end numerous organizations within the USG have lead, coordinating, or supporting roles 

in the effort to disrupt terrorist financing and are interconnected by

a complex web of formal and informal relationships (see Appendix C 

for a more comprehensive listing).65 This section focuses only on the 

major councils, departments, and agencies within the USG.66

National Security Council (NSC). The NSC is responsible for the overall 

coordination of the IA framework for combating terrorism, to include 

disrupting terrorist financing.67 Under the NSC, a series of committees 

and working groups develop policy, share information and coordinate 

the response to terrorist threats against U.S. interests.68 The NSC’s 

Sub-Counterterrorism Security Group (CSG) on Terrorist Finance has 

the primary responsibility to ensure proper coordination of counterterrorism financing activities and information sharing among the IA,

intelligence organizations, and law enforcement communities.69 The 

NSC has several other Sub-Groups and offices that manage various

programs and activities to combat terrorist financing abroad.70

The Treasury Department. Since June 1995, the Secretary of the Treasury has been responsible for identifying and blocking terrorist funds 

within the U.S. and its jurisdiction.71 In addition, a number of Treasury 

Department offices work with other federal agencies to implement key

statutory provisions of the Currency and Foreign Transactions Reporting Act (commonly referred to as the Bank Secrecy Act—BSA of 1970)

and the Uniting and Strengthening America by Providing Appropriate 

Tools Required to Intercept and Obstruct Terrorism Act of 2001 (better

known as the USA Patriot Act), and to enhance information sharing 

among intelligence, law enforcement, and financial institutions.72
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JSOU Report 08-3

The primary office within the Treasury Department that is involved

in the effort to disrupt terrorist financing is the Office of Terrorism

and Financial Intelligence (TFI). The TFI is comprised of a) the Office

of Terrorist Financing, b) the Office of Intelligence and Analysis, c) the

Office of Foreign Asset Control, d) the Financial Crimes Enforcement

Network, and e) the Treasury Executive Office for Asset Forfeiture and

Treasury Forfeiture Fund.73 In addition, the Treasury Department has 

several other offices that manage various programs and activities to

combat terrorist financing abroad.74

The Department of State (DoS). The DoS serves as the USG’s lead 

agency in its efforts to combat terrorism overseas. To safeguard the 

international financial system against terrorist financing and money

laundering, the DoS focuses on three areas: 

a. Designation, by blocking assets and cutting off worldwide 

channels of terrorist financing

b. Standard setting, by establishing internationally accepted 

standards

c. Capacity and coalition building, by building the technical 

capacity and political will to ensure global compliance with 

international standards.75

Within the DoS, the Office of the Coordinator for Counterterrorism

(S/CT) and the Bureau of International Narcotics and Law Enforcement Affairs (INL) have the primary responsibility for coordinating 

capacity building abroad to disrupt terrorist financing, while the

Bureau of Economic, Energy, and Business Affairs (EEB) has primary 

responsibility for international coalition building.76 In addition, DoS 

has several other bureaus and offices that manage various programs

and activities that help combat terrorist financing.77

The Department of Justice (DoJ). The DoJ has the lead responsibility 

for investigating and prosecuting terrorist acts, including all forms of 

material support to terrorist organizations.78 Within the DoJ, the FBI 

has the lead role for law enforcement and criminal matters related 

to terrorism.

79 The two major organizations within the DoJ that are 

involved in disrupting terrorist financing are the Terrorist Financing

Unit (TFU) and the Terrorist Financing Operations Section (TFOS), 

which falls under the FBI.80

Department of Homeland Security (DHS). DHS has a supporting role 

in tracking terrorist financing and conducting related investigations
19

Anderson: Disrupting Threat Finances 

within the U.S. and select overseas activities.81 The major organization 

within the DHS that is involved in disrupting terrorist financing is the

Bureau of Immigration and Customs Enforcement (ICE).82

The Department of Defense. The DoD has a supporting role within the 

USG in the fight against terrorist financing. Accordingly, the DoD has

broadened its nonkinetic efforts to include the disruption of threat 

financing. While terrorist financing concentrates on organizations,

networks, cells, and individuals directly linked to terrorism, and is 

the primary focus of this paper, it is only one of the five areas within

threat financing. Threat financing is a broader-based concept that

includes Weapons of Mass Destruction/Effects (WMD/E) funding, 

terrorist financing, narcotics trafficking, organized crime, and human

trafficking.83

Within the DoD, the United States Special Operations Command 

(USSOCOM) has been designated the executive agent for synchronizing 

the GWOT, which includes disrupting and defeating threat finances.84

The other two major organizations within the DoD that facilitate the 

disruption of terrorist finances are the geographic combatant commands (GCCs), through Threat Finance Exploitation Units (TFEUs), 

and various Combat Support Agencies, such as the Defense Intelligence 

Agency (DIA), through the Joint Intelligence Task Force-Combating 

Terrorism (JITF-CT). 

a. USSOCOM. As the supported combatant command for the 

GWOT, USSOCOM synchronizes the counterterrorism plans 

of the five GCCs.85 USSOCOM also plans and executes combat 

missions against terrorist organizations as the supported Command, while maintaining the role of force provider to the other 

GCCs.86 With regard to terrorist financing, USSOCOM’s Threat

Finance Exploitation Branch has the lead for synchronizing 

efforts against threat finances.

b. Geographic Combatant Commands. The GCCs are currently 

assessing the ability of terrorists and insurgents to finance

operations and the effectiveness of the U.S. military efforts 

to deny resources to terrorist organizations. Initial data from 

these assessments indicate that the DoD, while enjoying some 

successes in analyzing and disrupting the funds of terrorists 

and insurgents, is progressing slowly in combating terrorist 

financing on a global scale.87 Currently, U.S. Central Command 
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JSOU Report 08-3

(USCENTCOM), U.S. European Command (USEUCOM), U.S. 

Northern Command (USNORTHCOM), U.S. Pacific Command

(USPACOM), and U.S. Southern Command (USSOUTHCOM) are 

operating TFEUs that work with DoD and non-DoD intelligence, 

law enforcement, and regulatory agencies to detect financial

support networks; collect, process and analyze information;

and target, disrupt, or destroy financial systems and networks,

which support activities that threaten U.S. interests.88

Not all GCCs call their TF Exploitation entity a TFEU. For 

instance USSOCOM calls its entity a TF Exploitation Branch, 

but each GCC has an entity that analyzes and exploits financial

intelligence. Each of the TF Exploitation entities has a somewhat different focus that is based on their region. For example, 

USSOUTHCOM is more focused on the narcotics trafficking

portion of TF, whereas USCENTCOM is focused more on the 

terrorists and insurgents. Each of the TF Exploitation entities 

are resourced, manned, and utilized to varying degrees based 

on the emphasis that is placed on their importance by the 

GCC, and not all TF Exploitation entities operate at the same 

level of proficiency.

International Organizations

Terrorist financing networks are global, so efforts to identify and

disrupt terrorist access to funds must also be global.89 Moreover, 

because the overwhelming majority of terrorist funds are outside U.S. 

jurisdiction, the U.S. has entered into several agreements to improve 

and facilitate international organizations’ counterterrorism efforts.90

International organizations can be grouped into four main categories: 

international standard setters, international capacity builders, regional 

entities, and industry-sector standard setters (see Appendix D for a 

more comprehensive listing).91

International Standard Setters

United Nations. The United Nations is one of the key international 

entities in the fight against terrorist organizations and networks.

The single biggest role conducted by the United Nations with regard 

to terrorist financing is the imposition and enforcement of international financial sanctions through the designation lists maintained

under UNSCR 1267 and 1617.92 In addition, the United Nations 
21

Anderson: Disrupting Threat Finances 

provides member states with numerous forms of assistance for 

their counterterrorism efforts through the contributions of various 

departments, programs, and specialized agencies.93 On 8 September, 

2006, the United Nations began a new phase in its counterterrorism

efforts by adopting the Global Counterterrorism Strategy, which serves 

as a common platform to bring together the counterterrorism efforts 

of the various United Nations departments, programs, and specialized 

agencies into a common, coherent, and more focused framework.94

Although the United Nations consists of numerous departments and 

specialized agencies, the Counterterrorism Implementation Task Force 

(CTITF) and the Counterterrorism Committee (CTC) have the largest 

roles in disrupting terrorist finances.95

Financial Action Task Force. The FATF consists of 33 member countries 

and 2 regional organizations. It is one of the preeminent international

bodies dedicated to developing, promoting, and assessing legal and 

regulatory standards and policies to combat money laundering and 

terrorist financing.96 FATF’s most notable contributions against terrorism include two fundamental documents: 

a. The FATF Forty Recommendations on Money Laundering, a set 

of international standards for countries to establish an effective anti-money-laundering regime

b. Nine Special Recommendations on Terrorist Financing, which 

has become the international standard for evaluating a state’s 

antiterrorist financing laws.97

In addition, FATF established a Non-Cooperative Countries and 

Territories (NCCT) list of those countries that fail to meet internationally recognized standards and serve as terrorist money laundering 

havens, monitors member progress in implementing anti-moneylaundering measures, conducts mutual evaluations of its member 

countries and jurisdictions, and reports on money laundering trends 

and techniques.98

International Capacity Builders

Egmont Group. The Egmont Group is an international body, comprised 

of 101 financial intelligence units (FIUs), that fosters improved communications, information sharing, and training coordination worldwide in the fight against money laundering and terrorist financing.99

The FIUs work collectively to eliminate impediments to information 

sharing, promote the reporting of terrorist financing as a suspicious
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JSOU Report 08-3

activity to FIUs, and undertake joint studies on money laundering 

and terrorist financing vulnerabilities. They also improve expertise

and capabilities of law enforcement personnel and agencies, and they 

expand and create a systematic exchange of financial intelligence

information.

100

The International Criminal Police Organization (INTERPOL). INTERPOL is 

the world’s largest international police organization, with 186 member

countries that facilitate cross border police cooperation. INTERPOL 

also supports and assists all organizations, authorities, and services 

whose mission is to prevent or combat international crime.101 With 

regard to combating financial crimes, INTERPOL’s primary focus is

on payment cards, money laundering, intellectual property crime, 

currency counterfeiting, and new technologies, all of which can be 

used by terrorist organizations to fund their operations.102 Within 

INTERPOL, the Fusion Task Force (FTF) has the lead for conducting 

antiterrorism efforts. The FTF’s primary objectives include identifying 

active terrorist groups and their members; soliciting, collecting, and

sharing information and intelligence; providing analytical support; and

enhancing the capacity of member countries to address the threats 

of terrorism and organized crime.103

Weaknesses within the U.S. and 

International Organizational Framework

There are four major weaknesses within the U.S. and international 

organizational framework: 

a. No organization has both the mandate and funding authority 

to coordinate and direct the actions of all USG agencies against 

terrorist organizations. 

b. Information sharing is predicated on a need to know versus 

a need to share basis within the U.S. and international community.

c. No integrated and collaborative communications network exists 

within the U.S. or between its allies and partner nations.

d.	 An insufficient effort made to maximize information between

the collector, analyst, and end user and the inability to utilize 

a commonly understood language. 
23

Anderson: Disrupting Threat Finances 

5. Legal Considerations

I

n the fight against terrorist financing, it is critical to address

the authority of international organizations for several reasons. 

First, most of the funds supporting terrorist organizations are 

not under the control or jurisdiction of the U.S. Therefore, the U.S. 

must internationalize its initiatives.104 Second, international organizations have a tremendous sphere of influence, so by influencing

and supporting various international conventions and resolutions 

the U.S. can protect its own interests through the efforts of various 

other countries around the world.105 Finally, the U.S. has ratified all

thirteen international conventions relating to terrorism, which means 

U.S. domestic laws must be in compliance with and support these 

international conventions.106

International conventions and resolutions designed to disrupt the 

flow of terrorist financing are discussed below in two parts: international conventions and United Nations Security Council Resolutions 

(see Appendix E for a more comprehensive listing). Following the 

international conventions and resolutions, U.S. laws and federal 

regulations are discussed. 

International Conventions 

International conventions serve an important role in coordinating the 

counterterrorism efforts and establishing legal norms within the various ratifying states around the world. Two international conventions 

that are important in facilitating the disruption of terrorist financing

are the International Convention for the Suppression of the Financing 

of Terrorism and the International Convention against Transnational 

Organized Crime. 

International Convention for the Suppression of the Financing of Terrorism, 1999. This convention established terrorist financing as a distinct

offense, which is constituted by directly or indirectly, unlawfully and 

willfully, providing or collecting funds with the intent that they should 

be used or in the knowledge that they are to be used, in full or in part, 

to carry out an offense described in any one of the other twelve United 

Nations counterterrorist treaties, or to commit any other violent act 

with the intent of intimidating a population or compelling a government to act in a certain manner. The convention contains four primary 
24

JSOU Report 08-3

obligations that a) criminalize the provision or collection of funds for 

terrorists; b) prohibit the provision of funds, assets or financial services

to terrorists; c) freeze without delay terrorist funds or other assets;

and d) establish adequate identification and reporting procedures for

financial institutions. In addition, the convention requires ratifying

countries to criminalize terrorism, terrorist organizations, and terrorist acts and encourages member states to implement measures that 

are consistent with FATF recommendations.107

International Convention Against Transnational Organized Crime, 2000.

Although not one of the thirteen United Nations conventions that specifically address terrorism, this convention can be used as an effective

tool to disrupt terrorist financing. Member states that have ratified the

convention are required to establish within their domestic laws four

criminal offenses: participation in an organized criminal group, money 

laundering, corruption, and obstruction of justice.108 The convention 

also obligates ratifying countries to: 

a. Criminalize all serious crimes as predicate offenses of money 

laundering, whether committed within or outside of the country, and permits the required criminal knowledge or intent to

be inferred from objective facts.

b. Establish regulatory regimes to deter and detect all forms of 

money laundering, including customer identification, record

keeping, and reporting of suspicious transactions. 

c. Authorize the cooperation and exchange of information among 

administrative, regulatory, law enforcement, and other authorities, both domestically and internationally. 

d. 	 Establish a financial intelligence unit to collect, analyze, and

disseminate information. 

e. Promote international cooperation.109

United Nations Security Resolutions

The USG, with the DoS in the lead, maintains a working relationship 

with the United Nations to develop and support numerous UNSCRs 

(United Nations Security Council Resolutions) such as 1267, 1269,

1373, 1617, 1730, and 1735, that have helped give international

momentum and legitimacy to the global effort against terrorist financing.110 This is extremely important because most of the assets making 

their way to terrorist organizations are not under U.S. control or juris-
25

Anderson: Disrupting Threat Finances 

diction, and when an individual or organization, such as Al Qaeda, is 

included on the United Nations sanctions list, all 191 United Nations

member states are obligated to implement the sanctions, such as 

freezing the assets.111

UNSCR 1267, 1999. UNSCR 1267 obligates member states to freeze

assets of individuals and organizations associated with Osama bin 

Laden, members of Al Qaeda or the Taliban that are included on the 

consolidated list maintained and regularly updated by the United 

Nations 1267 Sanctions Committee.112 UNSCR 1267 is also one of the

implementing authorities for EO 13224.113

UNSCR 1269, 1999. UNSCR 1269 calls on member states to implement the international antiterrorist conventions to which they are a 

party. Although the Security Council specifically referred to terrorist

financing” for the first time in UNSCR 1269, it was not in the context

of state-sponsored terrorism. However, General Assembly Resolution 

49/60 clearly implicated state entities directly in such financing by

acts and omissions such as sheltering, facilitating, funding, and failing to adopt suppressive measures.114

UNSCR 1373, 2001. UNSCR 1373 is the broadest of the UNSCRs and 

obligates member states to:

a.	 Criminalize actions that finance terrorism.

b.	 Prevent and suppress terrorist financing, and freeze funds and

other financial assets or economic resources of persons who

commit or attempt to commit terrorist acts.

c. Prohibit active or passive assistance to terrorists.

d. Cooperate with other countries in criminal investigations and 

share information with regard to planned terrorist acts.115

UNSCR 1617, 2005. UNSCR 1617 extended sanctions against Al Qaeda,

Osama bin Laden, and the Taliban, and it strengthened previous 

related resolutions. This resolution:

a.	 Extended the mandate of the 1267 Sanctions Committee’s

Monitoring Team.

b.	 Clarified what constitutes association with Al Qaeda.

c. Strongly urged all member states to implement the comprehensive international standards embodied in the FATF Forty 

Recommendations on Money Laundering and Nine Special 

Recommendations on Terrorist Financing. 
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d.	 Requested the Secretary General increase cooperation between

the United Nations and INTERPOL in order to provide the 

United Nations 1267 Committee with better tools to fulfill its

mandate. 

e. Urged member states to ensure that stolen and lost passports 

and other travel documents were invalidated as soon as possible, as well as to share information on those documents with 

other member states through the INTERPOL database.

116

UNSCR 1730 (2006). UNSCR 1730 expanded on UNSCR 1617 and

added an element of due process to designation mechanism. UNSCR 

1730:

a. Emphasizes that sanctions are an important tool in the maintenance and restoration of international peace and security.

b.	 Adopts delisting procedures and requests the Secretary-General

establish, within the Secretariat (Security Council Subsidiary 

Organs Branch), a focal point to receive delisting requests

and to perform the tasks described in the annex to UNSCR 

1730.

c. Directs the sanctions committees established by the Security 

Council, including those established pursuant to resolution 

1718 (2006), 1636 (2005), 1591 (2005), 1572 (2004), 1533

(2004), 1521 (2005), 1518 (2003), 1267 (1999), 1132 (1997),

918 (1994), and 751 (1992) to revise their guidelines accordingly.117

UNSCR 1735 (2006). UNSCR 1735 is a rollover of UNSCR 1617, reaffirming 1267, 1373, 1617, standardizing listing procedures through

the use of cover sheet and statement of case. UNSCR 1735 expresses

deep concern about the criminal misuse of the Internet and the nature 

of the threat, particularly the ways in which terrorist ideologies are 

promoted by Al Qaeda, Osama bin Laden, and the Taliban, and other 

individuals, groups, undertakings, and entities associated with them, 

in furtherance of terrorist acts. In addition, UNSCR 1735 freezes the

funds and other financial assets or economic resources of these individuals, groups, undertakings and entities, including funds derived 

from property owned or controlled, directly or indirectly, by them or 

by persons acting on their behalf or at their direction, and ensures 

that neither these nor any other funds, financial assets or economic
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Anderson: Disrupting Threat Finances 

resources are made available, directly or indirectly, for such persons’ 

benefit, or by their nationals or by persons within their territory.118

U.S. Laws and Federal Regulations

U.S. laws, federal regulations and policies designed to disrupt the flow

of terrorist financing and are discussed in three parts: sanction-focused

laws, banking-focused laws, and federal regulations (see Appendix F 

for a more comprehensive listing).119

U.S. Sanction-Focused Laws 

Two important sanction-focused laws facilitate the disruption of terrorist financing: the International Emergency Economic Powers Act

and the Antiterrorism and Effective Death Penalty Act. 

International Emergency Economic Powers Act (IEEPA), 1977. The 

IEEPA falls under the provisions of the National Emergencies Act 

and authorizes the President of the United States (POTUS) to deal 

with any unusual and extraordinary threat to the national security, 

foreign policy, or economy of the U.S., which has its source in whole 

or substantial part outside the U.S., if the POTUS declares a national 

emergency with respect to such a threat.120 It further authorizes the 

POTUS, after such a declaration, to block transactions and freeze 

assets to deal with the stated threat. In the event of an actual attack 

on the U.S., the POTUS can also confiscate property connected with

a country, group, or person that aided in the attack.121

Antiterrorism and Effective Death Penalty Act (AEDPA), 1996. The

AEDPA was the product of legislative efforts stretching back well over 

a decade. It was energized in part by the tragedies in Oklahoma City 

and at the World Trade Center and serves as the empowering statute 

for FTO designation.122 The AEDPA has several important antiterrorist measures:

a. Makes membership in a designated terrorist organization a 

basis for the denial of a visa to enter the U.S.

b. Makes illegal-alien terrorists excludable rather than deportable, wherever and whenever they are apprehended.

c. Establishes special deportation procedures for aliens believed 

to be engaged in terrorist activities when there is evidence of 

a classified nature to support the allegation.
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JSOU Report 08-3

d.	 Allows the Attorney General to request assistance from the

DoD in cases involving WMD.

e. Authorizes funds to establish a counterterrorism center, which 

eventually became the National Counterterrorism Center 

(NCTC).123

The AEDPA contains two specific provisions that address terrorist financing:

a. Bans material support (excluding medical and religious materials) that is knowingly given to foreign organizations designated 

as terrorist by the Secretary of State. 

b. Closes a loophole in the judicial system that permitted groups 

to raise money for terrorist organizations.124

U.S. Banking-Focused Laws

Two banking-focused laws that are important in facilitating the disruption of terrorist financing are the Currency and Foreign Transactions

Reporting Act and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism

Act (USA Patriot Act).

Currency and Foreign Transactions Reporting Act, 1970. The Currency 

and Foreign Transactions Reporting Act, otherwise known as the Bank 

Secrecy Act (BSA), was designed to help identify the source, volume, 

and movement of currency and other monetary instruments into or 

out of the U.S.125 The central purpose of the BSA is to fight money

laundering, terrorist financing, and other illicit financing activities.

Today more than 170 crimes are listed in the federal money laundering statutes. They range from drug trafficking, gunrunning, murder

for hire, and fraud, to acts of terrorism.126

USA Patriot Act, 2001. This act was passed after the attacks of 9/11 and

greatly expanded the authority and investigative tools of law enforcement agencies to disrupt terrorist activities at home and abroad.127

The USA Patriot Act enhances the U.S. ability to combat terrorist 

financing and money laundering in several ways:

a.	 Expanding anti-money-laundering compliance program requirements of organizations, such as broker-dealers and casinos

b.	 Facilitating access to records and requiring banks to respond

to requests for information within 120 hours
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Anderson: Disrupting Threat Finances 

c. 	 Requiring regulatory agencies to evaluate an institution’s

anti-money laundering (AML) record when considering bank 

mergers, acquisitions, and other applications for business

combinations

d. Providing the Secretary of the Treasury with the authority 

to impose “special measures” on jurisdictions, institutions, 

or transactions that are of “primary money-laundering concern.” 128

U.S. Federal Regulations

EO 13224. The USG’s primary and most public tool in the fight against

terrorist financing is EO 13224.129 EO 13224 provides a means of 

disrupting the financial support network for terrorists and terrorist

organizations by authorizing the USG to designate and block the assets 

of foreign individuals and entities that commit, or pose a significant

risk of committing, acts of terrorism.130 In addition, the order authorizes 

the USG to block the assets of individuals and entities that provide 

support, services, or assistance to, or otherwise associate with, terrorists and terrorist organizations designated under the order, as well as 

their subsidiaries, front organizations, agents, and associates.131 EO 

13224 serves as an outstanding example of leveraging international

efforts to support U.S. interests. In 2005, there were 300 individuals

and entities designated by the USG pursuant to EO 13224 that were

listed on the UNSCR 1267/1617 Consolidated List.132

DoD Directives. As stated in Chapter 1, DoD has no defined authorities under U.S. law and regulations nor does DoD have an overarching policy that addresses threat finance. However, DoD derives its

roles and responsibilities from the National Strategy for Combating 

Terrorism, the National Implementation Plan (NIP), and various other 

classified national action plans.

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6. Recommendations and Desired Effects

Designate an Organization with the Mandate and Funding 

Authority to Direct Actions

Issue. Currently there is no overarching organization with the mandate 

and funding authority to direct the actions of the IA against terrorist 

organizations. 

Discussion. The NSC has the authority to coordinate actions among 

the IA. What the NSC does not have is the authority to: 

a. 	 Mandate actions when justifiable differences and priorities

occur within the IA.

b. Mandate strategic alignment of efforts and resources. 

c.	 Allocate additional resources to facilitate IA requirements when

necessary.133

In addition, the NCTC serves as the primary organization in the 

USG for integrating and analyzing all intelligence pertaining to terrorism and counterterrorism activities, conducting strategic operational 

planning by integrating all instruments of national power, and coordinating and monitoring counterterrorism plans and activities between 

the various government agencies.134 Although the NCTC has worked to 

integrate the various intelligence agencies’ efforts and coordinate the 

various counterterrorism plans and activities within the USG, those 

efforts represent only one piece of the solution. 

Neither the NSC nor NCTC has the mandate and funding authority to provide a fully integrated and resourced holistic approach to 

maximize U.S. efforts in disrupting terrorist organizations. The current 

system is predicated on the 

various IA putting aside legitimate differences with respect 

to focus, priorities, resources, 

and mission requirements and

working together in a collegial 

manner to accomplish what 

is often a poorly orchestrated 

and resourced effort. While the current system has merit, it has a 

tendency to rely heavily on force of personality and informal relationships between the various organizations rather than on any mandated 

The current system is predicated on 

the various IA putting aside legitimate 

differences...and working together 

in a collegial manner to accomplish 

what is often a poorly orchestrated 

and resourced effort.
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JSOU Report 08-3

structural mechanism to achieve its end state. The disruption of terrorist finances must be addressed within the overarching context of

threat finance, and threat finance must be integrated and resourced

as part of a holistic approach in the fight against terrorist organizations. 

Currently the U.S. operates under a system in which the NSC has 

the authority to coordinate the various efforts of organizations such as 

CIA, DHS, DoJ, FBI, DoD, Treasury Department, and NCTC, as well 

as representatives of other departments or agencies as needed. Nonetheless, the various IA all work towards their own specific goals and

agendas without an overarching organization directing their efforts. To 

be successful the U.S. must address the problem of terrorism under 

the guidance and leadership of one overarching organization that has 

the mandate and funding authority to direct all activities’ and agencies’ actions against terrorist organizations.

Recommendations 

Increase National Security Council authority. The NSC should be given 

legislative authority to: 

a. Direct actions.

b. Establish funding priorities.

c. Develop an integrated U.S. strategy.

d. Establish accountability mechanisms.

e. Allocate additional resources as needed. 

Delegate to the Sub-Counterterrorism Security Group. The NSC should 

accomplish these new mandates through the Sub-CSG. 

Implement Counterterrorism Security Group. The CSG should: 

a. Rename the Sub-CSG on Terrorist Finance to the Sub-CSG 

on Threat Finance. 

b. Designate the Sub-CSG on Threat Finance as the lead organization against Threat Finance. 

c. Establish a working group or fusion center that allows all the 

organizations of the IA, law enforcement, and banking industry 

to integrate and deconflict their actions before being brought

up to the Sub-CSG level. 
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Anderson: Disrupting Threat Finances 

Desired Effect

The desired effect is the establishment of one organization 

with the mandate and funding authority to direct and leverage 

the various assets within the U.S. in concert with one another 

to achieve a synergistic and well-orchestrated end state. These 

recommendations would help facilitate not only alignment of the disparate organizations and agencies but also foreign policy guidance, 

diplomatic engagement, and training and technical assistance to 

foreign countries. This, in turn, will: 

a. Enhance disruption of and risk to terrorist organizations 

worldwide. 

b. Increase the security of U.S. citizens.

c. Protect U.S. interests at home and abroad. 

Enhanced Multilateral Information and Intelligence Sharing

Issue. The current U.S. information and intelligence sharing framework 

is predicated on the concept of need to know versus need to share.

Discussion. Multilateral information sharing is critical to the U.S. efforts 

against terrorist organizations. Since 9/11, most of the important

U.S. successes against terrorist organizations have been made possible through effective multilateral partnerships. Continued success 

depends on the actions of a powerful coalition of nations and industry 

enhancing the flow of information and intelligence between one another.

While much of the information the intelligence community produces 

can be of significant value in the fight against terrorist organizations,

the value will not be fully realized or maximized until multilateral 

efforts are made to filter, analyze, and disseminate the information

to those organizations that can make the best use of the information 

in a timely manner.135 While great strides have been made to enhance 

the sharing of information among the IA since 9/11, the U.S. still has

a lot of room for improvement when it comes to obtaining, analyzing, 

and disseminating information in a timely fashion, especially with 

respect to the private sector entities, allies, and partner nations.

There are times when information should not be shared in a 

multilateral fashion due to political, operational, and various security 

reasons—these reasons should be treated as the exception to the rule 

rather than the norm. With respect to threat finance, information
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JSOU Report 08-3

sharing predicated on a need to know mentality actually increases 

risk. For instance, members of the USG interact weekly with various 

other nations and private industries around the world who ask to see 

the facts that substantiate the U.S. case for designating a group as 

a terrorist organization or for nominating an organization for inclusion on the UNSCR 1267/1617 Consolidated List. Unfortunately,

these questions are often not answered to the satisfaction of the questioning nation based on the unwillingness or inability of the U.S. to 

share the pertinent information that substantiates its case.136 Due to 

the fact that the country does not understand the reasons for designation, they are often less likely to support the U.S. designation,

especially when the nation views the organization in question as

a legitimate and often beneficial organization and has no available

information or intelligence to the contrary. 

Recommendations 

Implement Need to Share. The U.S. should pass applicable laws, treaties, 

arrangements, or other mechanisms that would allow and encourage 

a change in its information and intelligence sharing framework from a 

need to know to a need to share mentality. Specifically, legislation, treaties, arrangements, or other mechanisms should expand the language 

found in EO 13356: Strengthening the Sharing of Terrorism Information 

to Protect Americans, 2004 and EO 13388: Further Strengthening the 

Sharing of Terrorism Information to Protect Americans, 2005 to cover

allies and partner nations. This would allow the U.S. to:

a. Grant access to terrorism information and intelligence to the 

heads of various agencies, organizations, and nations that 

have counterterrorism functions and provide a standardized 

method for sharing information and intelligence. 

b. Cooperate in the development and facilitate the production 

of reports based on terrorism information with contents and 

formats that permit maximum dissemination.

c. Provide a common standard for the sharing of terrorism information by agencies within the intelligence community (IC). 

In addition, the U.S. could improve information and intelligence 

sharing by: 

a.	 Requiring, at the outset of the intelligence collection and analysis process, the creation of records and reporting for both raw 
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Anderson: Disrupting Threat Finances 

and processed information, including, for example, metadata 

and content in such a manner that sources and methods are 

protected so that the information can be distributed at lower 

classification levels, and by creating unclassified versions for

distribution whenever possible

b.	 Requiring records and reports related to terrorism information

to be produced with multiple versions at an unclassified level

and at varying levels of classification, e.g., on an electronic

tear line basis, allowing varying degrees of access

c.	 Requiring terrorism information to be shared free of originator

controls

d. Minimizing the applicability of information compartmentalization systems to terrorism information

e. Establishing appropriate arrangements that provide incentives 

for, and hold personnel accountable for, increased sharing 

of terrorism information consistent with requirements of the

Nation’s security.137

Improve information sharing. Legislation should be passed to expand 

the role of the Program Manager Information Sharing Environment 

(PIMSE) to include allies and partner nations. PIMSE has made headway with regard to improving terrorism information sharing between 

federal, state, local, and tribal entities and is progressing toward 

incorporating private sector entities. However, the U.S. must expand 

its efforts to facilitate information sharing with foreign governments. 

In addition, legislation should be passed to modify the Intelligence 

Reform and Terrorism Prevention Act (IRTPA), 2004 with respect to

NCTC by adding purely domestic terrorist groups to the language.

Improve data acquisition. Legislation should be passed that facilitates 

and streamlines acquisition of terrorism information data. The current

system is often a legally and bureaucratically cumbersome process, 

wherein Secretary-level government officials frequently must approve

the data transfer.138 Without timely and accurate passage of information 

the U.S. is only hampering its efforts and creating additional seams 

for terrorists to exploit. 

Desired Effect

The desired effect is a proactive information and intelligence sharing framework predicated on a need to share mentality. Through 
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JSOU Report 08-3

multilateral cooperation the U.S. will enhance the ability of its allies 

and partner nations across the globe to: 

a. Secure critical infrastructures

b. Enhance the disruption and risk to terrorist organizations 

worldwide

c. Deny terrorist funding and freedom of movement

d. Deny terrorists access to WMD/E and safe havens in ungoverned spaces around the world. 

An Integrated and Collaborative Information 

and Intelligence Sharing Network

Issue. Currently there is no integrated and collaborative information 

and intelligence sharing network within the U.S. between the IA, law 

enforcement, private sector, allies, and partner nations. 

Discussion. While there are numerous types of information and intelligence sharing architectures in existence, none of the current systems 

allow for integrated and collaborative information and intelligence 

sharing between the IA, law enforcement, private sector, allies, and 

partner nations.139 Some progress has been made over the past five

years, especially with the creation of NCTC Online (NOL), but most 

of the current systems are disjointed and stovepiped and still do not 

maximize timely information and intelligence sharing. 

One of the keys to success in the effort to disrupt terrorist organizations is the ability of IA, law enforcement, private sector, allies, 

and partner nations to conduct integrated and collaborative efforts 

over a network that is secure, flexible, and allows for timely passage

of information, while being robust enough to meet evolving command, 

control, communications, and computer requirements.

Recommendation

The U.S. should create an integrated and collaborative information 

and intelligence sharing network among the IA, law enforcement, 

private sector, allies, and partner nations called the Worldwide Information and Intelligence Network (WIIN) (see Appendix G for a more 

comprehensive explanation).140 WIIN would create an integrated and 

collaborative international online community against terrorism that 

could be used to: 

a. Maximize the use of limited resources. 
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Anderson: Disrupting Threat Finances 

b. Filter, analyze, and disseminate practical information in a 

timely manner using tear lines for those organizations that 

can best use the information.

c.	 Create access to raw, current, and finished intelligence products.

d. Facilitate development of international standards with regard 

to intelligence reporting, legal authorities, law enforcement, 

banking, definitions and terms, and technical and training

assistance.

e. Increase law enforcement ability to prevent, investigate, and 

prosecute terrorist organizations through the exchange of 

information between law enforcement, security agencies, and 

private sector organizations.

f. Create a repository for standardized data points on patterns, 

techniques and mechanisms that would enhance modeling of

terrorist organizations and increase international understanding of the patterns and behaviors of terrorist organizations.

g. Facilitate the development of metrics to measure the effects 

of current counterterrorism efforts.

h. Help create an effective risk-based holistic screening tool.

i. Create a service-oriented architecture to separate data from 

applications and improve the integration of legacy capabilities. 

The advantages of WIIN are that: 

a. The Internet is used as the coordination backbone.

b. Provides a platform for integrated collaboration and communications from the Unclassified to Top Secret (TS)/Sensitive

Compartmented Information (SCI) levels. 

c. All communication systems used in the system comply with 

NSA and Communications Security Establishment (CSE) standards for Type 1 encryption.

d. 	 All traffic from site to site is encrypted in accordance with NSA

guidelines using Type 1 encryption devices.

e.	 Does not require additional hardware at the individual user

level.

f. It is deployable.
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JSOU Report 08-3

g.	 Provides capabilities for file sharing and transfer, e-mail, Web

conferencing with Voice over IP (VoIP), chat, instant messaging, Web-based information management (which in turn allows 

publishing and compartmentalization of the system), and 

providing a Common Operational Picture (COP) at a package 

cost of $1,200,000 per server with a tail of $250,000 per year

as designed. 

While WIIN would create a complicated balance of legal, technical, security, and policy matters that would need to be resolved, and 

a massive quantity of information that would need to be filtered, the

gains would far outweigh the risks and challenges involved. Since 

various organizations around the world hold different pieces of the 

terrorist finance puzzle, it is critical for the U.S. to have the ability to

access information and intelligence in its entirety if it hopes to create 

a complete picture against which to allocate its resources. 

Desired Effect

The desired effect is an integrated collaborative network that enhances 

information and intelligence sharing among the IA, law enforcement, 

private sector, allies, and partner nations from the Unclassified to

TS/SCI level on a need to share basis. This, in turn, will enhance the 

disruption and risk to terrorist organizations worldwide, increase 

the security of U.S. citizens, and protect U.S. interests at home and 

abroad.

DoD Policy and Way Ahead

Issue. Currently, the DoD has neither policy nor way ahead on how to 

facilitate and integrate its threat finance efforts with regard to the IA,

law enforcement, private sector, allies, and partner nations. 

Discussion. While the DoD derives its threat finance roles and responsibilities from the National Strategy for Combating Terrorism (NSCT), 

2006, the NIP, and various other national actions plans, these strategies and plans do not constitute a DoD threat finance policy or way

ahead. The DoD has also developed the National Military Strategic 

Plan for the War on Terrorism (NMSP-WOT), 2006, and several other

classified plans, execution orders, and assessments to combat terrorism, but these documents do not constitute a policy or way ahead 

with respect to threat finance, either.
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Anderson: Disrupting Threat Finances 

Other threat finance areas that DoD should address to maximize

its capabilities and resources to better protect U.S. interests at home 

and abroad include developing: 

a.	 Refined threat finance organizational structure

b. Types of actions that could be conducted in support of the IA, 

law enforcement, allies, and partner nations

c. Doctrine, organization, training, material, leadership, facilities, 

and personnel (DOTMLFP) requirements

d.	 Cadre of experts in the field of threat finance and a method

for tracking these experts within DoD

e. Comprehensive education and training program

f.	 Baseline list of equipment requirements

g.	 Tactics, techniques, and procedures

h.	 New threat finance doctrine, as well as an integration of current threat finance concepts into current doctrine

i. Method that would synchronize the DoD terrorist list with the IA

j. Synchronization method that broadens DoD focus from GCC 

level to the global level and that allows DoD to speak with one 

voice when interacting with IA, law enforcement, private sector, 

allies, and partner nations at the strategic level

k. Better relationships with the IA, law enforcement, private sector, 

allies, and partner nations to enhance DoD understanding 

of their equities, objectives, and requirements. DoD needs to

place more emphasis and resources behind its efforts. 

The first NMSP-WOT, 2006 GWOT military strategic objective listed

is to deny terrorists the resources they need to operate and survive.141

If this is truly the DoD number one strategic objective, then DoD 

should allocate additional resources accordingly. 

Recommendations 

Develop policy. The first recommendation is for DoD to develop a clear

and well thought out policy and way ahead through a collaborative 

effort between the Secretary of Defense, Under Secretary of Defense for 

Policy, Assistant Secretary of Defense for Special Operations and Low 

Intensity Conflict (ASD SO/LIC), Joint Chiefs of Staff, unified combatant commands, combat support agencies (CSA), IA, law enforcement, 

private sector, allies, and partner nations.142
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JSOU Report 08-3

The Under Secretary of Defense for Policy should develop, coordinate, and oversee the implementation of DoD policy for threat finance

planning, preparation, coordination, implementation, support, and 

lessons learned, and represent DoD at the Sub-CSG on Terrorist 

Finance. 

The ASD SO/LIC should:

a. Serve as the principal staff assistant and civilian advisor to 

the Secretary of Defense and the Undersecretary of Defense 

for Policy on threat finance.

b. Establish and promulgate goals and objectives, policy guidance, and recommendations on threat finance.

c.	 Determine threat finance requirements in accordance with

DoD threat finance policy and strategic guidance, once it is

developed.

d. Promulgate policy and provide policy guidance and recommendations on DoD support to other government agencies.

e. Coordinate the development of a plan of action and milestones 

(POAM)

f.	 Coordinate and review DoD progress toward developing a flexible and fully integrated threat finance architecture.

g.	 Serve as the DoD focal point for integrating DOTMLFP requirements.

h.	 Convene a threat finance coordination group to develop, review,

and recommend policy level actions which would serve to integrate the actions of various DoD entities. 

The Joint Chiefs of Staff should: 

a. Provide advice to the Secretary of Defense on military aspects 

of threat finance.

b.	 Coordinate implementation of a threat finance policy and

DOTMLFP requirements.

c.	 Ensure that the Joint Requirements Oversight Council (JROC)

reviews threat finance annual requirements.

Each of the unified combatant commands and defense agencies

should develop a threat finance capability with clearly delineated roles

and responsibilities that are integrated with a Joint and Interagency 

Coordination Group (JIACG) tailored to meet the requirements and
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Anderson: Disrupting Threat Finances 

challenges of their organizations. Such actions would result in improved 

interagency cooperation and operational effectiveness at the operational and tactical level. If the unified combatant command or defense

agency does not have a JIACG or a Joint Interagency Task Force, then 

at a minimum DoS and the Treasury Department should exchange 

liaison officers (LNOs) and increase IA assignments to enhance threat

finance coordination and interoperability.

Finally, USSOCOM should be appointed as the synchronizing 

entity within DoD to promote interoperability with regard to equipment requirements; education and training; doctrinal development

and integration; tactics, techniques, and procedures development and

integration; developing and advancing threat finance capabilities; and

terrorist designation integration and synchronization between the DoD 

and the IA by adopting the NCTC tiered threat priority construct.

This first recommendation is by no means a complete solution to

the problem and does not address several of the current problems 

related to threat finance. For instance, the roles for several of the

Under Secretary and Assistant Secretary positions, such as the Under 

Secretary of Defense for Intelligence should be examined, and there is 

a need for additional working groups, like a Threat Finance Technology Working Group (TFTWG). 

Organizational Structure. The second recommendation is to refine the

current threat finance organizational structure within DoD.143

The proposed organizational structure facilitates integration, collaboration, enhanced utilization of resources, flexibility, and synchronization of effort between DoD and the IA from the tactical to strategic 

level, and it helps to create one DoD voice at the strategic level. The 

proposed threat finance organizational and command structure contains four key concepts:

a. Does not change the current command and control relationship between GCCs and CSAs with the Secretary of Defense. 

b.	 Clarifies the synchronization role conducted by USSOCOM.

c.	 Provides a linkage for maximizing DoD threat finance integration between GCCs and CSAs and the IA through the use of 

TFEUs. 

d. Establishes a mechanism for the DoD to speak with one voice 

to the IA at the national level. 
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The advantage of the proposed recommendation is that it maximizes 

the ability of unified combatant commanders to execute their missions

and leverage IA capabilities, and vice versa, while synchronizing their 

efforts across the globe. In addition, it provides a flexible mechanism

for DoD to integrate, support, and build relationships with the IA, 

law enforcement, private sector, allies, and partner nations. Third, it 

places a threat finance exploitation capability within all the unified

commands that can be utilized to disrupt threat finances.

Action list. The third recommendation is that DoD develop a comprehensive and integrated list of actions that could be conducted in 

support of other government agencies, law enforcement, allies, and 

partner nations. Some of the actions that DoD could take include: 

a.	 Expanding the definition of threat finance to include economic

warfare

b. Providing intelligence collection support along with analysis 

and the widest dissemination of the information on a need to 

share basis

Figure 3. Proposed DoD Threat Finance Organizational and Command 

Structure

National Security Council

Principals Committee

Deputies Committee

Counterterrorism

Security Group

Sub-CSG on 

Terrorist Finance

President

Secretary

of Defense

Ass’t to the President

for Nat’l Security Affairs

Secretary

of Defense

Under Secretary of Defense 

for Policy

Ass’t Secretary

of Defense

– SOLIC

Joint Chiefs

of Staff

Joint and Interagency Group / Joint Interagency Task Force

USSOCOM Synchronizing

Combat Support

Agencies

Reserve

Affiars

USAFRICOM

USEUCOM

USNORTHCOM

USSOCOM

USPACOM

USSOUTHCOM

USSTRATCOM

USJFCOM

USTRANSCOM

TF TF TF TF TF TF TF TF TF TF TF

TF

TF

Direct

Advise

Coordinate

Threat Finance

Capability

SOLIC: Special Operations

Low Intensity Conflict
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Anderson: Disrupting Threat Finances 

c. Providing situational awareness through the presence of service 

members on the ground

d. Providing the conditions that allow the IA, law enforcement, 

allies, and partner nations to conduct operations within a 

non- or semi-permissive environment

e. Creating a multilateral information sharing network as discussed earlier in this chapter to facilitate the rapid dissemination and exploitation of information

f. Providing LNOs and increasing interagency and intergovernmental assignments to help break down organizational stovepipes and advance the exchange of ideas and practices for a 

more effective counterterrorism effort

g. Placing DoD personnel on DoS-lead Financial Systems Assessment Team (FSAT)

h. Infusing and sewing the seeds of doubt, distrust, and deception into terrorist organizations and networks to expand the 

threat seams and gaps that currently exist

i. Conducting senior leader visits to the various IA

j.	 Developing a global engagement strategy that integrates 1206

funding

k. Enhancing Sensitive Sight Exploitation (SSE) to improve evidence collection, prosecution, and data collection

l. Creating a data and trend analysis repository that is facilitated 

by the multilateral information sharing network on a need to 

share basis

m. Expanding computer network exploitation

n. Enhancing capabilities and actions during the initial detention 

facility screening process which would allow the IA to maximize 

their resources.

Personnel. The fourth recommendation is to expand education, training, 

and personnel utilization in the area of threat finance. To accomplish

this, DoD should: 

a.	 Establish or integrate a DoD threat finance course at the resident and nonresident level.

b.	 Send select personnel to the various IA threat finance courses

and seminars.
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c.	 Allocate five to seven graduate level threat finance-associated

slots a year under the advanced civil schooling program.

d.	 Develop and integrate threat finance into existing joint doctrine.

e.	 Establish and promulgate tactics, techniques, and procedures.

f.	 Promote integration of threat finance during mission readiness

exercises, such as those conducted at USJFCOM.

g. Develop a “train the trainer” program.

h. Establish mobile training teams.

i.	 Host an annual threat finance conference that includes IA,

law enforcement, private sector, allies, and partner nations.

j. Identify and track personnel who have been trained in threat 

finance by creating an enlisted and officer threat finance skill

identifier to assist in future threat finance assignment utilization. By developing and fostering subject matter experts through 

education, training, and personnel utilization, the DoD will be 

better equipped to disrupt threat finance in a proactive and

flexible manner.

Desired Effect

A well thought-out policy and way ahead that is flexible and will

facilitate an integrated DoD threat finance effort regarding the IA,

law enforcement, private sector, allies, and partner nations. Like any 

organization, DoD cannot hope to reach its desired end state without 

first determining what that end state looks like, developing a phased

plan to reach that end state, determining alignment of resources, and 

then developing a policy to facilitate its way ahead.
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Anderson: Disrupting Threat Finances 

7. Conclusion

I

n the years since 9/11, the fight against terrorist organizations

has been fought on many fronts, with a great amount of attention being paid to DoD actions in Afghanistan and Iraq and to the

prosecutions and preventive measures taken by the DoJ and DHS. 

Meanwhile, a somewhat quieter, complex campaign against terrorist financing has shown that financial information and intelligence,

investigations, prosecutions, sanctions, and diplomacy, when carefully 

coordinated and facilitated through international standards among the 

IA, private sector, allies, and partner nations, can make a meaningful 

contribution to enhance U.S. security, disrupt terrorist operations and 

mitigate terrorist effects on U.S. strategic interests.144

The struggle against terrorism should focus on disrupting terrorist 

organizations and networks by constricting their operating environment, making it harder for terrorists to conduct operational, logistical, 

and financial activities. Although it may be impossible to completely

eradicate terrorism, it is possible to 

constrict the operating environment 

to the extent that it will eventually 

lead to the suffocation of an individual terrorist organization. For 

instance, the Abu Nidal organization in the 1980s was the Al Qaeda of today; however, it no longer

exists. So too will come a day when the primary international terrorist threat to U.S. interests is no longer posed by Al Qaeda. Sadly, as 

long as there are intolerant and violent humans on this earth, there 

will always be another terrorist organization standing in the wings to 

take its place.145

Therefore, if the U.S. hopes to be successful in its efforts against 

terrorist organizations, it must focus its efforts towards constricting 

the terrorists’ operating environment by: 

a. Increasing its expertise and allocation of resources against the 

disruption of terrorist financing

b. Building capacity for improved governance by working with 

allies and partner nations across all elements of national 

power to improve their ability to detect and disrupt terrorist 

organizations

Although it may be impossible to 

completely eradicate terrorism, 

it is possible to constrict the 

operating environment...
46

JSOU Report 08-3

c. Conducting an integrated and coordinated effort at the international level through: i) the promotion of international intelligence and information sharing; ii) the establishment of

common standards, tools, and protocols; and iii) fostering an

environment of mutual understanding and respect between 

U.S. allies and partner nations. 
47

Anderson: Disrupting Threat Finances 

Endnotes

	 1.	 John Roth, Douglas Greenburg, and Serena Wille, National Commission

on Terrorist Attacks Upon the United States, Monograph on Terrorist 

Financing: Staff Report to the Commission (Washington, DC: Government 

Printing Office, 2004), 17.

	 2.	 U.S. Senate, Committee on Banking, Housing, and Urban Affairs, Subcommittee on International Trade and Finance, Testimony by Matthew 

Levitt, Senior Fellow, Washington Institute for Near East Policy, “Role of 

Charities and NGOs in the Financing of Terrorist Activities,” 1 August

2002, 2, available from http://banking.senate.gov/02_08hrg/080102/

levitt.htm (accessed 18 September 2006).

3. Matthew Levitt, “Untangling the Terror Web: Identifying and Counteracting the Phenomenon of Crossover between Terrorist Groups,” SAIS 

Review 24, no. 1 (2004): 33.

	 4.	 Roth, et al., 19.

	 5.	 The White House, Executive Order 13224, Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten to Commit, 

or Support Terrorism, 23 September 2001, available from www.fas.org/

irp/offdocs/eo/eo-13224.htm (accessed 27 February 2007).

	 6.	 Government Accountability Office, GAO-06-19, Terrorist Financing:

Better Strategic Planning Needed to Coordinate U.S. Efforts to Deliver 

Counterterrorism Financing Training and Technical Assistance Abroad 

(Washington, DC: GAO, 2005), i.

	 7.	 The White House, Executive Order 13224.

	 8.	 Section (section) 6(j) of the Export Administration Act, section 40 of the

Arms Export Control Act, and section 620A of the Foreign Assistance

Act; Pursuant to 8 United States Code (USC) section 1189; Pursuant

to 50 USC, section 1701-1706, International Emergency Economic

Powers Act (IEEPA); See State Sponsors of Terror, FTOs, SDGTs, Terrorist Exclusion List, and Specially Designated Nationals, at the U.S. 

Department of State Web site, available from www.state.gov/, and the 

U.S. Treasury Department Web site, available from www.ustreas.gov/ 

(accessed 18 September 2006) and U.S. Laws, Federal Regulations,

Federal Register Notices, Cornell School of Law Web site, available from 

www4.law.cornell.edu/ (accessed 18 September 2006).

	 9.	 National Strategy for Combating Terrorism, September 2006, 5.

	 10.	 United Nations, UN Action to Counterterrorism, 9 December 1999, available from www.un.org/terrorism/ (accessed 27 February 2007).

	 11.	 House of Representatives, Committee of Financial Services, Subcommittee on Oversight and Investigations, Statement by Juan C. Zarate, 

“Patriot Act oversight: Investigating Patters of Terrorist Financing,” 12

February 2002, 7, available from financialservices.house.gov/media/

pdf/107-53.pdf (accessed 27 February 2007).
48

JSOU Report 08-3

	 12.	 General Accounting Office, GAO-04-163, Terrorist Financing: U.S. Agencies Should Systematically Assess Terrorists’ Use of Alternative Financing 

Mechanisms (Washington, DC: GAO, 2003), 9-10; and General Accounting Office, GAO-04-501T, Combating Terrorism, Federal Agencies Face 

Continuing Challenges in Addressing Terrorist Financing and Money 

Laundering (Washington, DC: GAO, 2004), 6.

	 13.	 U.S. Senate, Committee on Governmental Affairs, Testimony by Lee

L. Wolosky, Schiller Boies, and LLP Flexner, “Terrorist Financing,” 29

September 2004, 1-2.

	 14.	 Department of the Treasury, Office of Foreign Assets Control, Terrorist Assets Report 2001, (Washington, DC: Government Printing Office,

December 2001), 9.

	 15.	 Roth et al., 29.

	 16.	 Ibid., 9.

	 17.	 Ibid., 17.

	 18.	 U.S. Senate, Committee on Banking, Housing, and Urban Affairs, Testimony of Anthony E. Wayne, Assistant Secretary for Economic and 

Business Affairs, “The State Department Role in Combating the Financing of Terrorism,” 4 April 2006, available from www.state.gov/e/eeb/

rls/rm/2006/ 64109.htm (accessed 18 September 2006) and authors 

personal analysis.

	 19.	 Government Accountability Office, GAO-06-19, 5.

	 20.	 Ibid.

	 21.	 Richard Shelby, U.S. Senator, Senate Banking Committee to Hold

Hearing on Terrorist Financing, Washington, DC: 20 October 2003,

37, available from http://shelby.senate.gov/legislation/legis-record.

cfm?id=213770 (accessed 27 February 2007).

	 22.	 Government Accountability Office, GAO-06-19, 5.

	 23.	 Kitfield and Levey, 2.

	 24.	 House of Representatives, Committee on Government Reform, Subcommittee on Criminal Justice Drug Policy and Human Resources, 

Testimony of Daniel L. Glaser, Director, Executive Office for Terrorist

Financing and Financial Crime, U.S. Department of the Treasury, 11

May 2004, 2, available from www.ustreas.gov/press/releases/js1539.

htm (accessed 18 September 2006).

	 25.	 Headquarters Department of Defense, Joint Publication 1-02, DoD Dictionary of Military and Associated Terms (Washington, DC: Government 

Printing Office, 2006), 146.

	 26.	 A More Secured World: Our Shared Responsibility, United Nations,

December 2004.

	 27.	 National Commission on Terrorist Attacks Against the United States.

22 July 2004; 108-214.

	 28.	 Joint Publication 1-02, 375.

	 29.	 U.S. Senate, Judiciary Subcommittee on Terrorism, Technology, and

Homeland Security, Matthew A. Levitt, Senior Fellow in Terrorism 
49

Anderson: Disrupting Threat Finances 

Studies and The Washington Institute for Near East Policy “Terrorist 

Financing,” 10 September 2003, 3.

	 30.	 Ibid., 1-3.

	 31.	 Ibid., 3.

	 32.	 Lee H. Hamilton, Vice Chair, and The National Commission On Terrorist Attacks Upon The United States, “Terrorist Financing,” FDCH 

Congressional Testimony, 1.

	 33.	 Roth et al., 17-19.

	 34.	 Kitfield and Levey, 2.

35. Lee H. Hamilton, Vice Chair, and The National Commission On Terrorist Attacks Upon The United States, “Terrorist Financing,” FDCH 

Congressional Testimony, 4.

	 36.	 The White House, Executive Order 13224.

	 37.	 Department of Treasury, Office of Foreign Assets Control, Terrorist 

Assets Report 2005. Fourteen Report to Congress on Assets in the United 

States of Terrorist Countries and Internal Terrorism Program Designees, 

December 2005, 5, available from www.treas.gov/offices/enforcement/

ofac/reports/tar2005.pdf (accessed 18 September 2006).

	 38.	 Roth et al., 1.

	 39.	 Government Accountability Office, GAO-06-19, 2.

	 40.	 Ibid., 3.

	 41.	 Ibid., 33.

	 42.	 Department of Treasury, Terrorist Assets Report 2005, 6.

	 43.	 Ibid.

	 44.	 Government Accountability Office, GAO-06-19, 33.

	 45.	 U.S. Senate, Committee on Governmental Affairs, Testimony by Lee

L. Wolosky, Schiller Boies, and LLP Flexner, “Terrorist Financing,” 29

September 2004, 3.

	 46.	 Todd M. Hinnen, “The Cyber-Front in the War on Terrorism: Curbing

Terrorist use of the Internet,” The Columbia Science and Technology 

Law Review, vol. 5 (2004): 2.

	 47.	 As referenced in Appendix C.

	 48.	 General Accounting Office, GAO-04-501T, 6.

	 49.	 See Appendix D.

	 50.	 General Accounting Office, GAO-04-163, 3.

	 51.	 See Figure 1: Example Terrorist Organization Hierarchal Structure;

and Levitt, “Terrorist Financing,” 19.

	 52.	 See Figure 2; and John Arquilla and David Ronfeldt, Networks and 

Netwars: The Future of Terror, Crime, and Military (Santa Monica CA: 

National Defense Research Institute, 2001), 30.

	 53.	 Levitt, “Terrorist Financing,” 19.

	 54.	 Levitt, SAIS Review, 2.

	 55.	 Levitt, “Terrorist Financing,” 1-3.
50

JSOU Report 08-3

	 56.	 Joint Publication 1-02, 101.

	 57.	 White House, “National Strategy for Combating Terrorism,” September 2006, 17. available from www.state.gov/s/ct/rls/wh/71803.htm

(accessed 15 March 2007).

	 58.	 Arquilla and Ronfeldt, 33.

	 59.	 Ibid., 34.

	 60.	 For the purposes of this monograph, the term Internet does not include 

the separate network infrastructures provided for automated teller 

machine (ATM), wire transfer, or debit and credit card networks, although 

it does include Web-based applications through which debit, credit or 

value card transactions may be accomplished.

	 61.	 White House, “National Strategy for Combating Terrorism,” 17.

	 62.	 White House, “National Strategy for Combating Terrorism,” 12.

	 63.	 Courtney J. Linn, “How Terrorists Exploit Gaps in U.S. Anti-Money

Laundering Laws to Secrete Plunder,” Journal of Money Laundering 

Control 8, no. 3 (March 2005): 1.

	 64.	 The White House, National Security Strategy of the United States of 

America (Washington, DC: Government Printing Office, 2006), 9-45.

	 65.	 Raphael Perl, Terrorism and National Security: Issues and Trends (Washington, DC: Congressional Research Service, The Library of Congress, 

2004), 14-15, available from www.fas.org/irp/crs/IB10119.pdf (accessed

27 February 2007).

	 66.	 See Appendix D for a more in-depth description of the various organizations mentioned in this section.

	 67.	 Government Accountability Office, GAO-06-19, 2-6.

	 68.	 See Appendix D for further information and discussion.

	 69.	 Perl, 14-15. Authors note: It is important to understand that the NSC

does not control the law enforcement community or its actions, it merely 

maintains coordination authority.

	 70.	 See Appendix D.

	 71.	 PDD 39, June 1995, 1.

	 72.	 General Accounting Office, GAO-03-165, Combating Terrorism: Interagency Framework and Agency Programs to Address the Overseas Threat

(Washington, DC: GAO, 2003), 147.

	 73.	 See Appendix D for more detailed information, composition and discussion on the TFI.

	 74.	 See Appendix D for a more detailed list of Treasury offices, services,

task forces and networks.

	 75.	 U.S. Senate, Committee on Banking, Housing, and Urban Affairs,

Testimony of Anthony E. Wayne, Assistant Secretary for Economic 

and Business Affairs, “The State Department Role in Combating the 

Financing of Terrorism,” 4 April 2006, 3, available from www.state.

gov/e/eeb/rls/rm/2006/ 64109.htm (accessed 18 September 2006).

	 76.	 General Accounting Office, GAO-03-165, 150.
51

Anderson: Disrupting Threat Finances 

	 77.	 See Appendix D for a more detailed list of DoS agencies, bureaus,

councils, and offices.

	 78.	 Barry Sabin, Acting Deputy Assistant Attorney General, and Department of Justice, “Counterterrorism Financing,” FDCH Congressional 

Testimony, 2006, 1-2.

	 79.	 Government Accounting Office, GAO-03-165, 149.

80. See Appendix D for a more detailed list of DoJ bureaus, administrations, sections, branches, task forces, and offices.

	 81.	 Government Accounting Office, GAO-03-165, 149.

	 82.	 See Appendix D for a more detailed list of DHS units and bureaus.

83. House Armed Services Committee, Subcommittee on Terrorism, Unconventional Threats, and Capabilites and House Financial Services, 

Subcommittee on Oversight and Investigations, Statement of James Q. 

Roberts, “Terrorist and Insurgent Financing,” 28 July 2005, 2, available

from www.dod. mil/dodgc/olc/docs/Test05-07-28Roberts.doc (accessed

18 September 2006).

	 84.	 CW3 Thomas Newell, “The Use of Special Operations Forces in Combating 

Terrorist Finances,” Naval Post Graduate School, Monterey California, 

2006, i.

85. House Armed Services Committee, Subcommittee on Terrorism, Unconventional Threats and Capabilities, Statement by Marshall Billingslea, 

“Special Operations Forces Acquisition,” 1 April 2003, available from

www.globalsecurity.org/military/library/congress/2003_hr/03-04-

01billingslea.htm (accessed 18 September 2006).

	 86.	 Thomas O’Connell, “Update On Special Operations Forces,” 2004, Testimony before The Senate Committee On Armed Services, United States 

Senate, 6-7.

	 87.	 House Armed Services Committee, “Terrorist and Insurgent Financing,”

3-4.

88. Thomas W. O’Connell, Defense Perspectives: The War on Terrorism, 

2006, 16-17, available from www.dtic.mil/ndia/2006solic/oconnell.

pdf (accessed 18 September 2006).

	 89.	 Jimmy Gurule, “The Global Effort to Stop Terrorist Financing,” Hampton 

Roads International Security Quarterly (January 2004): 2.

	 90.	 Department of the Treasury, Fact sheet, Contributions by the Department 

of Treasury to the Financial War on Terror, September 2002, 5, available

from www.ustreas.gov/press/releases/ reports/2002910184556291211.

pdf (accessed 18 September 2006).

	 91.	 See Appendix E: International Organizations and Efforts to Disrupt

Terrorist Financing for a more comprehensive list of these organizations 

and efforts.

	 92.	 Todd M. Hinnen, Chief Counsel of the Senate Judiciary Committee,

Annotated comment on draft version 1.1 of this monograph, 3 March

2007.
52

JSOU Report 08-3

	 93.	 United Nations, Coordinating Counterterrorism Actions Within and Beyond 

the UN system, available from www.un.org/terrorism/cttaskforce.html 

(accessed 27 February 2007).

	 94.	 United Nations, United Nations Action to Counterterrorism, available 

from www.un.org/terrorism/ (accessed 27 February 2007).

	 95.	 See Appendix E: International Organizations and Efforts to Disrupt

Terrorist Financing for a more complete description of United Nations 

efforts.

	 96.	 Gurulé, 3-4.

	 97.	 See Appendix E: International Organizations and Efforts to Disrupt

Terrorist Financing for a description of FATF Forty Recommendations 

on Money Laundering and Nine Special Recommendations on Terrorist 

Financing.

	 98.	 Financial Action Task Force, Report on Money Laundering and Typologies 2002-2003. 14 February 2003, 1, available from www.pszaf.hu/

resource.aspx?ResourceID= penzmos_fatf_ty2003 (accessed 18 September 2006).

	 99.	 House of Representatives, Financial Services, Subcommittee on Oversight and Investigations and the House of Representatives, International 

Relations, Subcommittee on International Terrorism and Nonproliferation; Testimony of Stuart Levey, Under Secretary, and Department of

the Treasury, “Terror Financing in the Middle East; Terror Financing in

the Middle East,” 4 May 2005, 3, available from www.treas.gov/press/

releases/js2427.htm (accessed 18 September 2006).

	100.	 Government Accounting Office, GAO-03-165, 152.

	101.	 Ibid., 141-142.

	102.	 The International Criminal Police Organization, Financial and HighTech Crimes, available from www.interpol.int/Public/FinancialCrime/

Default.asp (accessed 27 February 2007).

	103.	 The International Criminal Police Organization, Fusion Task Force,

available from www.interpol.int/Public/FusionTaskForce/default.asp 

(accessed 27 February 2007).

	104.	 Department of State, U.S. Interagency Efforts to Combat Terrorist 

Financing, available from www.state.gov/e/eb/rls/rm/2003/29144.

htm (accessed 18 September 2006).

	105.	 United Nations, UN Action to Counterterrorism, 1.

	106.	 Summary of all 13 conventions available from http://untreaty.un.org/

English/Terrorism.asp.

	107.	 United Nations, International Convention for the Suppression of the 

Financing of Terrorism, 1999, 1-15, available from www.un.org/law/

cod/finterr.htm (accessed 18 September 2006).

	108.	 United Nations, Convention against Transnational Organized Crime, 

2000, 1, available from www.unodc.org/adhoc/palermo/convmain.

html (accessed 18 September 2006).
53

Anderson: Disrupting Threat Finances 

	109.	 United Nations, United Nations Convention against Transnational Organized Crime, 2000, 1-34, available from www.unodc.org/unodc/en/

crime_cicp_convention.html (accessed 27 February 2007).

	110.	 Government Accounting Office, GAO-06-19, 8.

	111. House of Representatives, Committee on Government Reforms, Subcommittee on Technology and Information Policy Intergovernmental 

Relations and the Census, Testimony of George Glass, Director of the 

Office of Terrorism Finance and Sanctions Policy, Department of State,

“U.S. Interagency Efforts to Combat Terrorist Financing,” 15 December 2003, 3, available from www.globalsecurity.org/ security/library/

congress/2003_h/031215-state_testimony.pdf (accessed 18 September

2006).

	112.	 United Nations Security Council, Resolution 1267, 15 October 1999,

1-4, available from www.un.org/Docs/scres/1999/sc99.htm (accessed

1 March 2007).

	113.	 The White House, Executive Order 13224, 1.

	114.	 United Nations Security Council, Resolution 1269, 19 October 1999,

1-2, available from www.un.org/Docs/scres/1999/sc99.htm (accessed

1 March 2007).

	115.	 United Nations Security Council, Resolution 1373, 28 September 2001,

1-4, available from www.un.org/docs/scres/2001/sc2001.htm (accessed

1 March 2007).

	116.	 United Nations Security Council, Resolution 1617, 29 July 2005, 1-8,

available from www.un.org/Docs/sc/unsc_resolutions05.htm (accessed

1 March 2007).

	117.	 United Nations Security Council, Resolution 1730, 19 December 2006,

available from www.un.org/Docs/sc/unsc_resolutions06.htm (accessed

1 March 2007).

	118.	 United Nations Security Council, Resolution 1735, 22 December 2006,

available from www.un.org/Docs/sc/unsc_resolutions06.htm (accessed

1 March 2007).

	119.	 See Appendix D for a more in depth list that pertain to terrorist financing.

	120.	 85th Congress of the U.S. 1977, International Emergency Economic 

Powers Act, available from www.law.cornell.edu/uscode/50/usc_

sup_01_50_10_35.html (accessed 18 March 2006).

	121.	 Ibid., 5.

	122.	 Charles Doyle, Antiterrorism and Effective Death Penalty Act of 1996: A 

Summary, 3 June 1996, available from www.fas.org/irp/crs/96-499.

htm (accessed 18 September 2006).

	123.	 104th Congress of the U.S. 1996, Antiterrorism and Effective Death 

Penalty Act, 1-150, available from usinfo.state.gov/usa/infousa/laws/

majorlaw/s735.htm (accessed 18 September 2006).

	124.	 Ibid., 50-55.
54

JSOU Report 08-3

	125.	 House of Representatives, Committee on International Relations, Testimony of Herbert A. Biern, “The Bank Secrecy Act and the USA Patriot 

Act,” 17 November 2004, available from www.federalreserve.gov/boarddocs/testimony/2004/20041117/default.htm (accessed 18 September

2006).

	126.	 Department of the Treasury, Bank Secrecy Act, 1970, available from

www.fincen.gov/reg_statutes.html (accessed 18 September 2006).

	127.	 Scott Sulzer, “Money Laundering: The Scope of the Problem and Attempts

to Combat It,” Tennessee Law Review, 143 (1995): 153.

	128. Uniting and Strengthening America by Providing Appropriate Tools 

Required to Intercept and Obstruct Terrorism Acts of 2001, Pub. L. No. 

107-56, 115 stat. 272 (codified and amended in scattered sections of

8, 15, 18, 22, 31, 42, 49, and 50 of the United States Code), available

from www.fincen.gov/pa_main.html (accessed 18 September 2006).

	129.	 House of Representatives, Committee on Government Reform, Subcommittee on Criminal Justice Drug Policy and Human Resources, 

Testimony of Daniel L. Glaser, Director, Executive Office for Terrorist

Financing and Financial Crime, U.S. Department of the Treasury, 11

May 2004, 1, available from www.ustreas.gov/press/releases/js1539.

htm (accessed 18 September 2006).

	130.	 EO 13224 gives the Departments of the Treasury and State the ability

to designate terrorists and terrorist financiers and gives the Treasury

Department the ability to implement orders that freeze the assets of 

designated terrorists.

	131.	 The White House, Executive Order 13224, 1.

	132.	 Department of Treasury, Terrorist Assets Report 2005, 1-6.

	133.	 The White House, The National Security Council, available from www.

whitehouse.gov/nsc/ (accessed 27 February 2007).

	134.	 National Counterterrorism Center, NCTC, available from www.nctc.gov/ 

(accessed 18 September 2007).

	135.	 U.S. Senate, Committee on Banking, Housing and Urban Affairs, Testimony of John S. Pistole, Assistant Director, Counterterrorism Division, 

FBI, “Identifying, Tracking and Dismantling the Financial Structure of 

Terrorist Organizations,” 25 September 2003, 5, available from www.

fbi.gov/ congress/congress03/pistole092503.htm (accessed 11 March

2007).

	136.	 Levitt, “Terrorist Financing,” 35.

	137.	 The White House, Executive Order 13356, Strengthening the Sharing of 

Terrorism Information to Protect Americans, 27 August 2004, available

from www.fas.org/irp/offdocs/eo/eo-13356.htm (accessed 27 February

2007).

	138.	 National Counterterrorism Center, NCTC and Information Sharing, Five 

Years Since 9/11: A Progress Report (Washington, DC: GAO, 2006), 10,

available from www.nctc.gov/docs/report_card_final.pdf (accessed 28

September 2006).
55

Anderson: Disrupting Threat Finances 

	139.	 Such systems include:

a. NCTC Online (NOL)

b. Joint Worldwide Intelligence Communications System (JWICS)

c. Law Enforcement Online (LEO)

d. FinCEN Communications Network

e. GRIFFIN 

f. FBI Intranet

g. Data Analysis and Research for Trade Transparency System 

(DARTTS)

h. Secret Internet Protocol Router Network (SIPRNet)

i. DoD Intelligence Information System (DODIIS)

j.	 INTERPOL’s I-24/7 Global Police Communications System

k. Egmont Group Secure Web. 

	140.	 See Appendix F, Worldwide Information and Intelligence Network (WIIN),

for design and capabilities of proposed system.

	141.	 Department of Defense, National Military Strategic Plan for the War on 

Terrorism, 1 February 2006, available from www.defenselink.mil/qdr/

docs/2005-01-25-Strategic-Plan.pdf (accessed 18 September 2006).

	142.	 The current unified commands are Reserve Affairs Worldwide Support, 

USEUCOM, USJFCOM, USNORTHCOM, USPACOM, USSOUTHCOM, 

USSOCOM, USSTRATCOM, USTRANSCOM. 

	143.	 See Figure 3, Proposed DoD Threat Finance Organizational Structure

	144.	 Joseph M. Myers, “The Silent Struggle against Terrorist Financing,”

Georgetown Journal of International Affairs 6, no. 1 (Winter 2005): 33.

	145.	 Levitt, “Terrorist Financing,” 3.

57

Anderson: Disrupting Threat Finances 

Appendix A. FTO Locations and 

the Original Pan-Islamic Caliphate

10 34

42

Sunni Islam

Shi’ite Islam

Islam, other

28 35

40

39

 5

26

25 19

11

38

20

 8 16

15

13

23

17

22

33

41

24

 7

18

 9 2

 1 3 32

36 37

 4 21

3027 6 12 14 29 31

1. Abu Nidal Organization (ANO)

2. Abu Sayyaf Group (ASG)

3. Al-Aqsa Martyrs Brigade

4. Ansar al-Islam

5. Armed Islamic Group (GIA)

6. Asbat al-Anser

7. Aum Shinrikyo

	 8.	 Basque Fatherland and Liberty (ETA)

9. Communist Party of the Phillipines

/New People’s Army

10. Continuity Irish Republican Army

11. Gama’s al-Islamiyya (Islamic Group)

	 12.	 HAMAS (Islamic Resistance Movement)

	 13.	 Harakat ul-Mujahidin (HUM)

	 14.	 Hizballah (Party of God)

15. Islamic Jihad Group

	 16.	 Islamic Movement of Uzbekistan (IMU)

17. Jaish-e-Mohammed (JEM) (Army of 

Mohammed)

18. Jemaah Islamiya organization (JI)

19. al-Jihad (Egyptian Islamic Jihad)

20. Kahane Chai (Kach)

21. Kongra-Gel (KGK, formerly PKK, 

KADEK)

	 22.	 Lashkar-eTayyiba (LT) (Army of the Righteous)

	 23.	 Lashkar i Jhangvi (LJ)

	 24.	 LiberationTigers ofTamil Eelam (LTTE)

25. Libtan Islamic Fighting Group (LIFG)

26. Moraccan Islamic Combatant Group 

(LIFG)

	 27.	 Mujahidin-e Khalq Organization (MEK)

28. National Liberation Army (ELN)

29. Palestine Liberation Front (PLF)

30. Palestinian Islamic Jihad (PIJ)

31. Popular Front for the Liberation of Palestine (PFLF)

32. PFLP-General Command (PFLP-GC)

33. Al Qaida

34. Real IRA (RIRA)

	 35.	 Revolutionary Armed Forces of Columbia (FARC)

	 36.	 Revolutionary Nuclei (formerly ELA)

	 37.	 Revolutionary Organization 17 November (17 November)

	 38.	 Revolutionary People’s Liberation Party/

Front (DHKP/C)

	 39.	 Salafist Group for Call and Combat

(GSPC)

40. Shining Path (Sendero Luminoso, SL)

	 41.	 Tarzim Qa’idat al-Jihad fi Bilad al-Rafidayn

(QJBR)

42. United Self-Defense Forces of Columbia 

(AUC) 

Figure A-1. The approximate location of the 42 FTOs, the original Pan-Islamic Caliphate, 

and the distribution of the types of Islam.1
58

JSOU Report 08-3

Note

	 1.	 Adapted and integrated by the author from:

a. Wikipedia, http://de.wikipedia.org/wiki/Bild:Weltreligionen.png 

(accessed 18 September 2006)

b.	 	U.S. Department of State, Foreign Terrorist Organizations, 11

October 2005, www.state.gov/s/ct/rls/fs/37191.htm (accessed 18

September 2006)

c.	 	Office of the Coordinator for Counterterrorism, www.state.gov/s/

ct/ (accessed 18 September 2006).
59

Anderson: Disrupting Threat Finances 

Appendix B. Alternative Financing Mechanisms

Table B-1. Examples of Alternative Financing 

Mechanisms: Sources, Movement, and Storage1

Alternative Financing Mechanisms Sources Movement Storage

Criminal Activity 

 Credit Card Fraud X

 Counterfeiting

 Extortion X

 Identity Theft X

 Immigration Benefit Fraud X

 Intellectual Property Piracy X

 Kidnapping for Ransom X

 Welfare Benefit Fraud X

Currency

 Debit or Stored Value “Smart” Cards X X

 Digital Currency X X

 Money X X

 Phone Value Cards X X

 Travelers Checks X X

Systems

 Alternative Remittance “Informal Value Transfer” X

 Hawala X

 Hundi X

 Cash Couriers X

 Charities X X

 Corporate Contributors X X

 Financial Facilitators X

 Formal Banking X X

 Individual Contributors, Witting & Unwitting X

 Internet X X X

 Auctions X X

 Casinos X X X

 Islamic Banks X X

 Not for Profit Organizations, Witting & Unwitting X X

 State Sponsors X X X

 Trade Based X X

 Unlicensed Money Services Businesses X

 Wire Transfers X

Trade in Commodities

 Contraband Cigarettes X

 Counterfeit Goods X

 Diamonds X X X

 Drug Trafficking X

 Gemstones X X X

 Gold X X X

 Weapons X
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Note

	 1.	 Adapted by the author from Terrorist Financing: U.S. Agencies Should 

Systematically Assess Terrorists’ Use of Alternative Financing Mechanisms, GAO-04-163, 2003, and the authors analysis based on government, industry, and various other research sources.
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Appendix C: U.S. Organizations and 

Efforts to Disrupt Terrorist Financing

Major USG departments and agencies, including their major bureaus, 

divisions, and offices, with descriptions of their efforts.1

1. National Security Council (NSC)

The National Security Act of 1947, as amended, established the National

Security Council to advise the President of the U.S. with respect to the 

integration of domestic, foreign, and military policies relating to national 

security. In short, the NSC advises the President on national security 

and foreign policy; serves as a forum for discussion among the President,

presidential advisers, and cabinet officials; and is the President’s mechanism for coordinating policy among government agencies on interdisciplinary issues. The NSC is responsible for the overall coordination of the 

interagency framework for combating terrorism including the financing of

terrorist operations. Under the NSC structure are a series of committees 

and working groups which address terrorism issues.

1.1. Counterterrorism Security Group (CSG). The CSG is chaired by the 

NSC which is composed of high-level representatives (at the Assistant Secretary level) from key federal agencies (DHS, FBI, CIA, DoD, 

DHS, DoJ, Treasury Department, NCTC as well as representatives of 

other departments or agencies as needed). The purpose of the CSG 

is to share information and coordinate counterterrorism action on a 

daily basis against threats to U.S. interests domestically and abroad. 

A series of interagency working groups under the CSG coordinate 

specific efforts as needed.

1.1.1. Sub-CSG on Terrorist Finance. The President established a Sub-CSG 

under the auspices of the NSC to ensure the proper coordination of 

counterterrorism financing activities and information sharing among

all agencies including the Central Intelligence Agency, Department of 

Defense, Department of Justice, Department of Homeland Security, 

National Security Council, State Department, and Treasury Department, as well as the law enforcement community. Chaired by the 

Treasury Department, Office of the General Counsel. The Sub-CSG

on Terrorist Financing was formalized at the end of 2005. The SubCSG coordinates the development and implementation of policies to 

combat terrorist financing and provides analysis on these issues. The

Sub-CSG generally meets at least once a month to coordinate the 

USG’s campaign against terrorist financing. The meetings generally

focus on ensuring that all relevant components of the federal government are acting in a coordinated and effective manner to combat 

terrorist financing.
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1.2. Directorate for Combating Terrorism. The Directorate for Combating 

Terrorism, which is part of NSC, is headed by the National Coordinator 

at the Deputy National Security Advisor level. The National Coordinator 

will work within the National Security Council, report to the President 

through the Assistant to the President for National Security Affairs, 

and produce for him an annual Security Preparedness Report. The 

National Coordinator will also provide advice regarding budgets for 

counterterror programs and lead in the development of guidelines 

that might be needed for crisis management. 

2. Treasury Department 

Since PDD 39 in June 1995, the Secretary of the Treasury has been

responsible for identifying and blocking terrorist financing. These efforts

were stepped up after the terrorist attacks of 9/11, when the President

signed Executive Order 13224.Treasury also has the responsibility to

protect the integrity of the financial system by administering the Bank

Secrecy Act (BSA), as enhanced by Title III of the USA Patriot Act. 

2.1. Office of Terrorism and Financial Intelligence (TFI), Treasury Department. TFI marshals the department’s intelligence and enforcement 

functions with the twin aims of safeguarding the financial system

against illicit use and combating rogue nations, terrorist facilitators, 

money launderers, drug kingpins, and other national security threats. 

TFI also brings together Treasury’s intelligence, regulatory, law enforcement, sanctions, and policy components. TFI allows Treasury to: 

a.	 Better develop and target their intelligence analysis and financial

data to detect how terrorists are exploiting financial systems and to

design methods to stop them and their financial infrastructure.

b. Better coordinate aggressive law, sanctions and regulatory 

enforcement programs, while working with other components of 

the government and the private sector. 

c.	 Continue to develop a strong international coalition required to

combat terrorist financing, in part by facilitating the development

and exchange of financial information that supports their requests

for collaborative action. 

d. Ensure accountability, thus helping to achieve better results.

2.1.1. Office of Terrorist Financing, TFI, Treasury Department. TFI develops, organizes, and implements USG strategies to combat terrorist 

financing and financial crime, both internationally and domestically.

Is the policy and outreach apparatus for the Treasury Department on 

the issues of terrorist financing, money laundering, financial crime,

and sanctions. Provides increased coordination with other elements 

of the USG, including law enforcement and regulatory agencies. 
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Domestically, the office is charged with continuing to develop and

implement the USG’s national money laundering strategy as well as 

other policies and programs. Serves as a primary outreach body to 

the private sector and other stakeholders. 

2.1.1.1. The Office of Terrorist Finance and Financial Crimes (TFFC), 

Office of Terrorist Financing, TFI, Treasury Department. TFFC, formerly the Executive Office of Terrorist Finance and Financial Crime

(EOTF/FC), was created in March 2003 and assumed the main

functions of the former Office of Enforcement. TFFC became part

of TFI under the Office of Terrorist Financing in August 2004. The

office is charged with coordinating Treasury Department’s efforts to

combat terrorist financing both in the U.S. and abroad. Participates

in U.S. interagency assessments of countries’ capabilities to combat 

terrorist financing and money laundering. Provides technical advice

and practical guidance on how international standards for combating money laundering and terrorist financing should be adopted and

implemented. Develops U.S. strategies and policies to deter terrorist 

financing, domestically and internationally. Develops and implements

the National Money Laundering Strategy as well as other policies and 

programs to prevent financial crimes.

2.1.2. Office of Intelligence and Analysis (OIA), TFI, Treasury Department. 

The overall purpose of OIA is to ensure that the Treasury Department 

properly analyzes relevant intelligence—adding their own unique

expertise and capabilities—to create actionable financial intelligence

that Treasury and the rest of the USG can use effectively. Priorities 

include identifying and attacking the financial infrastructure of terrorist groups; assisting in efforts to identify and address vulnerabilities

that may be exploited by terrorists and criminals in domestic and 

international financial systems; and promoting stronger relationships

with our partners in the U.S. and around the world.

2.1.3. Office of Foreign Asset Control (OFAC), TFI, Treasury Department.

OFAC acts under Presidential wartime and national emergency powers, 

as well as under authority granted by specific legislation to administer

and enforce economic and trade sanctions based on U.S. foreign policy 

and national security goals against targeted foreign countries, Foreign 

Terrorist Organizations (FTOs), terrorists, international narcotics traffickers, and those engaged in activities related to the proliferation of

weapons of mass destruction (WMD). In administering and enforcing 

its economic sanctions programs, OFAC focuses on: 

a. Assisting U.S. persons in complying with the sanctions prohibitions through its compliance and licensing efforts

b. Penalizing U.S. persons violating the prohibitions
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c. Working with other USG agencies, including law enforcement

d. Coordinating and working with other nations to implement similar 

strategies. 

	 Since 1995, OFAC has administered three sanctions programs targeting international terrorists and terrorist organizations. OFAC also 

administers five sanctions programs relating to terrorism-supporting

governments and regimes.

2.1.4. Financial Crimes Enforcement Network (FinCEN), TFI, Treasury 

Department. FinCEN was created in 1990 to maximize information

sharing among law enforcement agencies and its other partners in 

the regulatory and financial communities. FinCEN works to safeguard

the financial system from the abuse of federal crime, including terrorist financing, money laundering, and other illicit activities. FinCEN

achieves this mission through its fulfillment of four essential roles:

a. Administering the BSA

b. Supporting law enforcement, intelligence, and regulatory agencies 

through sharing and analysis of financial intelligence

c.	 Building global cooperation with counterpart financial intelligence

units

d. Networking people, ideas and information. 

	 FinCEN provides financial intelligence training and technical assistance to a broad range of government officials, financial regulators, law

enforcement officers, and others abroad with a focus on the creation

and improvement of financial intelligence units. FinCEN partners with

other governments and international entities to coordinate training 

and participates in the assessments of foreign governments’ financial

intelligence capabilities. 

2.1.5. The Treasury Executive Office for Asset Forfeiture and Treasury 

Forfeiture Fund (TEOAF), TFI, Treasury Department. TEOAF administers the Treasury Forfeiture Fund (TFF). The TFF was established 

in 1992 as the successor to what was then the Customs Forfeiture

Fund. It is the receipt account for the deposit of nontax forfeitures 

made by the following Member Agencies: Internal Revenue Service 

Criminal Investigation Division (IRS-CI), U.S. Treasury Department;

U.S. Immigration and Customs Enforcement (U.S. ICE), Department 

of Homeland Security (DHS); U.S. Customs and Border Protection

(U.S. CBP), DHS; U.S. Secret Service (USSS), DHS; and U.S. Coast

Guard, DHS. 

2.2. Internal Revenue Service (IRS), Treasury Department. Assists with 

terrorist finance criminal cases within the U.S. with an emphasis on

charitable organizations. 
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2.2.1. IRS-Criminal Investigation (IRS-CI), IRS, Treasury Department. The 

IRS-CI Division specializes in analyzing complex financial information and determining whether that information is in violation of tax 

laws, money laundering laws, and the BSA. In addition, IRS-CI is 

heavily involved with the Joint Terrorism Task Force (JTTF), Operation Green Quest and similar partnerships focused on disrupting 

and dismantling terrorist financing. In particular, IRS-CI is focused

on preventing the abuse of charities by those who support terrorism. 

The IRS-CI maintains a direct reporting relationship to the Office of

Terrorist Financing. 

2.3. Office of Technical Assistance / Enforcement Policy and Administration Program, Treasury Department. Provides a range of training and 

technical assistance including intermittent and long-term resident 

advisors to senior-level representatives in various ministries and central banks on a range of areas including financial reforms related to

money laundering and terrorist financing. Conducts and participates

in assessments of foreign government anti-money-laundering regimes 

for the purpose of developing technical assistance plans. 

2.4. Office of International Affairs, Treasury Department. The Office of

International Affairs works bilaterally and multilaterally to build and 

maintain the international coalition against terrorist finances along

with other federal agencies, including the DoS, DoJ, FBI, and the 

intelligence community. 

2.4.1. Liaison Officer (LNO), Geographic Combatant Commanders (GCCs), 

Department of Defense. Treasury LNOs: a) identify and propose joint 

GCC Treasury initiatives; b) provide “area of responsibility” (AOR) perspective to OFAC and OIA in response to taskings for the development 

of administrative records for designation of target support networks;

c) communicate theater strategy, plans, initiatives, and analytical 

findings to Treasury; and d) provide technical and policy expertise

to GCCs, staff, and components on Treasury’s authorities, programs 

and initiatives that relate to GCC objectives within its AOR. 

2.4.2. Financial Attachés, Office of International Affairs, Treasury Department. Develop extensive contacts with foreign finance ministries,

foreign regulatory authorities, central banks and financial market

participants. Financial Attachés explain new U.S. policies to their

foreign counterparts. They also collect, report, interpret, and forecast macroeconomic and financial developments and policies in their

assigned countries. 
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3. Department of State (DoS)

The DoS is the lead agency for USG efforts to combat terrorism overseas. 

Within the department, multiple bureaus and offices manage various

programs and activities to combat terrorism abroad. DoS also works with 

other USG agencies, foreign government agencies, and international organizations in carrying out its counterterrorism programs and activities. As 

the lead foreign affairs agency, the DoS serves as the statutorily-appointed 

coordinator and overall clearinghouse for the wide span of counterterrorism 

activities conducted overseas by the USG. In addition, the Departments 

of State, Treasury, and Justice work with other countries on a bilateral 

and multilateral basis to identify and freeze terrorist assets. Offices from

other IA’s lend their expertise on a bilateral and multilateral basis to 

provide technical assistance and training to countries to help them meet 

international standards to combat terrorist financing.

3.1. The Office of the Coordinator for Counterterrorism (S/CT), DoS. In 

conjunction with International Narcotics and Law Enforcement Affairs, 

S/CT has the lead in coordinating capacity building to combat terrorist 

financing in other countries. With the concurrence of the Departments

of Justice and Treasury, designates foreign terrorist organizations, 

individuals, and groups for a variety of purposes, including blocking 

terrorism-related financing. S/CT also coordinates and funds U.S.

training and technical assistance provided by other U.S. agencies to 

develop or enhance the capacity of a selected countries; manages or

provides funding for other counterterrorism financing programs for

DoS, other IA, ILEAs, international entities, and regional bodies; leads

the U.S. IA assessments of foreign government vulnerabilities; coordinates U.S. counterterrorism policy and efforts with foreign governments 

to deter terrorist financing; provides funds and policy guidance to the

Office of Antiterrorism Assistance Program and determines which

countries are authorized to participate in the program; and publishes

an unclassified report called Patterns of Global Terrorism.

3.1.1. Counterterrorism Finance Unit, S/CT, DoS. The unit implements 

significant parts of the U.S. strategy to cut off financial support to

terrorists. The unit coordinates the delivery of technical assistance 

and training to governments around the world that seek to improve 

their ability to investigate, identify, and interdict the flow of money

to terrorist groups. The unit, along with the Bureau of International 

Narcotics and Law Enforcement, funds and coordinates IA training and 

technical assistance in the five basic components of a comprehensive

counterterrorist financing/anti-money-laundering regime: a) legal

frameworks, b) financial regulatory systems, c) financial intelligence

units, d) law enforcement, and e) judicial/prosecutorial development. 

The unit also works with the Office of Terrorist Finance and Economic
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Sanctions Policy, DoS to foster a coordinated USG response to terrorist 

financing, the White House, OFAC, the Financial Action Task Force

(FATF), and other international organizations and foreign governments 

to disrupt terrorist finances.

3.2. Bureau of International Narcotics and Law Enforcement Affairs (INL), 

DoS. INL has primary responsibility within DoS for international anticrime issues, including programs to combat money laundering and 

other financial crimes. In conjunction with S/CT it has the lead in

coordinating capacity building to combat terrorist financing in other

countries. INL provides funding to the DoJ and Treasury, to assist 

in the training and assistance of foreign governments to strengthen 

their financial and regulatory regimes to reduce terrorist financing.

These programs are aimed at providing front-line states with technical 

assistance in drafting antiterrorist financing legislation, and training

for bank regulators, investigators, and prosecutors to identify and 

combat financial crime, particularly terrorist financing.

3.3. Office of Antiterrorism Assistance Program (ATA), Bureau of Diplomatic Security (DS), DoS. ATA strategy involves applying all aspects of 

national power in conjunction with U.S. partners and allies to target 

terrorists’ leadership and sanctuaries and to address the conditions 

terrorists seek to exploit. Since 1983, ATA has provided a key tool for

providing partner countries the training, equipment, and technology

they need to improve their ability to contribute effectively to these 

aims by deterring or capturing and prosecuting terrorists and their 

supporters. 

3.3.1. Diplomatic Security Antiterrorism Assistance Programs, ATA, DS, 

DoS. The program is run by the ATA, DS and provides law enforcement training for foreign counterparts and, through International 

Law Enforcement Agencies (ILEAs), to develops the skills necessary 

to combat terrorism, to include: a) protecting national borders, b) 

protecting critical infrastructure, c) protecting the national leadership, 

d) responding to and resolving terrorist incidents, e) investigating 

and prosecuting those responsible for terrorist acts, f) responding 

to WMD attacks, g) managing kidnapping for ransom crimes, and 

h) responding to terrorist incidents resulting in mass casualties or 

fatalities. The program provides a wide range of courses to strengthen 

the capacities of recipient countries. The training includes traditional 

courses such as hostage negotiations, bomb detection, and airport 

security. In recent years however, ATA has developed new courses 

for countering terrorism financing and defeating cyber-terrorism. It

also has provided a series of seven seminars to help other countries 

strengthen their counterterrorism legislation. 
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3.4. The Overseas Security Advisory Council (OSAC), DoS. OSAC is a 

Federal Advisory Committee with a USG Charter to promote security 

cooperation between American business and private sector interests 

worldwide and the DoS. OSAC helps over 2,800 businesses, universities, religious groups, and nongovernmental organizations cope 

with security threats by sharing information on crime and terrorism 

and by providing insight into political, economic, social, and cultural 

climates around the globe. The objectives of the council as outlined 

in the charter are: 

a. Establish continuing liaison and to provide for operational security cooperation between DoS security functions and the private 

sector.

b. Provide for regular and timely interchange of information between 

the private sector and the DoS concerning developments in the 

overseas security environment.

c. Recommend methods and provide material for coordinating security planning and implementation of security programs

d. Recommend methods to protect the competitiveness of American 

businesses operating worldwide. 

3.5. Bureau of Economic Energy, and Business Affairs (EEB), DoS.

Maintains the leadership role in the IA effort to combat terrorist 

financing. Formulates and carries out U.S. foreign economic policy,

integrating U.S. economic interests with foreign policy goals so 

that U.S. firms and investors can compete on an equal basis with

their counterparts overseas. In addition, EEB coordinates terrorist financing policy and coalition building on terrorist financing,

including related to United Nations sanctions under Resolution 

1267, and chairs the Coalition Building meetings, which supports

U.S Government efforts to develop strategies and activities to obtain 

international cooperation. 

3.5.1. The Office of Terrorism Finance and Economic Sanctions Policy 

(TFS), EEB, DoS. Is responsible for leading the effort to build international coalition support to block terrorist assets. Coordinates policy 

implementation at the working level, largely through the network of 

Terrorism Finance Coordinating Officers located at embassies worldwide as directed by the Energy, Sanctions, and Commodities (ESC). 

In conjunction with other bureaus and agencies, coordinates efforts 

to build international support for efforts against terrorist finance.

In addition, TFS works through U.S. missions around the world 

to a) encourage countries to take actions to freeze terrorist assets when 

found, b) develop new initiatives to strengthen international cooperation 

against terrorist finance, and c) support efforts to provide technical
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assistance to foreign governments working against terrorist finance.

TFS coordinates efforts to a) create, modify, or terminate unilateral 

sanctions regimes as appropriate to the changing international situation, such as Iraq and Libya; b) develop strategies for implementation of specific aspects of sanctions regimes; and c) provide foreign

policy guidance on specific commercial business, export, import,

and general licensing issues to the Treasury Department’s Office of

Foreign Assets Control and the Commerce Department’s Bureau of 

Industry and Security. 

3.6. Embassies, DoS. Embassies and consulates play a critical role in the 

fight against terrorism by serving as direct conduits to the governments

of other nations. Embassies facilitate the USG’s efforts to disrupt terrorist networks and to apprehend terrorist individuals. The ambassador, his or her deputy, and other members of the country team, 

including representatives from other agencies, all play instrumental 

roles in developing and maintaining good working relations with the 

host country and pursuing U.S. counterterrorism objectives. 

3.6.1. Terrorism Finance Coordinating Officer, Embassy, DoS. Facilitates 

the efforts to disrupt terrorist networks and to apprehend terrorist. 

Each embassy has identified a Terrorism Finance Coordination Officer to lead the effort of working with the host governments to detect, 

disrupt, and deter terrorist financing.

3.7. Bureau of International Organization Affairs (IO), DoS. Develops and 

implements U.S. counterterrorism policy in the United Nations and 

other international organizations, serving as DoS primary liaison. 

3.8. Bureau of Intelligence and Research (INR), DoS. The INR, drawing 

on all-source intelligence, provides value-added independent analysis 

of events to DoS policymakers, ensures that intelligence activities 

support foreign policy and national security purposes, and serves as 

the focal point in the DoS for ensuring policy review of sensitive counterintelligence and law enforcement activities. INR’s primary mission 

is to harness intelligence to serve U.S. diplomacy. The bureau also 

analyzes geographical and international boundary issues.

4. Department of Justice (DoJ)

Has the lead responsibility for the prosecution and investigation of terrorism and terrorist financing offenses under Title 18 USC, section 2332b(f).

DoJ is the lead agency for law enforcement and criminal matters related 

to terrorism overseas and domestically. Within the department, multiple 

bureaus and offices manage various programs and activities to combat

terrorism abroad. The DoJ also works with other USG agencies, foreign 
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government law enforcement organizations and agencies, and multinational 

organizations in carrying out these programs and activities.

4.1. Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF), DoJ.

Participates in investigations of terrorist financing cases involving

alcohol, tobacco, firearms, and explosives.

4.2. Drug Enforcement Administration (DEA), DoJ. Participates in investigations of terrorist financing cases involving narcotics and other

illicit drugs.

4.3. Asset Forfeiture and Money Laundering Section (AFMLS), DoJ. Assists 

in the drafting of money laundering, terrorist financing, and asset

forfeiture legislation compliant with international standards for international and regional bodies and foreign governments. Provides legal 

training and technical assistance to foreign prosecutors and judges, in 

conjunction with Justice’s Office of Overseas Prosecutorial Development, Training and Assistance. Sponsors conferences and seminars 

on transnational financial crimes such as forfeiting the proceeds of

corruption, human trafficking, counterfeiting, and terrorism. Participates in U.S. interagency (IA) assessments of countries’ capacity to 

block, seize, and forfeit terrorist and other criminal assets. AFMLS 

designs and, with its staff and the assistance of the U.S. Attorneys 

around the nation, delivers both training and technical assistance, 

particularly with respect to the threat of money laundering and asset 

forfeiture issues. 

4.4. Criminal Division, Deputy Assistant Attorney General, DoJ. Is responsible for the design, implementation, and support of law enforcement 

efforts to combat international terrorism, including legislative initiatives 

and policies. This includes investigating and prosecuting suspected 

terrorists for acts of terrorism against U.S. interests worldwide. Develops, coordinates, and prosecutes terrorist financing cases; participates

in financial analysis and develops relevant financial tools; promotes

international efforts; and delivers training to other nations.

4.5. National Security Division (NSD), DoJ. The core mission of NSD is 

to coordinate DoS efforts to combat terrorism and protect national 

security. NSD is responsible for assisting the Attorney General and 

other senior Department and Executive Branch officials in ensuring

that the national security-related activities of the U.S. are consistent 

with relevant law; overseeing terrorism investigations and prosecutions; and handling counterespionage cases and matters.

4.5.1. Counterterrorism Section (CTS), NSD, Deputy Assistant Attorney 

General, DoJ. Coordinates with headquarter offices of USG agencies

including: Treasury Department, DoS, Intelligence agencies, DHS, 

and the FBI to facilitate prevention of terrorist activity through daily 
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detection and analysis to provide information and support to the 

field. CTS provides:

a. Investigative and prosecutorial training and technical assistance 

to foreign investigators, prosecutors, and judges in conjunction 

with the Office of Overseas Prosecutorial Development, Training,

and Assistance and other DoJ components.

b. Designs and, with its staff and the assistance of the U.S. Attorneys around the nation, delivers both training and technical 

assistance. 

c.	 Investigates and prosecutes terrorist financing matters, including material support cases, through the Terrorist Financing Task 

Force. 

4.5.1.1. Terrorist Financing Unit (TFU), CTS, National Security Division, 

Deputy Assistant Attorney General, DoJ. The TFU is made up of whitecollar prosecutors drawn from various Main Justice litigating components and U.S. Attorneys’ Offices. Coordinates the terrorist financing

enforcement efforts within Justice’s National Security Division. The 

task force works with prosecutors around the country as well as with 

the FBI’s Foreign Terrorist Tracking Task Force and Terrorist Financing Operation Section to disrupt groups and individuals representing 

terrorist threats. TFU works closely with the FBI’s Terrorist Financing 

Operations Section (TFOS), which draws resources from numerous, 

federal law enforcement agencies and is devoted to the collection and 

analysis of information concerning terrorist financing.

4.6. Federal Bureau of Investigation (FBI), DoJ. Leads all terrorist financing investigations and operations and has the primary responsibility 

for collecting foreign intelligence and counterintelligence information 

within the U.S. Provides basic and advanced law enforcement training 

to foreign governments on a bilateral and regional basis and through 

ILEAs and the FBI Academy in Quantico, Virginia. Developed a twoweek terrorist financing course that was delivered and accepted as

the USG’s model. Participates in U.S. IA assessments of countries’ 

law enforcement and counterterrorism capabilities. 

4.6.1. National Security Branch (NSB), FBI, DoJ. The NSB structure 

took effect on September 12, 2005, in response to a directive from

the President to the Attorney General. The NSB consists of the FBI’s 

Counterterrorism Division (CTD), the Counterintelligence Division 

(CD), the Directorate of Intelligence (DI), and the new Weapons of 

Mass Destruction (WMD) Directorate. 

4.6.2. Counterterrorism Division (CTD), NSB, FBI, DoJ. Is the principal 

investigative agency of the federal government, it serves as lead agency 

for international counterterrorism investigations. The mission of the 
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CTD is to identify and disrupt potential terrorist plots by individuals 

or terror cells; to freeze terrorist finances; to share information with

law enforcement and intelligence partners worldwide; and to provide

strategic and operational threat analysis to the wider intelligence 

community. The FBI has extraterritorial jurisdiction to expand its 

investigative authority outside U.S. borders. Its investigations include 

incidents involving bombings, hostage taking, homicides of U.S. citizens 

overseas, sabotage, and extortion by threatening the use of WMD. 

4.6.2.1. Terrorist Financing Operations Section (TFOS), Counterterrorism 

Division, NSB, FBI, DoJ. TFOS is both an operational and coordinating 

entity with proactive and reactive responsibilities. As a coordinating 

entity, TFOS is responsible for ensuring that a unified approach is

pursued in investigating terrorist financing networks by a) coordinating the financial aspects of FBI Field Office and Legal terrorism

investigations; b) establishing overall initiatives, policy and guidance

on terrorist financing matters; c) participating in the Sub-CSG on

Terrorist Financing; d) coordinating national liaison with the financial

services sector; e) cooperating in and coordinating criminal terrorist

financing investigations with the DoJ; and f) providing support and

training to Field Offices, to include the designated Terrorism Financing

Coordinator (TFC). According to the FBI, TFOS brings financial expertise to bear in identifying terrorist financing methods and movement

of money into and out of the U.S. in support of terrorist activity. To 

help prevent terrorist attacks, TFOS developed a centralized terrorist 

financial database to identify potential terrorist-related activity in the

U.S. and abroad. 

4.6.2.2. National Joint Terrorism Task Force (NJTTF), Counterterrorism 

Division, NSB, FBI, DoJ. In July 2002, the FBI formally created the

NJTTF to act as a liaison and conduit for information on threats and 

leads from FBI Headquarters to the local JTTFs and to 40 participating

agencies. NJTTF serves as the national coordinating mechanism for 

sharing information on suspected terrorists, including those of foreign 

origin. Also, it complements the local Joint Terrorism Task Forces by 

improving collaboration and information sharing with other federal, 

state, tribal, and local agencies. The task force operates out of the 

FBI’s Strategic Information Operation Center in Washington, D.C. 

4.6.3. Foreign Terrorist Tracking Task Force (FTTTF), FBI, DoJ. The FTTTF 

was established to ensure that federal agencies, including the FBI, INS, 

Customs Service and others, coordinate their efforts to bar from the 

U.S. all aliens who meet any of the following criteria: a) aliens who are 

representatives, members, or supporters of terrorist organizations; b)

aliens who are suspected of engaging in terrorist activity; or c) aliens
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who provide material support to terrorist activity. Federal agencies 

coordinate programs to accomplish the following: a) deny entry into 

the U.S. of aliens associated with, suspected of being engaged in, or 

supporting terrorist activity and b) locate, detain, prosecute, or deport 

any such aliens already present in the U.S. 

4.6.4. Joint Terrorism Task Forces (JTTFs), Field Offices, FBI, DoJ. JTTFs 

were established in the 1980s and grew significantly after 9/11.

The JTTFs serve three main purposes: a) prevent terrorist attacks;

b) respond to and investigate terrorist incidents or terrorist-related 

activity, including terrorist financing; and c) identify and investigate

domestic and foreign terrorist groups and individuals targeting or 

operating within the U.S. JTTFs team up police officers, FBI agents,

and officials from over 20 federal law enforcement agencies to investigate terrorism cases. The FBI has increased multi-agency JTTFs 

from 35 to 101 since 2001 and has increased the number of agents

and law enforcement personnel serving on JTTFs from under 1,000

to nearly 4,000. In 2002, the FBI created a national JTTF in Washington, D.C., to collect terrorism information and intelligence and 

funnel it to the field JTTFs, various terrorism units within the FBI,

and partner agencies. Serves as the operational arm of the Antiterrorism Task Forces (ATTFs). 

4.7. Anti-Terrorism Advisory Council, U.S. Attorney District Offices, DoJ. 

Integrates and coordinates the antiterrorism activities in each of the 

judicial districts within the U.S. The task forces are comprised of federal 

prosecutors from the U.S. Attorneys Office, members of federal law

enforcement agencies, and the primary state and local enforcement 

officials in each district. They serve as part of a national network

that coordinates closely with the JTTF in the collection, analysis, 

and dissemination of information. The ATTF also developed the U.S. 

investigative and prosecution strategy throughout the country. 

4.8. Office of Overseas Prosecutorial Development, Training and Assistance 

(OPDAT), DoJ. Provides targeted legal and prosecutorial training and 

technical assistance for criminal justice sector counterparts abroad 

and through ILEAs in drafting anti-money-laundering and counteringterrorism-financing statutes. Provides Resident Legal Advisors to focus

on developing counterterrorism legislation that criminalizes terrorist 

financing and achieves other objectives. Conducts regional conferences

on terrorist financing, including a focus on charitable organizations.

Participates in U.S. interagency assessments to determine countries’ 

criminal justice system capabilities. Since 2002, the Department has

provided assistance in countering-terrorism-financing and anti-moneylaundering legislation drafts for 138 countries.
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4.9. U.S. National Central Bureau of the International Criminal Police 

Organization (INTERPOL), DoJ. Represents the U.S. as a member of 

INTERPOL. It facilitates international law enforcement cooperation 

by transmitting law enforcement-related information between the 

National Central Bureaus of INTERPOL, member countries, and U.S. 

law enforcement agencies. It also coordinates information relevant 

to international investigations and identifies patterns and trends in

criminal activities. 

5. Department of Homeland Security (DHS)

The DHS is primarily focused on combating terrorism within the U.S. 

Within the department, multiple bureaus, offices, and agencies manage

various programs and activities to combat terrorism primarily through 

the Bureau of Immigration and Customs Enforcement and the U.S. Secret 

Service. However, for selected overseas activities, it supports the DoS. DHS 

also works with other USG agencies, foreign government organizations 

and agencies, and international organizations in carrying out counterterrorism programs and activities. 

5.1. Bureau of Immigration and Customs Enforcement (ICE), DHS. ICE 

has a mission to target current terrorist funding sources and identify 

possible future sources. The bureau has a multi-agency entity called 

Operation Green Quest to bring together federal agency expertise 

across departments and bureaus to identify systems, individuals, and 

organizations that serve as sources of terrorist funding. ICE provides 

law and border enforcement training and technical assistance to 

foreign governments in conjunction with other U.S. law enforcement 

agencies (LEAs) and the ILEAs. ICE also participates in assessments 

of foreign countries in the law and border enforcement arena. ICE 

has a long history of collecting, analyzing and utilizing BSA data in 

criminal investigations. ICE uses Currency Transaction Report (CTR) 

data as a valuable analytic tool for detecting illegal activity, developing 

leads, and furthering investigations. 

5.1.1. Trade Transparency Unit (TTU), ICE, DHS. The TTU and Money 

Laundering Coordination Center (MLCC) provide the analytical infrastructure to support financial and trade investigations. The TTU

develops investigative leads from analysis through Data Analysis & 

Research for Trade Transparency System (DARTTS) and facilitates 

the dissemination of investigative referrals to field entities. The TTU

provides the capability to identify and analyze complex trade-based 

money laundering systems, such as the estimated 5 billion U.S. Dollars (USDs) per year drug money laundering scheme known as the 

Black Market Peso Exchange. 
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5.1.2. Financial Operations Unit (Financial Operations) ICE, DHS. Financial Operations provides programmatic support and line authority to 

ICE Financial field components targeting money-laundering activities.

Financial Operations provides ICE’s input for the development and 

utilization of the National Money Laundering Strategy as a foundation 

to target transnational money laundering activity. Financial Operations 

also closely coordinates with other law enforcement entities such as 

FinCEN to assist in processing field requests, including BSA data,

USA Patriot Act 314(a) requests for bank account information, and

registration data pertaining to money service businesses (MSBs). 

5.2. U.S. Secret Service, DHS. The U.S. Secret Service is responsible for 

enforcement of laws relating to U.S. securities and financial crimes.

Its efforts to combat terrorist financing rest primarily on the investigation of counterfeiting of currency and securities. 

5.3. Bureau of Customs and Border Protection, DHS. Detects movement 

of bulk cash across U.S. borders and maintains data about movement 

of commodities into and out of the U.S. 

6. Department of Defense (DoD)

The Secretary of Defense is responsible for supporting:

a. The lead federal agency, the DoS, in responding to a terrorist 

incident overseas

b. The DoJ (through the FBI) for crisis management of a domestic 

terrorist incident

c. The Federal Emergency Management Agency (FEMA) for consequence management of a domestic terrorist incident.

The DoD has work underway to support efforts in the area of threat finance.

While terrorist financing focuses on organizations, cells, and individuals

directly linked to terrorism, threat financing is a broader-based concept

and includes WMD funding, terrorist financing, narcotics-trafficking,

organized crime, and human trafficking. The DoD has stated that following the money (in all forms) is a key element to mapping the network 

and understanding relationships between nodes and a key enabler for 

achieving DoD objectives. The DoD views the Treasury Department as 

the lead agency for terrorist finances.

6.1. U.S. Special Operations Command (USSOCOM), DoD. USSOCOM 

has been designated the executive agent for the DoD Global War on 

Terrorism Campaign. USSOCOM synchronizes the counterterrorism 

plans of the five geographic military commands as components of a

global campaign. 
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6.1.1. USSOCOM Threat Finance Exploitation Branch, USSOCOM, DoD.

Was established to coordinate and integrate military operations with 

IA activities to reduce threats to the U.S. and U.S. interests abroad 

by synchronizing joint DoD, IA, and coalition intelligence collection 

and analysis activities that lead to detection, identification, targeting,

disruption, or destruction of terrorist financial support systems and

networks. They serve as the DoD focal point for terrorist exploitation 

among the USG. 

6.2. Geographic Combatant Commands (GCC) – Threat Financing 

Exploitation Units (TFEUs), GCC, DoD. Currently, USCENTCOM, 

USEUCOM, USNORTHCOM, USPACOM, and USSOUTHCOM are the 

operating TFEUs which work with DoD and non-DoD intelligence, 

law enforcement and regulatory agencies to: a) detect financial 

support networks; b) collect, process and analyze information; and

c) target, disrupt, or destroy financial systems and networks which

support activities that threaten U.S. interests. Not all the GCCs call 

their TF Exploitation entity a TFEU. For instance USSOCOM calls 

its entity a TF Exploitation Branch, but each GCC has an entity that 

analyzes and exploits financial intelligence. Each of the TF Exploitation entities has a somewhat different focus that is based on their 

region. For example, USSOUTHCOM is more focused on the narcotics trafficking portion of TF, whereas USCENTCOM is focused more

on the terrorists and insurgents. Each of the TF Exploitation entities 

are resourced, manned, and utilized to varying degrees based on the 

emphasis that is placed on their importance by the GCC, and not all 

TF Exploitation entities operate at the same level of proficiency.

6.3. Defense Intelligence Agency (DIA), DoD. DIA is a DoD combat support agency and an important member of the United States Intelligence 

Community. DIA is a major producer and manager of foreign military 

intelligence and provides military intelligence to war fighters, defense

policymakers and force planners, in the DoD and the Intelligence 

Community, in support of U.S. military planning and operations and 

weapon systems acquisition.

6.3.1. Joint Intelligence Task Force-Combating Terrorism (JITF-CT), DIA, 

DoD. Provides enhanced analysis and production to support worldwide efforts in counterterrorism. JITF-CT analysts produced daily 

assessments of possible terrorist threats to DoD personnel, facilities, 

and interests. In addition, the Defense Intelligence Analysis Program 

(DIAP) mandated the responsibility of threat finance analysis be given

to JITF-CT. 
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7. Office of the Director of National Intelligence Agency (ODNI)

The ODNI was established through the Intelligence Reform and Terrorism 

Prevention Act of 2004. The Director of National Intelligence (DNI), who

must be confirmed by the U.S. Senate, does not serve as the head of any

individual element within the U.S. intelligence community, but establishes 

objectives and priorities for the intelligence community and manages and 

directs tasking of collection, analysis, production, and dissemination of 

national intelligence.

7.1. Central Intelligence Agency (CIA), ODNI. The Director of the CIA 

serves as the head of the CIA and reports to the DNI. To accomplish 

its mission, the CIA engages in research, development, and deployment of high-leverage technology for intelligence purposes. As a separate agency, the CIA serves as an independent source of analysis on 

topics of concern and works closely with the other organizations in 

the IC to ensure that the intelligence consumer, whether Washington 

policy maker or battlefield commander, receives the best intelligence

possible. 

8. Interagency

Interagency organizations are listed, followed by their participants and 

description of their effort. 

8.1. National Counterterrorism Center (NCTC), ODNI. CIA, DoJ, FBI, DoD, 

DHS, DoS, Treasury Department, Department of Agriculture, Department of Energy, Department of Health and Human Services, National 

Geospatial-Intelligence Agency, Nuclear Regulatory Commission and 

U.S. Capitol Police.

The NCTC, formally The Terrorist Threat Integration Center (TTIC), is 

staffed by personnel from across the USG and serves as the primary 

organization in the USG for integrating and analyzing all intelligence 

pertaining to terrorism and counterterrorism and conducting strategic 

operational planning by integrating all instruments of national power. 

In December 2004, Congress codified the NCTC in the Intelligence

Reform and Terrorism Prevention Act (IRTPA) and placed the NCTC in 

the Office of the ODNI. The NCTC is a multi-agency organization dedicated to eliminating the terrorist threat to U.S. interests at home and 

abroad. NCTC is charged with ensuring that agencies, as appropriate, 

have access to and receive all-source intelligence necessary to execute 

their counterterrorism plans and perform independent, alternative 

analysis. The NCTC was designed to serve as a central knowledge 

bank for information about known and suspected terrorists and to 

coordinate and monitor counterterrorism plans and activities of all 
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the government agencies. The NCTC is also responsible for preparing 

the daily terrorism threat report for the President. 

8.2. Terrorist Finance Working Group (TFWG). DoS, Treasury Department, DoJ, DHS. Other participants include NSC, CIA, Federal Deposit 

Insurance Corporation and the Federal Reserve. 

TFWG is co-chaired by S/CT and INL. It meets biweekly to receive 

intelligence briefings, schedule assessment trips, review assessment

reports, and discuss the development and implementation of technical assistance and training programs. TFWG leads the Program 

Development Process, which, with input from the intelligence and 

law enforcement communities, DoS, Treasury, and DoJ: 

a.	 Identifies and prioritize countries needing the most assistance to

deal with terrorist financing.

b.	 Evaluates priority countries’ counterterrorism finance and antimoney-laundering regimes.

c. Prepares a formal assessment report on vulnerabilities to terrorist 

financing and makes recommendations for training and technical

assistance to address these weaknesses.

d.	 Develops a counterterrorism financing training implementation

plan based on FSAT recommendations.

e.	 Provides sequenced training and technical assistance to priority

countries in-country, regionally, or in the U.S.

f.	 Encourages burden sharing with U.S. allies; with international

financial institutions, such as the International Monetary Fund

(IMF), World Bank, and regional development banks; and through

international organizations such as the United Nations, the United 

Nations Counterterrorism Committee, FATF on Money Laundering, 

and the Group of Eight (G-8) to capitalize on and maximize international efforts to strengthen counterterrorism finance efforts.

8.2.2. Financial Systems Assessment Team (FSAT). DoS, DoJ, and Treasury 

Department. 

	 DoS has the lead for FSAT teams. FSAT teams of 6–8 members include

technical experts from State, Treasury, Justice, and other regulatory 

and law enforcement agencies and evaluate priority countries’ counterterrorism finance and anti-money-laundering regimes. The FSAT

onsite visits take about one week and include in-depth meetings 

with host government financial regulatory agencies, the judiciary,

law enforcement agencies, the private financial services sector, and

nongovernmental organizations. 

8.3. Terrorism Financial Review Group (TFRG). CIA, DoJ, FBI, DoD, DHS, 

DoS, Treasury Department. 
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The mission of the TFRG has evolved into a broad effort to identify, 

investigate, prosecute, disrupt, and dismantle all terrorist-related 

financial and fundraising activities. The TFRG has taken a leadership

role in coordinating the comprehensive financial investigative effort.

To accomplish this mission, it has implemented initiatives to address 

all aspects of terrorist financing. The TFRG:

a.	 Conducts full financial analyses of terrorist suspects and their

global financial support structures.

b.	 Coordinates liaison and outreach efforts to exploit financial

resources of private, government and foreign entities.

c.	 Uses FBI and Legal expertise and relationships to develop financial

information from foreign law enforcement and private agencies.

d. Works jointly with the law enforcement, regulatory, and ICs. 

e. Develops predictive models and mines data to proactively identify 

terrorist suspects.

f.	 Provides the financial component to classified counterterrorism

investigations in support of the FBI’s counterterrorism responsibilities. 

8.4. Multiple, International Law Enforcement Academies. DoS, DoJ, DHS, 

and Treasury Department. 

International Law Enforcement Academies are regional academies led 

by U.S. agencies partnering with foreign governments to provide law 

enforcement training, including anti-money-laundering and counteringterrorism-financing. International Law Enforcement Academies in

Gaborone, Botswana; Bangkok, Thailand; Budapest, Hungary; and

Roswell, New Mexico, train over 2,300 participants annually on topics

such as criminal investigations, international banking and money 

laundering, drug-trafficking, human smuggling, and cyber-crime.

Note

	 1.	 Adapted from the “Terrorist Financing: Better Strategic Planning Needed

to Coordinate U.S. Efforts to Deliver Counterterrorism Financing Training and Technical Assistance Abroad: GAO-06-19,” 2005, GAO Reports

1, 39-43.

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Appendix D: International Organizations 

and Efforts to Disrupt Terrorist Financing1

1. International Standard Setters

1.1. United Nations (UN). Of the key international entities, the UN has 

the broadest range of membership and the ability to adopt treaties 

or international conventions that have the effect of law in a country 

once signed and ratified, depending on a country’s constitution (which

is the case in the U.S.). 

1.1.1. Counterterrorism Implementation Task Force (CTITF). The CTITF’s 

overall function is to coordinate the various UN bodies working on 

counterterrorism. CTITF was created by the Secretary General and 

encompasses the UN Secretariat and the wider UN system in an attempt 

to better coordinate counterterrorism efforts across the UN system 

and to ensure stronger cooperation and efficiency in implementing

the counterterrorism-related mandates of various UN departments, 

programs, funds, offices and agencies and to strengthen information

sharing throughout the system. In its coordinating work the Task Force 

goes beyond the wider UN system to also include 24 other entities,

such as the International Criminal Police Organization (INTERPOL) 

and IMF. 

1.1.2. Counterterrorism Committee (CTC). Was established via Security 

Council Resolution 1373 to monitor the performance of the member

countries in building a global capacity against terrorism. The CTC, 

which is comprised of the 15 members of the Security Council, is

not a law enforcement agency; it does not issue sanctions, nor does

it prosecute or condemn individual countries. Rather, the committee seeks to establish a dialogue between the Security Council and 

member countries on how to achieve the objectives of Resolution 

1373. Countries submit a report to the CTC on steps taken to implement resolution’s measures and report regularly on progress. CTC 

identifies weaknesses and facilitates assistance, but does not provide

direct assistance. The CTC’s primary task is the review of member 

state reports that describe the degree of national compliance with the 

counterterrorism mandates of Security Council Resolution 1373. As

of 18 January 2002, 122 nation-states had submitted reports to the

committee. 

1.1.2.1. Counterterrorism Committee Executive Directorate (CTED). 

Provides the CTC with expert advice on all areas covered by resolution 

1373. CTED was established also with the aim of facilitating technical

assistance to countries, as well as promoting closer cooperation and 
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coordination both within the UN system of organizations and among 

regional and intergovernmental bodies. 

1.1.3. The UN Global Counterterrorism Strategy (2006). Enhances 

national, regional, and international efforts in counterterrorism. This 

is the first time that all 192 member states have agreed to a common

strategic approach to fight terrorism. Several items of the Strategy

address terrorist financing:

a.	 Under measures to prevent and combat terrorism, item 1 addresses

refraining from financing, encouraging or tolerating terrorist

activities; item 2 addresses cooperating fully in the fight against

persons who support, facilitate, participate or attempt to participate in the financing, of terrorist acts; and item 10 encourages

states to implement the standards embodied in the FATF Forty 

Recommendations on Money Laundering and Nine Special Recommendations on Terrorist Financing. 

b. Under measures to build states’ capacity to prevent and combat 

terrorism, item 8 encourages the IMF, World Bank, the UN Office on

Drugs and Crime (UNODC) and INTERPOL to enhance cooperation 

to help states comply with international norms and obligations 

to combat terrorist financing.

c.	 Rule of law, item 4, addresses maintaining effective rule so that

any persons who supports terrorist acts is brought to justice. 

1.1.4. Global Program Against Money Laundering (GPML) (1997). The 

GPML is within the UNODC. The GPML is a research and assistance 

project with the goal of increasing the effectiveness of international 

action against money laundering by offering technical expertise, 

training, and advice to member countries upon request. It focuses

its efforts in the following areas: 

a. Raising the awareness level among key persons in UN member 

states 

b. Helping create legal frameworks with the support of model legislation 

c. Developing institutional capacity, in particular with the creation 

of financial intelligence units

d. Providing training for legal, judicial, law enforcement, regulators,and 

private financial sectors including computer-based training

e. Promoting a regional approach to addressing problems 

f. Maintaining strategic relationships 

g. Maintaining database and performing analysis of relevant information. 
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1.2 Financial Action Task Force on Money Laundering (FATF). The FATF 

was formed in 1989 by the G-7 countries. FATF is an intergovernmental body comprised of 33 member jurisdictions and two regional 

organizations that brings together legal, financial, and law enforcement experts and whose purpose is to develop, promote, and asses 

policies, both at the national and international levels, to combat 

money laundering and the financing of terrorism (expanded to include

counterterrorism financing in October 2001). FATF has developed

multiple partnerships with international and regional organizations 

in order to constitute a global network of organizations against money 

laundering and terrorist financing. Five of the FATF’s most notable

contributions to disrupt terrorist financing include:

a. Forty Recommendations on Money Laundering

b. Nine Special Recommendations on Terrorist Financing

c. The establishment of the Non-Cooperative Countries and Territories (NCCT) List

d. Monitoring member progress in implementing anti-money-laundering measures

e.	 Reporting on money laundering trends and techniques.

1.2.1. Forty Recommendations on Money Laundering. The FATF’s Forty 

Recommendations constitute a comprehensive framework for antimoney laundering (AML) and are designed for universal application 

by countries throughout the world. The Forty Recommendations 

set out principles for action, which permit a country’s flexibility in

implementing the principles according to the country’s own particular 

circumstances and constitutional requirements. Although not binding

as law upon a country, the Forty Recommendations have been widely 

endorsed by the international community and relevant organizations 

as the international standard for AML. The Forty Recommendations 

are actually mandates for action by a country if that country wants 

to be viewed by the international community as meeting international standards. The Forty Recommendations are available at www.

fatf-gafi.org. 

1.2.2. Nine Special Recommendations on Terrorist Financing. The FATF’s 

Nine Special Recommendations, which have become the international standard for evaluating a state’s antiterrorist financing laws,

require:

a. Ratifying the United Nations International Convention for the Suppression of the Financing of Terrorism and implementing relevant 

UN resolutions against terrorist financing

b.	 Criminalizing the financing of terrorism, terrorist acts, and terrorist organizations
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c.	 Freezing and confiscating terrorist assets

d.	 Reporting by financial institutions of suspicious transactions

linked to terrorism 

e. Providing the widest possible assistance to other countries’ laws 

enforcement and regulatory authorities for terrorist financing

investigations

f.	 Imposing anti-money-laundering requirements on alternative

remittance systems

g. Including accurate and meaningful originator information on 

money transfers by financial institutions

h.	 Ensuring that nonprofit organizations cannot be misused to

finance terrorism

i. Implementing measures to detect the physical cross-border transportation of currency and bearer negotiable instruments. 

1.2.3. The Non-Cooperative Countries and Territories (NCCT) List. One 

of FATF’s objectives is to promote the adoption of international antimoney-laundering/countering-terrorism-financing standards by all

countries. Thus, its mission extends beyond its own membership. 

However, FATF can only sanction its member countries and territories. 

Thus, in order to encourage all countries to adopt measures to prevent, 

detect, and prosecute money launderers (i.e., to implement the Forty 

Recommendations), FATF adopted a process to identify noncooperative 

countries and territories that serve as obstacles to international cooperation in this area and place them on a public list. An NCCT country 

is encouraged to make rapid progress in remedying its deficiencies or

countermeasures may be imposed which may include specific actions

by FATF member countries. Most countries make a concerted effort 

to be taken off the NCCT list because it causes significant problems

to their international business and reputation. 

1.2.4. Monitoring Member’s Progress. Facilitated by a two-stage process: 

self assessments and mutual evaluations. In the self-assessment 

stage, each member annually responds to a standard questionnaire

regarding its implementation of the recommendations. In the mutual 

evaluation stage, each member is examined and assessed by experts 

from other member countries. Ultimately, if a member country does 

not take steps to achieve compliance, membership in the organization 

can be suspended. There is, however, a sense of peer pressure and a 

process of graduated steps before these sanctions are enforced. 

1.2.5. Reporting on Money Laundering Trends and Techniques. One of 

FATF’s functions is to review and report on money laundering trends, 

techniques, and methods (also referred to as typologies). To accomplish

this aspect of its mission, FATF issues annual reports on develop-
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ments in money laundering through its Typologies Report. These 

reports are very useful for all countries, not just FATF members, to 

keep current with new techniques or trends to launder money and

for other developments in this area. 

2. International Capacity Builders

2.1 Egmont Group of Financial Intelligence Units. This is an is an informal body without a secretariat. The Egmont Group is an international 

network of 101 countries that have implemented national centers to

collect information on suspicious or unusual financial activity from

the financial industry, analyze the data, and make it available to

appropriate authorities and other FIUs for use in combating terrorist 

financing and other financial crimes. Members of the Egmont Group

have access to a secure private Web site to exchange information. As 

of 2004, 87 of the members were connected to the secure Web. The

Egmont Group has no permanent location and meets in a plenary 

session once a year and in working group sessions three times a year. 

Within the Egmont Group, the FIU heads make all the policy decisions, 

including membership. Currently, Egmont Group’s efforts focus on 

fostering improved communications, information sharing, and training coordination worldwide in the fight against money laundering and

terrorist financing.

2.1.1 Financial Intelligence Unites (FIUs). FIUs are a central, national 

agencies responsible for receiving (and as permitted, requesting),

analyzing, and disseminating to competent authorities, disclosures 

of financial information concerning suspected proceeds of crime and

potential financing of terrorism or as required by national legislation or

regulation in order to combat money laundering and terrorist financing. The Egmont Group’s definition of an FIU is entirely consistent

with the Forty Recommendations of the FATF. In addition, FIUs must 

also commit to act in accordance with the Egmont Group’s Principles 

for Information Exchange Between FIUs for money laundering and 

terrorist financing cases. These principles include conditions for the

exchange of information, limitation on permitted uses of information, 

and confidentiality.

2.2 International Monetary Fund (IMF) and World Bank. The World Bank 

helps countries strengthen development efforts by providing loans 

and technical assistance for institutional capacity building. The IMF 

mission involves financial surveillance and the promotion of international monetary stability. Together, the World Bank and IMF have 

established a collaborative framework with the FATF for conducting 

comprehensive anti-money-laundering/combating-financing-ofterrorism (AML/CFT) assessments of countries’ compliance with the 
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FATF’s Forty Recommendations on Money Laundering and Nine Special 

Recommendations on Terrorist Financing (known as the FATF 40+9

Recommendations) using a single global methodology. The assessments are carried out as part of the Financial Sector Assessment 

Program (FSAP) and lead to a Report on Observance of Standard and 

Codes (ROSCs). Three areas that the World Bank and IMF focus on 

include research and analysis and awareness-raising, assessments, 

and training and technical assistance. 

2.2.1. Research and Analysis and Awareness-Raising. The World Bank and 

IMF have: a) conducted work on international practices in implementing 

anti-money-laundering and countering-terrorism-financing regimes;

b) issued Analysis of the Hawala System discussing implications for 

regulatory and supervisory response; c) developed a comprehensive

reference guide on anti-money-laundering/countering-terrorismfinancing presenting all relevant information in one source; d) conducted Regional Policy Global Dialogue series with country, World Bank 

and IMF, development banks, and FATF-style regional bodies covering 

challenges, lessons learned, and assistance needed; and e) developed

Country Assistance Strategies that cover anti-money laundering and 

countering-terrorism financing in greater detail in countries that have

been deficient in meeting international standards.

2.2.2. Assessments. The World Bank and IMF have a) worked in close 

collaboration with FATF and FATF-style regional bodies to a produce single comprehensive methodology for anti-money-laundering/

countering-terrorism-financing assessments and b) engaged in a

successful pilot program of assessments of country compliance with 

FATF recommendations. In 2004, the World Bank and IMF adopted

the FATF 40+9 Recommendations as one of the 12 standards and

codes for which Reports on the Observance of Standards and Codes 

can be prepared and made anti-money-laundering/countering-terrorism-financing assessments a regular part of IMF/World Bank work.

World Bank and IMF staff participated in 58 of the 92 assessments

conducted since 2002.In addition, the Boards of the World Bank and

the IMF have agreed to adopt a more comprehensive and integrated 

approach to conducting assessments of compliance with international 

standards for fighting money laundering and terrorist financing in

member countries and to step up the delivery of technical assistance 

to those countries whose financial systems are most at risk.

2.2.3. Training and Technical Assistance. The World Bank and IMF have: 

a) organized training conferences and workshops, b) delivered technical assistance to individual countries, c) coordinated technical 

assistance, and d) substantially increased technical assistance to 

member countries on strengthening legal, regulatory, and financial
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supervisory frameworks for anti-money-laundering/counteringterrorism-financing. In 2002-2003 there were 85 country-specific

technical projects benefiting 63 countries and 32 projects reaching

more than 130 countries. Between January 2004 and June 2005, the

World Bank and IMF delivered an additional 210 projects. In 2004, IMF

and the World Bank decided to expand the anti-money-laundering/

countering-terrorism-financing technical assistance work to cover

the full scope of the expanded FATF recommendations following the 

successful pilot program of assessments.

2.3 International Organization of Supreme Audit Institutions. International cooperation related to money laundering also occurs through 

the International Organization of Supreme Audit Institutions, which 

represents 191 UN member nations and is the top accountability

organization related to government audit and oversight. The U.S. 

Government Accountability Office (formerly General Accounting Office) 

and its counterparts from around the world are working cooperatively 

to improve their oversight capacity for government departments and 

regulatory financial institutions. This work takes the form of publishing and disseminating standards and guidelines in critical areas 

such as auditing, internal control, financial reporting, information

technology, and public debt. In addition, the organization recently 

established a task force charged with studying the national audit 

offices’ role in helping prevent and detect money laundering and

sharing information and experiences with each other. The organization also has established partnerships with organizations such as 

the World Bank and the International Federation of Accountants to 

strengthen its impact in these areas.

2.4 G8. The G8 established a Counterterrorism Action Group (CTAG) 

composed of donor countries, as well as other states, mainly donors, 

to expand and coordinate training and assistance for countries that 

have the political will but lack the capacity to combat terror. 

CTAG provides an active forum for donor countries to coordinate 

counterterrorism cooperation with and assistance for countries in 

support of the UN Counterterrorism Committee’s efforts to oversee 

implementation of UN Security Council Resolution 1373. This resolution obligates all states to deny safe haven to those who finance,

plan, support, or commit terrorist acts. CTAG has coordinated efforts 

to assist countries to assess and improve airport security and has 

promoted and assisted with the implementation of travel security 

and facilitation standards and practices developed by G8’s Secure 

and Facilitated International Travel Initiative (SAFTI). CTAG goals are 

to analyze and prioritize needs and expand training and assistance 

in critical areas, including counterterrorism financing and other
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counterterrorism areas. In 2004, CTAG coordinated with FATF to

obtain assessments of countries CTAG identified as priorities. Anticipated areas of activity include outreach to countries in the area of 

counterterrorism cooperation and providing capacity building assistance to nations with insufficient capacity to fight terrorism.

2.5. INTERPOL. INTERPOL’s Web site serves as a clearinghouse for foreign 

law enforcement for the lists of those subject to freezing actions. The 

INTERPOL database consolidates international and national lists of 

terrorist financiers and makes it available to police around the world

to prevent the flow of funds to terrorist groups and to assist in criminal

investigations. INTERPOL collects, stores, analyzes, and exchanges 

information about suspected individuals and groups and their activities. The organization, with its 186 member states, also coordinates the

circulation of alerts and warnings on terrorists, dangerous criminals, 

and weapons threats to police in member countries. A chief initiative 

in this area is the Fusion Task Force. 

2.5.1. Fusion Task Force (FTF). As the planning for terrorist attacks often 

spans multiple countries and regions, fighting terrorism also requires

the same level of effort and cooperation among nations. Spearheading 

INTERPOL’s antiterrorism efforts is the FTF, created in September 

2002, in the wake of the alarming rise in the scale and sophistication

of international terrorist attacks. FTF’s primary objectives are to: 

a. Identify active terrorist groups and their membership. 

b. Solicit, collect, and share information and intelligence. 

c. Provide analytical support.

d. Enhance the capacity of member countries to address the threats 

of terrorism and organized crime. 

As terrorist organizations’ far-reaching activities are inextricably linked, 

the task force investigates not only attacks but also organizational 

hierarchies, training, financing, methods, and motives.

3. Regional Entities

In addition to the International Standard Setters and Capacity Builders 

there are other international organizations that play crucial roles in the 

fight against money laundering and terrorist financing. These groups tend

to be organized according to geographic region or by the special purpose 

of the organization.

3.1. FATF-Style Regional Bodies (FSRBs). Modeled after FATF, these groups 

have anti-money-laundering/countering-terrorism-financing efforts as

their objectives. FSRBs encourage implementation and enforcement 

of FATF’s 40+9 Recommendations. They administer mutual evaluations of their members, which are intended to identify weaknesses so 
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that the members may take remedial action. They provide members 

information about trends, techniques, and other developments for

money laundering in their typology reports. The size, sophistication, 

and the degree to which the FSRBs can carry out their missions 

vary greatly. Currently, the eight FSRBs are Asia/Pacific Group on

Money Laundering, Caribbean Financial Action Task Force, Council 

of Europe MONEYVAL, Eastern and Southern African Anti-Money 

Laundering Group, Eurasian Group on Combating Money Laundering and Financing of Terrorism, Financial Action Task Force Against 

Money Laundering in South America, Middle East and North Africa 

Financial Action Task Force, Inter-governmental Action Group Against 

Money Laundering (West Africa). 

3.2. Wolfsberg Group of Banks. The Wolfsberg Group is an association of 

12 global banks, representing primarily international private banking concerns. The group was named after the Château Wolfsberg in 

northeastern Switzerland where the group was formed. Wolfsberg 

Group established four sets of principles for private banking: 

a. AML principles for private banking, which deal with customer 

identification, including establishing beneficial ownership for all

accounts, and situations involving extra due diligence, such as 

unusual or suspicious transactions

b.	 A statement on the suppression of the financing of terrorism, which

emphasizes that financial institutions need to assist competent

authorities in fighting terrorist financing through prevention,

detection, and information sharing

c. Fourteen AML principles for correspondent banking, which prohibit international banks from doing business with “shell banks” 

and use a risk-based approach to correspondent banking that is 

designed to ascertain the appropriate level of due diligence that 

a bank should adopt with regard to its correspondent banking 

clients

d.	 Monitoring screening and searching, which identifies issues that

should be addressed in order for financial institutions to develop

suitable monitoring, screening and searching processes, using a 

risk-based profile approach.

3.3. The Commonwealth Secretariat. The Commonwealth Secretariat 

is a voluntary association of 53 sovereign states that consult and 

cooperate in the common interest of their peoples on a broad range 

of topics, including the promotion of international understanding 

and world peace. All of the member states, except for Mozambique,

have experienced direct or indirect British rule or have been linked 

administratively to another Commonwealth country.
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With regard to AML and combating the financing of terrorism, the

Commonwealth Secretariat provides assistance to countries to implement the FATF 40+9 Recommendations. It works with national and

international organizations and assists governments in the implementation of the FATF recommendations. In addition, the Commonwealth 

Secretariat has published A Manual of Best Practices for Combating 

Money Laundering in the Financial Sector. The manual is for government policy makers, regulators and financial institutions.

3.4. Organization of American States (OAS). The OAS is the regional 

body for security and diplomacy in the Western Hemisphere. All 35 

countries of the Americas have ratified the OAS charter. In 2004, the

commission amended model regulations for the hemisphere to include 

techniques to combat terrorist financing, development of a variety of

associated training initiatives, and a number of anti-money-laundering/counterterrorism meetings. Its Mutual Evaluation Mechanism 

included updating and revising some 80 questionnaire indicators

through which the countries mutually evaluate regional efforts and 

projects. Worked with International Development Bank and France to 

provide training for prosecutors and judges. Based on agreement with 

Inter-American Development Bank for nearly $2 million, conducted a

two-year project to strengthen FIUs in eight countries. In addition, the 

OAS assists with evaluating strategic plans and advising on technical 

design for FIUs in region.

3.5. Asian Development Bank (ADB). Established in 1966, the ADB is

a multilateral development finance institution dedicated to reducing

poverty in Asia and the Pacific. The bank is owned by 63 members,

mostly from the region, and engages in mostly public sector lending 

in its developing member countries. 

According to the ADB, it was one of the first multilateral development banks to address the money laundering problem, directly 

and indirectly, through regional and country assistance programs. 

The ADB Policy Paper, adopted on 1 April 2003, has three key elements: a) assisting developing member countries in establishing 

and implementing effective legal and institutional systems for antimoney-laundering and countering-terrorism-financing, b) increasing

collaboration with other international organizations and aid agencies, 

and c) strengthening internal controls to safeguard ADB’s funds. The 

bank provides loans and technical assistance for a broad range of 

development activities, including strengthening and developing antimoney-laundering regimes.

3.6. European Union (EU). The EU and the U.S. have worked closely 

together to ensure that terrorist financiers designated by one party

are also designated by the other. For example, in August 2002, Italy
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joined the U.S. in submitting to the UN Sanctions Committee the 

names of 25 individuals and entities linked to Al Qaeda so that their

assets could be frozen worldwide. 

4. Industry Sector Standard Setters

The following are various industries that are viewed as international 

standard setters. 

4.1. Basel Committee on Banking (Basel Committee). Established by the 

central bank Governors of the Group of Ten countries in 1974, formulates broad supervisory standards and guidelines and recommends 

statements of best practice in the expectation that individual authorities 

will take steps to implement them through detailed arrangements—

statutory or otherwise—which are best suited to their own national 

systems. Three of the Basel Committee’s supervisory standards and 

guidelines concern money laundering issues: 

a. Statement on Prevention of Criminal Use of the Banking System 

for the purpose of Money Laundering, 1988, which outlines basic

policies and procedures that bank managers should ensure are 

in place 

b. Core Principles for Effective Banking Supervision, 1997, which

provides a comprehensive blueprint for an effective bank supervisory system and covers a wide range of topics including money 

laundering 

c. Customer Due Diligence, 2001, which also strongly supports adoption and implementation of the FATF recommendations. 

4.2. International Association of Insurance Supervisors. Established in 

1994, this is an organization of supervisors from more than 100 different countries and jurisdictions that promotes cooperation among 

regulators, sets international standards, provides training, and coordinates with other financial sectors.

The Association established the Anti-Money Laundering Guidance 

Notes for Insurance Supervisors and Insurance Entities, 2002, which

is a comprehensive discussion on money laundering in the context of 

the insurance industry. The guidance is intended to be implemented 

by individual countries taking into account the particular insurance 

companies involved, the products offered within the country, and the 

country’s own financial system. The Association’s work is consistent

with the FATF 40+9 Recommendations and the Basel Core Principles

for Effective Banking Supervision. Its 2002 paper was updated as a

Guidance Paper on Anti-Money Laundering and Combating the Financing 

of Terrorism in 2004, with cases on money laundering and terrorist

financing. A document based upon these cases is posted on their Web
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site and is updated as new cases that might result from the FATF 

typology project are added.

4.3. International Organization of Securities Commissions (IOSCO). Members regulate and administer securities and laws in their respective 

105 national securities commissions. Core objectives are to protect

investors; ensure that markets are fair, efficient, and transparent;

and reduce systematic risk. 

IOSCO passed Resolution on Money Laundering in 1992 and

Principles on Client Identification and Beneficial Ownership for the 

Securities Industry, 2004, which is a comprehensive framework relating to customer due-diligence requirements and complementing the

FATF Forty Recommendations. In addition, IOSCO and FATF have 

discussed further steps to strengthen cooperation among FIUs and 

securities regulators in order to combat money laundering and terrorist financing.

Note

	 1.	 Adapted from the “Terrorist Financing: Better Strategic Planning Needed

to Coordinate U.S. Efforts to Deliver Counterterrorism Financing Training and Technical Assistance Abroad: GAO-06-19,” 2005, GAO Reports

1, 39-43.
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Appendix E. International 

Resolutions and Conventions1

1. United Nations (UN)

The UN and its member states established a broad array of resolutions 

and conventions to create a multilateral framework for combating international terrorism. This UN-based multilateral framework falls into three 

broad categories of documents or agreements: 

a. UN conventions or protocols related to terrorism

b. UN Security Council resolutions

c. UN General Assembly resolutions. 

According to the DoS, the U.S. is a party to all 12 international conventions and protocols relating to terrorism. 

1.1. UN Conventions. International conventions, which require signing,

ratification, and implementation by the UN member country to have

the effect of law within that country.

1.1.1. International Convention for the Suppression of the Financing 

of Terrorism, 1999. This convention applies to the offense of direct 

involvement or complicity in the intentional and unlawful provision 

or collection of funds, whether attempted or actual, with the intention 

or knowledge that any part of the funds may be used to carry out any 

of the offenses described in the conventions listed in its annex, or an 

act intended to cause death or serious bodily injury to any person not 

actively involved in armed conflict in order to intimidate a population,

or to compel a government or an international organization to do or 

abstain from doing any act. The provision or collection of funds in 

this manner is an offense whether or not the funds are actually used 

to carry out the proscribed acts. The convention requires each state

party to take appropriate measures, in accordance with its domestic 

legal principles, for the detection and freezing, seizure, or forfeiture 

of any funds used or allocated for the purposes of committing the 

offences described. 

1.1.2. International Convention Against Transnational Organized Crime 

(TOC), 2000. The TOC entered into force on 29 September 2003, after

40 countries became party to the treaty. As of 26 October 2005, there

are 147 signatories and 112 parties to the TOC. The trafficking in

persons protocol entered into force on 25 December 2003 and has 117

Signatories and 93 Parties. The migrant smuggling protocol entered

into force on 28 January 2004 and currently has 112 Signatories and

82 Parties. The TOC represents the first legally binding multilateral
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instrument that specifically targets transnational organized crime.

It requires parties that have not already done so to adopt legislation

criminalizing certain conduct typically associated with organized crime 

and provides a framework for international cooperation among parties 

to assist each other in investigating and prosecuting transnational 

organized crime. The successful negotiation and widespread ratification of the TOC represent the global community’s resolve to combat 

transnational organized crime as a serious worldwide threat. 

1.1.3. Convention Against Corruption, 2003. This is the first legally

binding multilateral treaty to address on a global basis the problems 

relating to corruption. Requires parties to institute a comprehensive

domestic regulatory and supervisory regime for banks and financial

institutions to deter and detect money laundering. Regimes must 

emphasize requirements for customer identification, record keeping,

and suspicious transaction reporting. 

1.2. Security Council Resolutions. Unlike an international convention, 

which requires signing, ratification, and implementation by the UN

member country to have the effect of law within that country, a Security Council Resolution passed in response to a threat to international 

peace and security under Chapter VII of the UN Charter is binding 

upon all UN member countries. 

1.2.1. Security Council Resolution 1214, 1998. Demands that the Taliban 

stop providing sanctuary and training for international terrorists and 

their operations, and that all Afghan factions cooperate with efforts 

to bring indicted terrorists to justice. 

1.2.2. Security Council Resolution 1267, 1999. Obligates member states 

to freeze assets of individuals and entities associated with Osama 

bin Laden or members of Al Qaeda or the Taliban that are included 

on the consolidated list maintained and regularly updated by the UN 

1267 Sanctions Committee.

1.2.3. Security Council Resolution 1269, 1999. Calls on member states 

to implement the international antiterrorist conventions to which 

they are a party and encourages the speedy adoption of the pending 

conventions. Although the Security Council specifically referred to

“terrorist financing” for the first time in Resolution 1269, it was not

in the context of state-sponsored terrorism. General Assembly Resolution 49/60 clearly implicates state entities directly in such financing

by acts and omissions such as sheltering, facilitating, funding, and 

failure to adopt suppressive measures.

1.2.4. Security Council Resolution 1333, 2000. Requires member states

to freeze without delay the funds and other financial assets of Osama

bin Laden and Al Qaeda associates. It also demands that the Taliban 
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should act swiftly to close all camps where terrorists are trained within 

the territory under its control.

1.2.5. Security Council Resolution 1363, 2001. Establishes a mechanism 

to monitor the implementation of the measures imposed by UN Security Council Resolutions 1267 and 1333.

1.2.6. Security Council Resolution 1368, 2001. Condemns the 9/11

attacks and calls on all states to work together urgently to bring to 

justice the perpetrators, organizers and sponsors of these terrorist 

attacks and stresses that those responsible for aiding, supporting 

or harboring the perpetrators, organizers and sponsors of these will 

be held accountable. The resolution also calls on the international 

community to increase their efforts to prevent and suppress terrorist acts by increased cooperation and full implementation of the 

relevant international antiterrorist conventions and Security Council 

resolutions, especially Resolution 1269 (1999). Finally, the resolution

expresses the Security Council’s preparedness to take all necessary 

steps to respond to the terrorist attacks of 9/11 and to combat all

forms of terrorism, in accordance with its responsibilities under the 

charter of the UN. 

1.2.7. Security Council Resolution 1373, 2001. Was adopted in direct 

response to events of September 11, 2001. Obligates countries to

criminalize actions to finance terrorism and deny all forms of support,

freeze funds or assets of persons, organizations, or entities involved in 

terrorist acts; prohibit active or passive assistance to terrorists; and

cooperate with other countries in criminal investigations and sharing 

information about planned terrorist acts. 

1.2.8. Security Council Resolution 1377, 2001. Calls on member states 

to implement UN Security Council Resolution 1373 and to assist each

other in doing so. Also it invites states to inform the Counterterrorism 

Committee of areas where they require support.

1.2.9. Security Council Resolution 1390, 2002. Obligates member states 

to freeze assets of individuals and entities associated with Osama 

bin Laden or members of Al Qaeda or the Taliban that are included 

on the consolidated list maintained and regularly updated by the UN 

1267 Sanctions Committee.

1.2.10. Security Council Resolution 1452, 2002. Decided that the provisions of resolution 1267 and 1390 do not apply to funds and other

financial assets or economic resources that have been determined

by the state to be necessary for basic expenses and extraordinary 

expenses. 

1.2.11. Security Council Resolution 1455, 2003. Improves the implementation of measures against the Taliban and members of the Al Qaeda 
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organization and their associates to include: a) the freezing of funds 

and other financial resources of the Taliban, as well as funds and

other financial assets of Osama bin Laden and individuals and entities associated with him as designated by the committee established 

by resolution 1267 (1999), an arms embargo, and travel prohibitions

and b) the need for improved coordination and increased exchange of 

information between the committee established by resolution 1267

(1999) and the Counterterrorism Committee established by resolution

1373 (2001), and called on all states to submit an updated report to

the committee no later than 90 days after today on all steps taken to

implement the above-mentioned measures and all related investigations and enforcement actions, unless to do so would compromise 

investigations or enforcement actions. 

1.2.12. Security Council Resolution 1456, 2003. Calls on states to prevent 

and suppress all active and passive support to terrorism and comply 

with UN Security Council resolutions 1373, 1390, and 1455. Also calls

on states to become a party to all relevant international conventions 

and protocols relating to terrorism, in particular the 1999 international

convention for the suppression of the financing of terrorism.

1.2.13. Security Council Resolution 1526, 2004. Expanded the broad 

set of measures adopted in resolution 1267 and 1269 (1999). Calls

on states to: a) not only freeze the economic resources and financial

assets of Al Qaeda connected individuals or groups but also those 

of “undertakings and entities, including funds derived from property 

owned or controlled, directly or indirectly by them...and ensure that 

neither those funds or any other financial assets...are made available, directly or indirectly for such person’s benefit, by their nationals

or by any persons within their territory” and b) move vigorously and 

decisively to cut the flows of funds and other financial assets and

economic resources to individuals and entities associated with the Al 

Qaeda organization, Osama bin Laden and/or the Taliban, taking into 

account international codes and standards for combating the financing

of terrorism, including those designed to prevent the abuse of nonprofit

organizations and informal/alternative remittance systems. 

1.2.14. Security Council Resolution 1566, 2004. Recalling that criminal 

acts, including against civilians, committed with the intent to cause 

death or serious bodily injury, or taking of hostages, with the purpose 

to provoke a state of terror, or compel a government or international 

organization to do or to abstain from doing any act that contravened 

terrorism-related conventions and protocols, were not justifiable for any

reason—whether of a political, philosophical, ideological, racial, ethnic 

or religious nature. Further, the council established a working group 

consisting of all its members, which would submit recommendations
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on practical measures to be imposed on individuals, groups or entities involved in or associated with terrorist activities, other than those 

designated by the Al Qaeda/Taliban Sanctions Committee. The recommendations could include more effective procedures for bringing the 

perpetrators to justice through prosecution and extradition. 

1.2.15. Security Council Resolution 1617, 2005. Extended sanctions 

against Al Qaeda, Osama bin Laden, and the Taliban, and strengthened previous related resolutions. This resolution extends the mandate of the 1267 Sanctions Committee’s Monitoring Team: the eight

experts, including one American, who are its eyes and ears. It also 

clarified what constitutes association with Al Qaeda, adds enhanced

due-process provisions to the listing process, and strongly urges 

all member states to implement the comprehensive international 

standards embodied in the FATF Forty Recommendations on Money 

Laundering and the FATF Nine Special Recommendations on Terrorist 

Financing. In addition, the Council requested the Secretary-General

increase cooperation between the UN and INTERPOL in order to 

provide the 1267 Committee with better tools to fulfill its mandate

and urged member states to ensure that stolen and lost passports 

and other travel documents were invalidated as soon as possible, as 

well as to share information on those documents with other member 

states through the INTERPOL database. 

1.2.16. Security Council Resolution 1624, 2005. Is a resolution related to 

the incitement of terrorist acts. Calls upon all states to a) cooperate, 

inter alia, to strengthen the security of their international borders—

including by combating fraudulent travel documents and, to the extent 

attainable, by enhancing terrorist screening and passenger security 

procedures—and b) continue international efforts to enhance dialogue 

and broaden understanding among civilizations—in an effort to prevent the indiscriminate targeting of different religions and cultures, 

and to take all measures as may be necessary and appropriate and in 

accordance with their obligations under international law to counter 

incitement of terrorist acts motivated by extremism and intolerance 

and to prevent the subversion of educational, cultural, and religious 

institutions by terrorists and their supporters. 

1.2.17. Security Council Resolution 1730, 2006. Expanded on UNSCR 

1617 and added an element of due process to designation mechanism.

UNSCR 1730: a) emphasizes that sanctions are an important tool in

the maintenance and restoration of international peace and security;

b) adopts delisting procedures and requests the Secretary-General

establish within the Secretariat (Security Council Subsidiary Organs 

Branch), a focal point to receive delisting requests and to perform

the tasks described in the annex to UNSCR 1730; and c) directs the
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sanctions committees established by the Security Council, including 

those established pursuant to resolution 1718 (2006), 1636 (2005),

1591 (2005), 1572 (2004), 1533 (2004), 1521 (2005), 1518 (2003),

1267 (1999), 1132 (1997), 918 (1994), and 751 (1992) to revise their

guidelines accordingly 

1.2.18. Security Council Resolution 1735, 2006. Is a rollover of UNSCR 

1617, reaffirming 1267, 1373, 1617, standardizing listing procedures

through use of cover sheet and statement of case. Expresses deep 

concern about the criminal misuse of the Internet and the nature 

of the threat in particular the ways in which terrorist ideologies are 

promoted by Al Qaeda, Osama bin Laden, and the Taliban, and other 

individuals, groups, undertakings, and entities associated with them, 

in furtherance of terrorist acts. Freezes the funds and other financial

assets or economic resources of these individuals, groups, undertakings and entities, including funds derived from property owned 

or controlled, directly or indirectly, by them or by persons acting on 

their behalf or at their direction, and ensure that neither these nor 

any other funds, financial assets or economic resources are made

available, directly or indirectly, for such persons’ benefit, or by their

nationals or by persons within their territory. In addition it updates 

some of the procedures and forms for listing and delisting terrorist 

to the committee for placement on the consolidated list as initially 

outlined in UNSCR 1267 and 1333.

Authors Note: As of June 2007, the UN had not passed any Security

Council resolutions regarding terrorist financing.

1.3. General Assembly Resolutions 

1.3.1. General Assembly Resolution 49/60, 1994. Approves the Declaration on Measures to Eliminate International Terrorism, which, among 

other things, unequivocally condemns all acts of terrorism, demands

that states take effective and resolute measures to eliminate terrorism, and charges the Secretary General with various implementation 

tasks. Some of these tasks include collecting data on the status of 

existing international agreements relating to terrorism and developing an international legal framework of conventions on terrorism. The 

first international legal use of the term “terrorist financing” appeared

in the UN General Assembly’s seminal Declaration on Measures to 

Eliminate International Terrorism in 1994.

1.3.2. General Assembly Resolution 51/210, 1996. Calls upon states to 

adopt further measures to prevent and combat terrorism. Some of 

these include accelerating research and development of explosive detection and marking technology; investigating the abuse of charitable,

social, and cultural organizations by terrorist organizations; and
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developing mutual legal assistance procedures to facilitate crossborder investigations. Further calls upon states to become parties 

to relevant international antiterrorism conventions and protocols. 

Also establishes an ad hoc committee to develop an international 

convention for the suppression of terrorist bombings and acts of 

nuclear terrorism. Approves a supplement to the 1994 declaration on

measures to Eliminate International Terrorism, which, among other 

things, reaffirms that asylum seekers may not avoid prosecution for

terrorist acts and encourages states to facilitate terrorist extraditions 

even in the absence of a treaty. 

1.3.3. General Assembly Resolution 52/165, 1997. Reiterates General 

Assembly Resolution 51/210. Reaffirms the Declaration on Measures

to Eliminate International Terrorism. Requests the ad hoc committee

established by UN General Assembly Resolution 51/210 continue

its work. Requests the Secretary General to invite the International

Atomic Energy Agency to assist the ad hoc committee.

1.3.4. General Assembly Resolutions 53/108, 1999. Recalls General 

Assembly Resolution 52/165. Reaffirms that actions by states to

combat terrorism should be conducted in conformity with the charter 

of the UN, international law, and relevant conventions. Decides to 

address the question of convening a UN conference to formulate a joint

response to terrorism by the international community. Decides the ad 

hoc committee shall continue to elaborate on a draft convention for 

the suppression of terrorist financing and will continue developing a

draft convention for the suppression of acts of nuclear terrorism. 

1.3.5. General Assembly Resolution 54/109, 2000. Adopts the International Convention for the Suppression of the Financing of Terrorism 

and urges all states to sign and ratify, accept, approve, or accede to 

the convention. 

1.3.6. General Assembly Resolution 54/110, 2000. Notes the establishment of the Terrorism Prevention Branch of the Centre for International Crime Prevention in Vienna, Austria. Invites states to submit 

information on their national laws, regulations, or initiatives regarding 

terrorism to the Secretary General. Invites regional intergovernmental 

organizations to do likewise. Continues the previous work of the ad 

hoc committee.

1.3.7. General Assembly Resolution 55/158, 2001. Reiterates General 

Assembly Resolution 54/110. Welcomes the efforts of the Terrorism

Branch of the Centre for International Crime Prevention. Continues 

the previous work of the ad hoc committee.

1.3.8. General Assembly Resolution 56/88, 2002. Calls upon states to 

refrain from financing, encouraging, providing training for, or otherwise
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supporting terrorist activities. Urges all states that have not yet done 

so to consider, as a matter of priority, and in accordance with Security Council resolution 1373 (2001), becoming parties to relevant

conventions and protocols as referred to in paragraph 6 of General

Assembly resolution 51/210, as well as become parties to International Convention for the Suppression of the Financing of Terrorism 

and calls upon all states to enact, as appropriate, domestic legislation necessary to implement the provisions of those conventions and 

protocols, to ensure that the jurisdiction of their courts enables them 

to bring to trial the perpetrators of terrorist acts, and to cooperate 

with and provide support and assistance to other states and relevant 

international and regional organizations to that end. 

1.3.9. General Assembly Resolution 56/288, 2002. Decided to consider 

further requirements necessary for conference and support servicing

of the Counterterrorism Committee in the context of the first performance report at its fifty-seventh session.

1.3.10. General Assembly Resolution 57/27, 2003. Reiterates its call upon 

states to refrain from financing, encouraging, providing training for, or

otherwise supporting terrorist activities. Reiterates General Assembly 

Resolution 56/88 with regard to terrorist financing.

1.3.11. General Assembly Resolution 57/219, 2003. Affirms that states

must ensure that any measure taken to combat terrorism complies 

with their obligations under international law, in particular international human rights, refugee, and humanitarian law. Encourages 

states, while countering terrorism, to take into account relevant 

UN resolutions and decisions on human rights and to consider the 

recommendations of the special procedures and mechanisms of the 

Commission on Human Rights and the relevant comments and views 

of UN human rights treaty bodies.

1.3.12. General Assembly Resolution 58/81, 2004. Reiterates its call upon 

states to refrain from financing, encouraging, providing training for or

otherwise supporting terrorist activities. Reiterates General Assembly 

Resolution 56/88 with regard to terrorist financing.

1.3.13. General Assembly Resolution 58/136, 2004. Supports the ongoing efforts of the executive director of the UN Office on Drugs and

Crime to enhance an integrated approach to combating terrorism, 

drug trafficking, transnational organized crime, and other related

forms of criminal activity. Stresses the need for close coordination 

and cooperation between states, international, regional, and subregional organizations and the Counterterrorism Committee, as well 

as the Centre for International Crime Prevention, in preventing and 

combating terrorism and criminal activities carried out for the purpose 
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of furthering terrorism in all its forms and manifestations. Encourages the activities of the Centre for International Crime Prevention 

of the UN Office on Drugs and Crime within its mandates in the area

of preventing terrorism by providing member states, upon request,

with technical assistance, specifically to implement the universal

conventions and protocols related to terrorism. 

1.3.14. General Assembly Resolution 58/174, 2004. Expresses concern 

about the growing connection between terrorist groups and other 

criminal organizations engaged in the illegal traffic in arms and drugs

at the national and international levels, as well as the consequent

commission of serious crimes such as murder, extortion, kidnapping, 

assault, the taking of hostages, and robbery, and requests the relevant

UN bodies to continue to give special attention to this question.

1.3.15. General Assembly Resolution 58/187, 2004. Reiterates General 

Assembly Resolution 57/219. Notes also the declaration on the issue

of combating terrorism contained in the annex to Security Council 

resolution 1456 (2003), in particular the statement that states must

ensure that any measures taken to combat terrorism comply with 

all their obligations under international law and should adopt such 

measures in accordance with international law, in particular international human rights, refugee, and humanitarian law.

1.3.16. General Assembly Resolution 59/46, 2004. Reiterates General 

Assembly Resolution 56/88 with regard to terrorist financing. In addition, urges states to ensure that their nationals or other persons and 

entities within their territory that willfully provide or collect funds for 

the benefit of persons or entities who commit, or attempt to commit,

facilitate, or participate in the commission of terrorist acts are punished by penalties consistent with the grave nature of such acts.

1.3.17. General Assembly Resolution 59/153, 2005. Reiterates General 

Assembly Resolution 58/136.

1.3.18. General Assembly Resolution 59/195, 2005. Emphasizes the need 

to intensify the fight against terrorism at the national level, to enhance

effective international cooperation in combating terrorism in conformity with international law, including relevant state obligations under 

international human rights and international humanitarian law, and 

to strengthen the role of the UN in this respect. Emphasizes also that 

states shall deny safe haven to those who finance, plan, support or

commit terrorist acts or provide safe havens. States concern with the 

tendencies to link terrorism and violence with religion and reject the 

identification of terrorism with any religion, nationality or culture.

1.3.19. General Assembly Resolution 60/43, 2006. Reiterates General 

Assembly Resolution 59/46 with regard to terrorist financing. In
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addition, urges all states that have not yet done so to consider, as a 

matter of priority, and in accordance with Security Council resolutions 1373 and 1566, to become parties to International Convention

for the Suppression of the Financing of Terrorism.

1.3.20. General Assembly Resolution 60/288, 2006. UN Global Counterterrorism Strategy recommends measures to: a) address the conditions 

conducive to the spread of terrorism; b) prevent and combat terrorism, to include encouraging states to implement the comprehensive 

international standards embodied in the Forty Recommendations 

and Nine Special Recommendations of the FATF, recognizing that 

states may require assistance in implementing them; c) build states’

capacity to prevent and combat terrorism and to strengthen the role 

of the UN system in this regard, to include encouraging IMF, World 

Bank, UNODC, and INTERPOL to enhance cooperation with states to 

help them to comply fully with international norms and obligations to 

combat money-laundering and the terrorist financing; and d) ensure

respect for human rights for and the rule of law as the fundamental 

basis of the fight against terrorism, to include domestic laws and

regulations that state any person who participates in the financing,

planning, preparation, or perpetration of terrorist acts or in support 

of terrorist acts is categorized as a serious criminal.

1.3.21. General Assembly Resolution 61/40, 2006. Requests the Terrorism Prevention Branch of the UN Office on Drugs and Crime in

Vienna to continue its efforts to enhance, through its mandate, the 

capabilities of the UN in the prevention of terrorism, and recognizes, in 

the context of the UN Global Counterterrorism Strategy and Security 

Council resolution 1373 (2001), its role in assisting states in becoming

parties to and implementing the relevant international conventions 

and protocols relating to terrorism, including the most recent among 

them, and in strengthening international cooperation mechanisms 

in criminal matters related to terrorism, including through national 

capacity building. Reiterates General Assembly Resolution 60/288

with regard to terrorist financing.

Authors Note. As of June 2007, the UN had not passed any general

resolutions regarding terrorist financing.

2. INTERPOL 

2.1 General Assembly Resolutions

2.1.1. General Assembly Resolution AGN/67/RES/12, 1998. Declared 

that INTERPOL: a) strongly condemns all terrorist acts, methods, and 

practices as criminal and unjustifiable; b) supports the proposal to

organize, under the aegis of the UN, an international conference on 
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combating terrorism, with the aim of setting up, in close coordination with INTERPOL, a common international strategy for taking all 

appropriate prevention, protection, surveillance, and law enforcement 

measures and to prepare concrete proposals for more effective action 

in combating terrorism, its funding, and support networks; c) supports

the idea of implementing an international action plan to strengthen 

police and judicial cooperation between member countries by eliminating the obstacles which hinder the extradition of fugitive terrorists, the sharing of information, and the adoption of specific criminal

charges relating to the use of new technologies for terrorist purposes;

and d) feels it is necessary for all members to undertake the principle 

of international solidarity in the fight against terrorism.

2.1.2. General Assembly Resolution AGN/68/RES/2, 1999. States that 

the fight against international terrorism is one of the main aims of

INTERPOL’s action in carrying out its general activities of police cooperation. Strongly condemns all terrorist acts, methods, and practices as 

criminal and unjustifiable. Calls upon all INTERPOL member states to

refrain from financing, encouraging, or otherwise supporting terrorist

activities wherever and by whomever committed them. Supports all 

efforts to adopt the International Convention for the Suppression of 

Terrorist Financing at the 54th Session of the UN General Assembly,

including the use of INTERPOL as a channel for the exchange of information between law enforcement authorities. Recommended that the 

National Central Bureaus of member states facilitate the exchange, 

between their appropriate authorities, of information relating to the 

financing of terrorism within the framework to be provided by the

proposed UN Convention on the Financing of Terrorism.

Note

	 1.	 Data compiled by the author from the UN Web site available at www.

un.org (accessed 18 September 2006); INTERPOL Web site available at

www.interpol.int/ (accessed 18 September 2006), and based on government, industry, and various other research sources. 

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Appendix F. U.S. Laws, Federal Regulations, 

Federal Register Notices, and Miscellaneous 

Sources of DoD Authority1

1. U.S. Laws

A law is a binding custom or practice of a community, a rule of conduct 

or action prescribed or formally recognized as binding or enforced by a 

controlling authority. Law implies imposition by a sovereign authority and 

the obligation of obedience on the part of all subject to that authority.

1.1. United Nations Participation Act (UNPA) of 1945. Provides the basic 

authority for U.S. participation as a member of the UN organization. 

In particular, it is the authority for the President to apply economic 

and other sanctions against a target country or its nationals pursuant 

to mandatory decisions by the UN Security Council under Article 41

of the UN Charter. Until recently, this statutory authority was rarely 

invoked, but in current practice it has become a significant basis for

U.S. economic sanctions and the fight against terrorist financing.

1.2. Currency and Foreign Transactions Reporting Act of 1970. Commonly 

referred to as the Bank Secrecy Act (BSA) is the basic anti-moneylaundering statutes requiring the reporting of large cash transactions

and suspicious financial activities. The BSA requires banks (and

now a host of other financial institutions, including broker dealers,

credit card companies, insurance companies, and money service 

businesses) to understand, control, and report transactions that may 

have a questionable origin or purpose. Specifically, the act requires

financial institutions to keep records of cash purchases of negotiable

instruments, file reports of cash transactions exceeding $10,000 (daily

aggregate amount), and to report suspicious activity that might signify money laundering, tax evasion, or other criminal activities. The 

Treasury Department has statutory authority to administer the BSA 

and has delegated this authority to FinCEN. 

1.3. International Emergency Economic Powers Act (IEEPA), 1977. Grants 

the President authority to regulate a comprehensive range of commercial and financial transactions with another country in order to

deal with a threat to the national security, foreign policy, or economy 

of the U.S, if the President declares a national emergency. This has 

been the basis for economic sanctions since expiration of the Export 

Administration Act. The IEEPA falls under the provisions of the 

National Emergencies Act, which means that an emergency declared 
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under the act must be renewed annually to remain in effect, and can 

be terminated by Congressional legislation.

1.4. Antiterrorism and Effective Death Penalty Act (AEDPA), 1996. Title 

I amends federal habeas corpus law as it applies to both state and 

federal prisoners whether on death row or imprisoned for a term of 

years. Title II expands the circumstances under which foreign governments that support terrorism may be sued for resulting injuries 

and increases the assistance and compensation available to victims 

of terrorism. Title III is crafted to help sever international terrorists 

from their sources of financial and material support. It enlarges the

proscriptions against assisting in the commission of various terrorist crimes. It authorizes the regulation of fundraising by foreign 

organizations associated with terrorist activities. Title V adjusts the 

restrictions on possession and use of materials capable of producing 

catastrophic damage in the hands of terrorists. Additionally the act 

requires U.S. financial institutions in possession or control of funds

in which a foreign terrorist organization or its agent has an interest are required to block such funds and report on the funds to the

Treasury Department.

1.4.1. Section 302 of the AEDPA (Title 8 USC, section 1189). Authorizes 

the Secretary of State, in consultation with the Secretary of the Treasury and the Attorney General, to designate organizations meeting 

stated criteria as foreign terrorist organizations, with prior notification

to the Congress of the Secretary’s intent to designate.

1.4.2. Section 303 of the AEDPA (Title 18 USC, section 2339B). Makes it 

a crime for persons within the U.S. or subject to U.S. jurisdiction to 

knowingly provide material support or resources to a foreign terrorist 

organization designated under Section 302.

1.5. The Money Laundering and Financial Crimes Strategy Act, 1998.

Requires the President, acting through the Secretary of the Treasury

and in consultation with the Attorney General and other relevant 

federal, state, and local law enforcement and regulatory officials to

develop and submit an annual National Money Laundering Strategy 

to the Congress each year from 1999 through 2003. The initial strategy set forth a series of action designed to advance four fundamental 

goals in the fight against money laundering: a) strengthening domestic

enforcement, b) enhancing the measures taken by banks and other 

financial institutions, c) building stronger partnerships with state

and local governments, and d) bolstering international cooperation. 

The Act also authorized the Secretary of the Treasury to designate 

High Intensity Money Laundering and Related Financial Crime Areas 

(HIFCA), in which federal, state, and local law enforcement would work 
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cooperatively to develop a focused and comprehensive approach to 

targeting money-laundering activity.

1.6. Uniting and Strengthening America by Providing Appropriate Tools 

Required to Intercept and Obstruct Terrorism Act (USA Patriot Act), 

2001. Contains tools to enhance the U.S. ability to combat the financing of terrorism and money laundering. Title III of the USA Patriot 

Act concerns international money laundering abatement and antiterrorism financing. The Patriot Act adds additional burdens on banks

and brokerages to report suspicious activities and to compile data 

on customers, as well as expand forfeiture laws, restrict the ability 

of shell banks to do business in the U.S., and encourage information 

exchange between the government and private banks. The private 

banking industry serves as a front line of investigation regarding 

terrorist financing.

1.6.1. USA Patriot Act, Title III, International Money Laundering and 

Anti-Terrorist Financing Act, 2001. Supplied Treasury with a host of 

new and important weapons to both systematically eliminate known 

risks to the U.S. financial system as well as to identify and nullify

new risks that develop. 

1.6.2. USA Patriot Act, Title 31 USC, section 5332, Bulk Cash Smuggling. 

Makes it a crime to smuggle or attempt to smuggle over $10,000 in

currency or monetary instruments into or out of the U.S., with the 

specific intent to evade the U.S. currency-reporting requirements

codified at 31 USC 5316.

1.6.3. USA Patriot Act, section 311. Provides the Secretary of the Treasury 

with authority to require U.S. financial institutions to apply graduated,

proportionate countermeasures against a foreign jurisdiction, a foreign 

financial institution, a type of international transaction, or a type of

account that the Secretary finds to be a “primary money laundering

concern.” It also added a new section, 5318A, to the BSA.

1.6.4. USA Patriot Act, section 312. Requires U.S. financial institutions

that establish, maintain, administer, or manage a “private banking 

account” or a correspondent account for a non-U.S. person (including 

a foreign bank) to apply due diligence, and in some cases enhanced 

due diligence, procedures, and controls to detect and report instances 

of money laundering through those accounts.

1.6.5. USA Patriot Act, section 313. Prohibits U.S. banks, securities 

brokers, and dealers from maintaining correspondent accounts for 

foreign shell banks—that is, unregulated banks with no physical 

presence in any jurisdiction. Also requires financial institutions to

take reasonable steps to ensure that foreign banks with correspondent accounts do not themselves permit access to such accounts by 
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foreign shell banks. Adds subsection (j) to 31 USC section 5318 to

prohibit depository institutions and securities brokers and dealers 

operating in the U.S. from establishing, maintaining, administering, 

or managing correspondent accounts for foreign shell banks, other 

than shell bank vehicles affiliated with recognized and regulated

depository institutions.

1.6.6. USA Patriot Act, section 314(a). Encourages cooperation and the 

sharing of information relating to money laundering and terrorism 

among law enforcement authorities, regulatory authorities, and 

financial institutions

1.6.7. USA Patriot Act, section 314 (b). Upon notice to the Secretary of the 

Treasury, permits the sharing among financial institutions of information relating to individuals, entities, organizations, and countries 

suspected of possible terrorist or money laundering activities.

1.6.8. USA Patriot Act, section 318. Expands the definition of financial

institutions for purposes of 18 USC section 1956 and 1957 to include

those operating outside the U.S.

1.6.9. USA Patriot Act, section 319(b). Amended asset forfeiture law (18

USC section 981) and authorizes the Secretary of the Treasury or

the Attorney General to issue a summons or subpoena to any foreign 

bank that maintains a correspondent account in the U.S. requesting records relating to that correspondent account. Requires U.S.

financial institutions that maintain a correspondent account for a

foreign bank to keep records identifying a) the owners of the foreign 

bank and b) the name and address of a person in the U.S. who is 

authorized to accept service of legal process for records related to the 

correspondent account. 

1.6.10. USA Patriot Act, section 324. Requires the Secretary of the

Treasury, in consultation with the Attorney General and the federal functional regulators, to evaluate the operations of Title III and 

submit recommendations for legislative amendments that may be 

necessary.

1.6.11. USA Patriot Act, section 325. Authorizes the Secretary of the Treasury to issue regulations concerning the maintenance of concentration 

accounts by U.S. depository institutions to ensure such accounts 

are not used to prevent association of the identity of an individual 

customer with the movement of funds of which the customer is the 

direct or beneficial owner.

1.6.12. USA Patriot Act, section 326(a). Requires the Secretary of the

Treasury to promulgate minimum standards for financial institutions and their customers regarding the identity of the customer 

that must apply in connection with the opening of an account at a 
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financial institution. The minimum standards must require financial institutions to implement, and customers (after being given 

adequate notice) to comply with, reasonable procedures concerning verification of customer identity, maintenance of records for

identity verification, and consultation at account opening of lists

of known or suspect terrorists provided by a financial institution

by a government agency. 

1.6.13. USA Patriot Act, section 326(b). Requires the Secretary of the

Treasury, in consultation with the federal functional regulators (as well 

as other appropriate agencies), to submit a report to Congress within 

six months of the date of enactment containing recommendations 

about the most effective way to require foreign nationals to provide

financial institutions in the U.S. with accurate identity information

comparable to that required to be provided by U.S. nationals, and to

obtain an identification number that would function similarly to a

U.S. national’s Social Security or tax identification number.

1.6.14. USA Patriot Act, section 328. Requires the Secretary of the Treasury, in consultation with the Attorney General and the Secretary of 

State, to take reasonable steps to encourage foreign governments to 

include originator information in wire transfer instructions.

1.6.15. USA Patriot Act, section 352. Requires anti-money-laundering

programs, for all financial institutions.

1.6.16. USA Patriot Act, section 356(a). Directs the Secretary of the Treasury, in consultation with the Securities and Exchange Commission 

and the Board of Governors of the Federal Reserve, to prescribe regulations requiring securities broker-dealers to file suspicious activity

reports to the extent considered necessary and expedient.

1.6.17. USA Patriot Act, section 356 (b). Authorizes the Secretary, in 

consultation with the Commodity Futures Trading Commission, 

to prescribe regulations requiring futures commission merchants,

commodity trading advisors, and commodity pool operators to file

suspicious activity reports.

1.6.18. USA Patriot Act, section 356 (c). Requires the Secretary of the

Treasury, the Board of Governors of the Federal Reserve, and the 

Securities and Exchange Commission to submit jointly a report to 

Congress recommending ways to apply BSA requirements to investment companies.

1.6.19. USA Patriot Act, section 357. Requires the Secretary of the Treasury to submit a report to Congress on the role of the Internal Revenue 

Service (IRS) in the administration of the BSA.
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1.6.20. USA Patriot Act, section 358. Expanded Treasury’s ability to 

share BSA information with the intelligence community, clarified

that the Right to Financial Privacy Act does not preclude the use of 

financial information to combat international terrorism, and gave law

enforcement and intelligence agencies access to credit reports when 

the inquiry relates to international terrorism.

1.6.21. USA Patriot Act, section 359. Requires the Secretary of the Treasury to submit a report on the need for additional legislation relating 

to Agricultural Research Service. Clarifies that the BSA treats certain

underground banking systems and money transmitting businesses 

as financial institutions for purposes of the funds transfer recordkeeping and other anti-money-laundering rules. The Secretary of the 

Treasury must report to Congress by October 26, 2002 on the need for

additional legislation or regulatory controls relating to underground 

banking systems.

1.6.22. USA Patriot Act, section 360. Authorizes the Secretary of the 

Treasury to instruct the U.S. executive director of each international 

financial institution to use such Directors’ “voice and vote” to support

loans and other use of resources to benefit nations that the President

determines are contributing to U.S. efforts to combat international 

terrorism, and to require the periodic auditing of disbursements at

such international financial institutions to ensure that funds are not

paid to persons engaged in or supporting terrorism.

1.6.23. USA Patriot Act, section 361. Requires, to the extent considered

necessary and expedient, the Secretary of the Treasury to submit a 

report on improving compliance with the reporting (Report of Foreign 

Bank and Financial Accounts) requirements of section 5314 of Title

31, United States Code (USC).

1.6.24. USA Patriot Act, section 362. Requires the Secretary of the Treasury to establish a highly secure network within FinCEN for filing of

BSA reports.

1.6.25. USA Patriot Act, section 365. Requires nonfinancial trades or

businesses to file currency transaction reports with FinCEN. Provides

Treasury and law enforcement with access to currency reports filed

by nonfinancial trades or businesses, a form previously difficult to

obtain in light of IRS confidentiality restrictions.

1.6.26. USA Patriot Act, section 366. Requires, to the extent considered

necessary and expedient, the Secretary of the Treasury to report 

to Congress on whether to expand the existing exemptions to the 

requirement that financial institutions file currency transaction

reports and on methods for improving financial institution utilization

of exemptions.
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1.6.27. USA Patriot Act, section 371. Addresses the known risks associated with the smuggling of bulk cash and currency by making it an 

offense under Title 31 not to declare amounts in excess of $10,000

to the Customs Service.

1.6.28. USA Patriot Act, section 373. Amended 18 USC section 1960 to

prohibit unlicensed money services businesses. In addition, such 

businesses must file suspicious activity reports with law enforcement officials.

1.6.29. USA Patriot Act, section 377. Provides extraterritorial jurisdiction 

for the financial crimes committed abroad where the tools or proceeds

of the offense pass through or are in the U.S. (example given, the 

account issuer or credit card system). 

1.6.30. USA Patriot Act, section 411. U.S. persons are prohibited from 

having dealings and must block the assets within U.S. jurisdiction of 

terrorists and terrorist groups that are designated by the Departments 

of State and Treasury, and those who are owned or controlled by, acting 

for or on behalf of, or materially, financially, or technologically assisting designated terrorists, terrorist groups, or their supporters. 

1.7. Terrorism Risk Insurance Act (TRIA), 2002. Establishes a temporary federal program of shared public and private compensation for 

insured commercial property and casualty losses resulting from acts 

of terrorism covered by TRIA. The intent of TRIA was to stimulate 

business investment that had slowed to a trickle after the events of 

11 September 2001. The law creates a three-year federal program that

backs up insurance companies and guarantees that certain terroristrelated claims will be paid. On 22 December 2005, President Bush

signed into law the Terrorism Risk Insurance Extension Act of 2005,

which extends TRIA through 31 December 2007.

1.8. Intelligence Reform and Terrorism Prevention Act (IRTPA), 2004.

IRTPA consists of eight separate titles that address topics of vital interest to terrorism prosecutors and others engaged on the legal front of 

the war on terror. These topics include: a) reform of the intelligence 

community; b) improvements in the intelligence capabilities of the

FBI; c) revamping and uniformity of security clearance procedures;

measures to enhance transportation security; d) improvements in

border protection; e) immigration and visa procedures; f) new tools for

terrorism prosecutors; implementation of 9/11 Commission Recommendations; g) establishment of interagency mechanisms concerning

information and intelligence sharing, infrastructure protection and 

analysis, and civil rights and civil liberties; and h) established both

the position of DNI and the NCTC. 
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1.9. Combating Terrorism Financing Act, 2005. Has been brought to 

Congress two times but has never become law. Would amend: a) the 

International Emergency Economic Powers Act to increase penalties for violating a license, order, or regulation under the Act; b) the

Racketeer Influenced and Corrupt Organizations Act (RICO) to expand

its scope to include offenses relating to the financing of terrorism

and violations of the Social Security Act relating to obtaining funds 

through the misuse of a Social Security number; c) the federal criminal

code to: (i) provide for civil forfeiture to the U.S. of the assets of any 

individual or organization engaged in planning or perpetrating an act 

of international terrorism against any international organization or 

foreign government and (ii) establish procedures for contesting the 

confiscation of assets of suspected international terrorists; and d)

RICO to make receiving military-type training from a foreign terrorist organization a predicate offense to violation of money laundering 

provisions. Authorizes DHS to investigate violations of money laundering and related offenses.

1.10. Foreign Intelligence Surveillance Act (FISA), 1978. Was passed to 

produce legal guidelines for federal investigations of foreign intelligence targets. Among the rules put in place were regulations governing: a) electronic surveillance, b) physical searches, c) pen registers 

and trap and trace devices for foreign intelligence purposes, and d) 

access to certain business records for foreign intelligence purposes. 

In addition to defining how foreign intelligence investigations were

to be performed, FISA also defined who could be investigated. Only

foreign powers or agents of foreign powers were to be subject to FISA 

investigations. Thus, targets are primarily those foreign persons who 

are engaged in espionage or international terrorism. 

1.11. Public Law 102-138 section 304 as amended by Public Law 103-236 

(22 USC section 2656g). Requires Treasury to submit the Terrorist

Assets Reports to the Committee on Foreign Relations and the Committee on Finance of the Senate and to the Committee on International 

Relations and the Committee on Ways and Means of the House.

2. Federal Regulations

Rules or orders issued by an executive authority or regulatory agency of 

a government and having the force of law.

2.1. United States Code (USC). Is the codification by subject matter of

the general and permanent laws of the U.S. It is divided by broad 

subjects into 50 titles and published by the Office of the Law Revision Counsel of the U.S. House of Representatives. Since 1926, the

USC has been published every six years. In between editions, annual 
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cumulative supplements are published in order to present the most 

current information. USC are laws made by the U.S. Congress. 

2.1.1. Title 18 USC section 1956. Makes it illegal to: a) conduct or attempt to 

conduct a financial transaction with proceeds known to be from specified unlawful activity, b) transport or attempt to transport monetary

instruments or funds to or from the U.S., and c) conduct or attempt to 

conduct a financial transaction involving property a law enforcement

officer represents to be the proceeds of specified unlawful activity or

property used to conduct or facilitate specified unlawful activity. The

criminalization of money laundering was largely in response to the 

massive amounts of money exchanging hands and sifting through 

American financial institutions as a product of the illegal trade of

narcotics. Clearly, with the Patriot Act’s amplified reporting and due

diligence requirements, Congress has intended to provide a means

to conduct additional financial analysis as part of a counterterrorist

financing regime.

2.1.2. Title 18 USC section 1957. Makes it illegal knowingly to engage 

or attempt to engage in a monetary transaction involving property 

valued at more than $10,000 if it is derived from specified unlawful

activity.

2.1.3. Title 18 USC section 2331(1). The term international terrorism

means activities that: a) involve violent acts or acts dangerous to 

human life that are a violation of the criminal laws of the U.S or of 

any state, or that would be a criminal violation if committed within 

the jurisdiction of the U.S or of any state; b) appear to be intended:

(i) to intimidate or coerce a civilian population; (ii) to influence the

policy of a government by intimidation or coercion; or (iii) to affect

the conduct of a government by mass destruction, assassination, or 

kidnapping; and c) occur primarily outside the territorial jurisdiction

of the U.S. or transcend national boundaries in terms of the means 

by which they are accomplished, the persons they appear intended to 

intimidate or coerce, or the locale in which their perpetrators operate 

or seek asylum. 

2.1.4. Title 18 USC section 2331(5). The term “domestic terrorism” means 

activities that: a) involve acts dangerous to human life that are a violation of the criminal laws of the U.S. or of any state; b) appear to be

intended to: (i) intimidate or coerce a civilian population; (ii) influence

the policy of a government by intimidation or coercion; or (iii) affect

the conduct of a government by mass destruction, assassination, or 

kidnapping; and c) occur primarily within the territorial jurisdiction

of the U.S.
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2.1.5. Title 18 USC section 2339A. Generally used in conjunction with 

18 USC section 1956, section 2339A pertains to providing material

support or resources for acts of international terrorism (conspiracies 

within the United States to kill/maim persons and destroy specific

property abroad). 

2.1.6. Title 18 USC section 2339B. States whoever knowingly provides 

material support or resources to a foreign terrorist organization, 

or attempts or conspires to do so, shall be fined under this title or

imprisoned not more than 15 years, or both, and, if the death of any

person results, shall be imprisoned for any term of years or for life. 

Except as authorized by the Secretary, any financial institution that

becomes aware that it has possession of, or control over, any funds 

in which a foreign terrorist organization, or its agent, has an interest, 

shall: a) retain possession of, or maintain control over, such funds and 

b) report to the Secretary the existence of such funds in accordance 

with regulations issued by the Secretary. Generally used in conjunction with 18 USC section 1956.

2.1.7. Title 22 USC section 2656f(d). The term ‘terrorism’ means premeditated, politically motivated violence perpetrated against noncombatant 

targets by subnational groups or clandestine agents, usually intended 

to influence an audience.

2.1.8. Title 31 USC section 5318 (k). Was codified by section 319(b) of the

USA Patriot Act, states any covered financial institution that maintains

a correspondent account in the U.S. for a foreign bank must maintain 

records in the U.S. identifying: a) the owner(s) of such foreign bank 

and b) the name and address of a person (as defined in 31 Code of

Federal Regulation section 103.11(z)) who resides in the U.S. and is

authorized to accept service of legal process for records concerning 

the correspondent account.

2.2. Code of Federal Regulations (C.F.R.). Is the codification of the general and permanent rules published in the federal regulations. by the 

executive departments and agencies of the USG. It is divided into 50 

titles that represent broad areas subject to federal regulation. Each 

volume of the C.F.R. is updated once each calendar year and is issued 

on a quarterly basis.

2.2.1. 31 C.F.R., Chapter 5, Part 594. Covers various Global Terrorism 

Sanctions Regulations (Part 594.101–594.901) from relation of this part

to other laws and regulations to paperwork reduction act notice.

2.2.2. 31 C.F.R., Chapter 5, Part 595. Covers various Terrorism Sanctions 

Regulations (Subpart A (595.101)–Subpart I (595.901)) from relation

of this part to other laws and regulations to Paperwork Reduction 

Act notice.
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2.2.3. 31 C.F.R., Chapter 5, Part 596. Covers various Terrorism List 

Governments Sanctions Regulations (Subpart A (596.101)–Subpart

I (596.901)) from relation of this part to other laws and regulations

to Paperwork Reduction Act notice.

2.2.4. 31 C.F.R., Chapter 5, Part 597. Covers various Foreign Terrorist 

Organizations Sanctions Regulations (Subpart A (597.101)–Subpart

I (597.901)) from relation of this part to other laws and regulations

to Paperwork Reduction Act notice.

2.3. Executive Orders (EOs). Most EOs are issued by the President to 

U.S. executive officers to help direct their operation, with the result

of failing to comply being removal from office. Some orders do have

the force of law when made in pursuance of certain Acts of Congress 

due to those acts giving the President discretionary powers. Other 

types of EOs are: a) National Security Directives, b) Homeland Security 

Presidential Directives, and c) Presidential Decision Directives, which 

deal with national security and defense matters. 

2.3.1. EO 12947, 1995. Prohibits transactions with terrorists who threaten 

to disrupt the Middle East Peace Process. Prohibits transfers, including 

donations of funds, goods, or services, to any organization or individual 

designated under its authority and blocks all property in the U.S. or 

within the possession or control of a U.S. person in which there is 

an interest of any designated person. Twelve terrorist organizations 

were named in the Annex to E.O. 12947.

2.3.2. EO 13099, 1998. Prohibits transactions with terrorists who threaten 

to disrupt the Middle East Peace Process (Tab 6), to amend EO 12947

by adding three individuals and one organization to the Annex of EO 

12947, including Osama bin Muhammad bin Awad bin Laden (also

known as Osama bin Laden) and Al Qaeda.

2.3.3. EO 13129, 1999. States that the actions and policies of the Taliban 

in Afghanistan, in allowing territory under its control in Afghanistan to 

be used as a safe haven and base of operations for Osama bin Laden 

and the Al Qaeda organization who have committed and threaten to 

continue to commit acts of violence against the U.S. and its nationals, 

constitute an unusual and extraordinary threat to the national security and foreign policy of the U.S., and declared a national emergency 

to deal with that threat.

2.3.4. EO 13224, 2001. Designation under this order results in assetblocking and a prohibition on transactions with the designated individual or entity. This EO expands the U.S. power to target the support 

structure of terrorist organizations, freeze the U.S. assets and block 

the U.S. transactions of terrorists and those that support them, and 

increases the ability to block U.S. assets of, and deny access to U.S. 
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markets to, foreign banks who refuse to cooperate with U.S. authorities to identify and freeze terrorist assets abroad. This order directed 

the Secretary of the Treasury, in consultation with the Secretary 

of State and the Attorney General, to deny financing and financial

services to terrorists and terrorist organizations. The executive order 

authorizes the blocking of assets of those designated individuals and 

organizations linked to global terrorism. It also prohibits transactions with designated terrorist groups, leaders, and corporate and 

charitable fronts.

2.3.5. EO 13268, 2002. States that the situation that gave rise to the 

declaration of a national emergency in EO 13129, with respect to the

Taliban, in allowing territory under its control in Afghanistan to be 

used as a safe haven and base of operations for Osama bin Laden 

and the Al Qaeda organization, has been significantly altered, thus

allowing the revocation of EO 13129 and terminating the national

emergency declared in that order with respect to the Taliban. In 

addition it amends section 1 of EO 13224 by including the name of

Mohammed Omar.

2.3.6. EO 13372, 2005. Clarifies the steps taken in EO 12947 with

respect to the implementation of section 203(b)(2) of IEEPA. Amends

section 4 of EO 13224 to state that it prohibit donations as provided

by section 1 of EO 12947 and that the Trade Sanctions Reform and

Export Enhancement Act of 2000 shall not affect the imposition or

the continuation of the imposition of any unilateral agricultural sanction or unilateral medical sanction on any person determined to be 

subject to this order. 

3. Federal Register Notices (FRs)

Published by the Office of the Federal Register, National Archives and

Records Administration (NARA), the Federal Register is the official daily

publication for rules, proposed rules, and notices of federal agencies and 

organizations, as well as EOs and other presidential documents. 

3.1. 71 FR 27199-06, 2006. Covers the Treasury Department’s, Office

of Foreign Assets Control (OFAC) revisions to the Global Terrorism 

Sanctions Regulations, the Terrorism Sanctions Regulations, and 

the Foreign Terrorist Organizations Sanctions Regulations to add 

general licenses authorizing certain transactions with the Palestinian Authority (PA). 

3.2. 71 FR 29251-06, 2006. Covers the Treasury Department’s, OFAC 

revisions to its regulations in order to reflect amendments to the

International Emergency Economic Powers Act (IEEPA) made by the 

Combating Terrorism Financing Act of 2005.
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3.3. 71 FR 58742-06, 2006. Covers OFAC of the U.S. Department of the 

Treasury revisions to the Global Terrorism Sanctions Regulations, the 

Terrorism Sanctions Regulations, and the Foreign Terrorist Organizations Sanctions Regulations to authorize in kind donations of medical 

devices and medical services by U.S. nongovernmental organizations 

to the PA Ministry of Health.

4. Miscellaneous Sources of DoD Authority

As stated in Chapter 1, currently DoD has no defined authorities under

U.S. law and regulations nor does DoD have an overarching policy that 

supports threat finance. However, DoD derives its roles and responsibilities from the following strategies, plans, execution orders, and assessments.

4.1. National Strategy for Combating Terrorism (NSCT), 2006. Builds 

directly from the National Security Strategy issued in March 2006 as

well as the 2003 National Strategy for Combating Terrorism. It focuses

on: a) advancing effective democracies as the long-term antidote to 

the ideology of terrorism, b) preventing attacks by terrorist networks, 

c) denying weapons of mass destruction to rogue states and terrorist allies, d) denying terrorists the support and sanctuary of rogue 

states, e) denying terrorists control of any nation they would use as 

a base or launching pad, and f) laying the foundations and building 

the institutions and structures the U.S. needs to carry the fight forward against terror. With regard to disrupting terrorist financing it

focuses on cutting off individuals and institutions from the networks 

they depend on for support and that facilitate their activities, and it 

acknowledges that the effective disruption of funding sources, interdiction of transfer mechanisms, and strengthening allies can help 

the U.S. and its partners starve terrorist networks of the material 

support they require.

4.2. National Military Strategic Plan for the War on Terrorism (NMSP-WOT), 

2006. Constitutes the comprehensive unified military plan to prosecute the Global War on Terrorism for the Armed Forces of the United 

States...including the findings and recommendations of the 9/11

Commission and a rigorous examination within the DoD. The plan 

emphasizes “encouraging” and “enabling” foreign partners, especially 

in countries where the U.S. is not at war and concludes that the conflict cannot be fought by military means alone—or by the U.S. acting

alone. The plan formally directs military commanders to go after a list 

of eight pressure points at which terrorist groups could be vulnerable: 

ideological support, weapons, funds, communications and movement, 

safe havens, foot soldiers, access to targets, and leadership. The plan’s 
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No. 1 stated objective is to deny terrorists the resources they need to

operate and survive and identifies resources as a critical requirement

for terrorist organizations.

4.3. National Implementation Plan (NIP). Classified

4.4. Global War On Terrorism Campaign Plan. Classified

4.5. Joint Intelligence Operations Center Execution Order. Classified

4.6. Global War on Terrorism Assessment June 05 MSO-1. Classified

4.7. National Action Plan for Foreign Fights. Classified

4.8. Disrupting External Funding to the Taliban (DEFT). Classified

4.9. Moving from Terrorist Finance to Threat Finance. Classified

4.10. Terrorist Finance Sub-CSG TIFWG. Classified

Note

	 1.	 Adapted by the author based on the work of Jeff Breinholt, “Counterterrorism Enforcement: A Lawyer’s Guide,” Office of Legal Education,

2004, 1-285 and the author’s analysis based on government, industry,

and various other research sources. 
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Appendix G: Worldwide Information 

and Intelligence Network (WIIN)

One of the keys to success in the effort to disrupt terrorist organizations 

is the ability of IA, law enforcement, private sector, allies, and partner 

nations to conduct integrated and collaborative efforts over a network, 

such as the proposed WIIN, which is secure, flexible, and allows for

timely passage of information, while being robust enough to meet evolving 

command, control, communications, and computer requirements. While

the author is providing an example architecture (WIIN) to facilitate his 

recommendation, in the end it is not the exact architecture that matters. 

What is important, however, is establishing a collaborative and integrated 

network that is predicated on a need to share mind set.

The WIIN would provide the following base capabilities at all nodes: 

a) file sharing and transfer. b) e-mail. c) Web-conferencing using voice

over Internet protocol. and d) chat/instant messaging. To support WIIN, 

a comprehensive Web-based information management (IM) system would 

need to be developed and maintained by a U.S. central management 

authority. The IM system would allow information to be published and 

compartmentalized as required. In addition, the network would provide

a clear understanding of the enemy threat through a Common Operating 

Picture (COP).

All communication systems used in WIIN would comply with National 

Security Agency (NSA) and Communications Security Establishment (CSE) 

standards for Type 1 encryption. Contingency electronic KEYMAT fills

could be generated and prepared for use with allies and partner nation 

activities.

Network Architecture

Initially, WIIN would provide a common command and control network 

available to IA, law enforcement, private sector, allies, and partner nations 

complementing existing national networks. As WIIN evolves, it would 

become the common link to optimize network resources and information sharing. The network would support both fixed sites and deployable

elements. A transit case communications package would be designed to 

support deployable elements. The Internet would be used as the transport backbone, and all traffic from site to site would be encrypted in

accordance with National Security Agency (NSA) guidelines using Type 

1 encryption devices.159

Server Enclave. All network services—except Domain Name Service (DNS) 

and Windows Internet Naming Service (WINS)—would be centralized at 

the server enclave. Server virtualization would be incorporated to reduce 
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the rack space, power, and HVAC (heating, ventilation, and air conditioning) footprints. An emission control (EMC) fiber channel Storage Area

Network (SAN) would be used for data storage. The server enclave would 

have connectivity to the Internet via two 10 Mbps Internet Protocol (IP)

connections.

Fixed Site Enclave. Each fixed site would consist of client machines and

one DNS/WINS server connected via fiber to an Ethernet switch/Dynamic

Host Configuration Protocol (DHCP) server. The switch is connected to

the red side of the KG-250. The black side of the KG-250 is connected to

a Cisco 3251 Home Agent router. The Home Agent router is connected to

another Cisco router. Finally, the Cisco router is connected to the Internet 

via commercial carrier. The red side of each fixed site would be assigned

its own class C network of IP addresses.

Deployable Enclave. Deployable enclaves must have the ability/flexibility

to connect to the Internet in several different ways. They must be able 

to connect via a standard Internet service provider (ISP), or if there is no 

ISP available, they must be able to access the Internet via other means, 

such as INMARSAT or satellite communications (SATCOM) connection. 

The concept of operations for the deployed element incorporates the use 

of mobile routers. Mobile routers allow the deployed element to operate 

identically in garrison and deployed environments. There are several 

advantages to this. It simplifies the setup and configuration of the workstations, since they use the same setup in garrison and deployed. It also 

Figure G-1. Network Topology 
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allows the computers to continue to be connected to the network when not 

deployed to receive required patches and updates. This ensures that the

machines are fully functional when deployed. The mobile router receives 

an IP address from an ISP or other provider, then translates that into 

the static IP range used on the internal side of the network. The mobile 

Figure G-2. Server Enclave 

Figure G-3. Fixed Site Enclave
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router requires the addition of a host-agent router at the fixed site. The

host agent acts as an edge router, directing traffic to the mobile users

and receiving and verifying information coming from the mobile router 

before sending it to the crypto equipment for decryption.

Network Services Architecture. All network services would be Web-based 

and secure sockets layer (SSL)-enabled originating from a centralized 

Figure G-5. Deployable Enclave with INMARSAT Connection

Figure G-4. Deployable Enclave with Direct Internet Connection
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location. Because all services are Web-based, there is no need for the 

machines in the enclaves to be part of the active-directory domain. This 

reduces the amount of traffic (machines do not have to authenticate to

the directory), thereby giving more bandwidth to user-required application

data. This architecture also requires very little systems administration

support at user enclaves. Both the Primary and Continuity of Operations 

(COOP) enclaves take advantage of server virtualization to reduce power, 

cooling, and the physical footprint of the servers.

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Appendix H. Acronyms and Terms

Acronyms

AML.............. Anti-Money Laundering

CIA............... Central Intelligence Agency

CSA.............. Combat Support Agencies

CSG.............. Counterterrorism Security Group, NSC

DHS ............. Department of Homeland Security

DoD.............. Department of Defense

DoJ .............. Department of Justice

DoS .............. Department of State

EO................ Executive Order

FATF............. Financial Action Task Force

FBI ............... Federal Bureau of Investigation

FinCEN......... Financial Crimes Enforcement Network, Treasury Department

FIU ............... Financial Intelligence Unit

FTO .............. Foreign Terrorist Organizations

GWOT........... Global War on Terrorism

IC ................. Intelligence community

IEEPA........... International Emergency Economic Powers Act

ILEA ............. International Law Enforcement Agency

IMF............... International Monetary Fund

INL ............... The Bureau of International Narcotics and Law Enforcement 

Affairs, DoS

INTERPOL .... The International Criminal Police Organization

JTTF............. Joint Terrorism Task Force

NCTC............ National Counterterrorism Center, IA, ODNI

NSC.............. National Security Council

S/CT ............ The Office of the Coordinator for Counterterrorism, DoS

TFEU............ Threat Financing Exploitation Unit, DoD

USC.............. United States Code

USG.............. United States Government

WMD/E ........ Weapons of Mass Destruction/Effects 

Terms

Bayat. An oath of allegiance to an emir.

Chain or Line Networks. Are simple structures, often used, for example, by 

smugglers. Information or goods move in a linear direction from one 

node to the next. Each contact knows his or her next contact, but can 

identify no one beyond that next contact.
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Combating Terrorism. Defined by NMSP-WOT as actions, including antiterrorism (defensive measures taken to reduce vulnerability to terrorist 

acts) and counterterrorism (offensive measures taken to prevent, deter, 

and respond to terrorism), taken to oppose terrorism throughout the 

entire threat spectrum.

Deter. Defined by NMSP-WOT as actions taken to disrupt, prevent, or preclude

acts of aggression. Deter includes preemptive actions to unhinge the 

ability to conduct operations.

Disrupt. Defined by NMSP-WOT as actions taken to interrupt, temporarily

prevent, or desynchronize a terrorist network’s capability to conduct 

operations.

Full Matrix Network. Is the most highly-developed network based on the 

fact that all of its members are connected to, and can communicate 

with, all other members.

Hawala. A means outside of traditional banking for moving money across 

borders.

Informal Value Transfer. Any system or network of people facilitating, on a 

full-time or part-time basis, the transfer of value domestically or internationally outside the conventional, regulated financial institutional

systems.

Mitigate. To cause to become less harsh or hostile, to make less severe or 

painful. In relation to an effect, mitigate means to lessen or eliminate 

the severity or incidence of an effect.

Money Service Business. Has been defined by FinCEN as check cashers,

traveler’s check sellers, currency exchangers, stored value sellers, and 

money transmitters.

String. A sequentially ordered set of things or events or ideas in which each

successive member is related to the preceding members; “a string of

islands,” “train of mourners,” “a train of thought.”

Terrorist Financing. Is defined as the financial support, in any form, of terrorism or of those who encourage, plan, or engage in it.