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STOPPING THE MONEY FLOW:

THE WAR ON TERROR FINANCE

JOINT HEARING

BEFORE THE

SUBCOMMITTEE ON TERRORISM, 

NONPROLIFERATION, AND TRADE

OF THE

COMMITTEE ON FOREIGN AFFAIRS

AND THE

SUBCOMMITTEE ON EMERGING THREATS AND 

CAPABILITIES

OF THE

COMMITTEE ON ARMED SERVICES 

HOUSE OF REPRESENTATIVES

ONE HUNDRED FOURTEENTH CONGRESS

SECOND SESSION

JUNE 9, 2016

Serial No. 114–188 H.A.S.C. No. 114–125

(Committee on Foreign Affairs) (Committee on Armed Services)

Printed for the use of the Committee on Foreign Affairs and the

Committee on Armed Services

(

Available via the World Wide Web: http://www.foreignaffairs.house.gov/ or

http://www.gpo.gov/fdsys/

(II)

COMMITTEE ON FOREIGN AFFAIRS 

EDWARD R. ROYCE, California, Chairman 

CHRISTOPHER H. SMITH, New Jersey 

ILEANA ROS-LEHTINEN, Florida 

DANA ROHRABACHER, California 

STEVE CHABOT, Ohio 

JOE WILSON, South Carolina 

MICHAEL T. MCCAUL, Texas 

TED POE, Texas 

MATT SALMON, Arizona 

DARRELL E. ISSA, California 

TOM MARINO, Pennsylvania 

JEFF DUNCAN, South Carolina 

MO BROOKS, Alabama 

PAUL COOK, California 

RANDY K. WEBER SR., Texas 

SCOTT PERRY, Pennsylvania 

RON DESANTIS, Florida 

MARK MEADOWS, North Carolina 

TED S. YOHO, Florida 

CURT CLAWSON, Florida 

SCOTT DESJARLAIS, Tennessee 

REID J. RIBBLE, Wisconsin 

DAVID A. TROTT, Michigan 

LEE M. ZELDIN, New York 

DANIEL DONOVAN, New York 

ELIOT L. ENGEL, New York 

BRAD SHERMAN, California 

GREGORY W. MEEKS, New York 

ALBIO SIRES, New Jersey 

GERALD E. CONNOLLY, Virginia 

THEODORE E. DEUTCH, Florida 

BRIAN HIGGINS, New York 

KAREN BASS, California 

WILLIAM KEATING, Massachusetts 

DAVID CICILLINE, Rhode Island 

ALAN GRAYSON, Florida 

AMI BERA, California 

ALAN S. LOWENTHAL, California 

GRACE MENG, New York 

LOIS FRANKEL, Florida 

TULSI GABBARD, Hawaii 

JOAQUIN CASTRO, Texas 

ROBIN L. KELLY, Illinois 

BRENDAN F. BOYLE, Pennsylvania

AMY PORTER, Chief of Staff THOMAS SHEEHY, Staff Director

JASON STEINBAUM, Democratic Staff Director 

SUBCOMMITTEE ON TERRORISM, NONPROLIFERATION, AND TRADE

TED POE, Texas, Chairman 

JOE WILSON, South Carolina 

DARRELL E. ISSA, California 

PAUL COOK, California 

SCOTT PERRY, Pennsylvania 

REID J. RIBBLE, Wisconsin 

LEE M. ZELDIN, New York 

WILLIAM KEATING, Massachusetts 

BRAD SHERMAN, California 

BRIAN HIGGINS, New York 

JOAQUIN CASTRO, Texas 

ROBIN L. KELLY, Illinois 

(III)

COMMITTEE ON ARMED SERVICES 

WILLIAM M. ‘‘MAC’’ THORNBERRY, Texas, Chairman

WALTER B. JONES, North Carolina 

J. RANDY FORBES, Virginia 

JEFF MILLER, Florida 

JOE WILSON, South Carolina 

FRANK A. LOBIONDO, New Jersey 

ROB BISHOP, Utah 

MICHAEL R. TURNER, Ohio 

JOHN KLINE, Minnesota 

MIKE ROGERS, Alabama 

TRENT FRANKS, Arizona 

BILL SHUSTER, Pennsylvania 

K. MICHAEL CONAWAY, Texas 

DOUG LAMBORN, Colorado 

ROBERT J. WITTMAN, Virginia 

DUNCAN HUNTER, California 

JOHN FLEMING, Louisiana 

MIKE COFFMAN, Colorado 

CHRISTOPHER P. GIBSON, New York 

VICKY HARTZLER, Missouri 

JOSEPH J. HECK, Nevada 

AUSTIN SCOTT, Georgia 

MO BROOKS, Alabama 

RICHARD B. NUGENT, Florida 

PAUL COOK, California 

JIM BRIDENSTINE, Oklahoma 

BRAD R. WENSTRUP, Ohio 

JACKIE WALORSKI, Indiana 

BRADLEY BYRNE, Alabama 

SAM GRAVES, Missouri 

RYAN K. ZINKE, Montana 

ELISE M. STEFANIK, New York 

MARTHA MCSALLY, Arizona 

STEPHEN KNIGHT, California 

THOMAS MACARTHUR, New Jersey 

STEVE RUSSELL, Oklahoma 

ADAM SMITH, Washington 

LORETTA SANCHEZ, California 

ROBERT A. BRADY, Pennsylvania 

SUSAN A. DAVIS, California 

JAMES R. LANGEVIN, Rhode Island 

RICK LARSEN, Washington 

JIM COOPER, Tennessee 

MADELEINE Z. BORDALLO, Guam 

JOE COURTNEY, Connecticut 

NIKI TSONGAS, Massachusetts 

JOHN GARAMENDI, California 

HENRY C. ‘‘HANK’’ JOHNSON, JR., Georgia 

JACKIE SPEIER, California 

JOAQUIN CASTRO, Texas 

TAMMY DUCKWORTH, Illinois 

SCOTT H. PETERS, California 

MARC A. VEASEY, Texas 

TULSI GABBARD, Hawaii 

TIMOTHY J. WALZ, Minnesota 

BETO O’ROURKE, Texas 

DONALD NORCROSS, New Jersey 

RUBEN GALLEGO, Arizona 

MARK TAKAI, Hawaii 

GWEN GRAHAM, Florida 

BRAD ASHFORD, Nebraska 

SETH MOULTON, Massachusetts 

PETE AGUILAR, California

ROBERT L. SIMMONS II, Staff Director

SUBCOMMITTEE ON EMERGING THREATS AND CAPABILITIES 

JOE WILSON, South Carolina, Chairman

JOHN KLINE, Minnesota 

BILL SHUSTER, Pennsylvania 

DUNCAN HUNTER, California 

RICHARD B. NUGENT, Florida 

RYAN K. ZINKE, Montana 

TRENT FRANKS, Arizona, Vice Chair

DOUG LAMBORN, Colorado 

MO BROOKS, Alabama 

BRADLEY BYRNE, Alabama 

ELISE M. STEFANIK, New York 

JAMES R. LANGEVIN, Rhode Island 

JIM COOPER, Tennessee 

JOHN GARAMENDI, California 

JOAQUIN CASTRO, Texas 

MARC A. VEASEY, Texas 

DONALD NORCROSS, New Jersey 

BRAD ASHFORD, Nebraska 

PETE AGUILAR, California 

PETER VILLANO, Professional Staff Member 

LINDSAY KAVANAUGH, Professional Staff Member 

(V)

C O N T E N T S 

Page

WITNESSES 

The Honorable Daniel Glaser, Assistant Secretary for Terrorist Financing, 

U.S. Department of the Treasury ....................................................................... 6

Mr. Andrew Keller, Deputy Assistant Secretary for Counter Threat Finance 

and Sanctions, Bureau of Economic and Business Affairs, U.S. Department 

of State .................................................................................................................. 18

Ms. Theresa Whelan, Acting Assistant Secretary for Special Operations/Low 

Intensity Conflict, U.S. Department of Defense ................................................ 30

Mr. William Woody, Chief of Law Enforcement, U.S. Fish and Wildlife Service .......................................................................................................................... 39

LETTERS, STATEMENTS, ETC., SUBMITTED FOR THE HEARING 

The Honorable Daniel Glaser: Prepared statement .............................................. 9

Mr. Andrew Keller: Prepared statement ............................................................... 20

Ms. Theresa Whelan: Prepared statement ............................................................ 32

Mr. William Woody: Prepared statement .............................................................. 41

APPENDIX 

Hearing notice .......................................................................................................... 62

Hearing minutes ...................................................................................................... 63

Mr. William Woody: Material submitted for the record ....................................... 64

Written responses from the Honorable Daniel Glaser to questions submitted 

for the record by: 

The Honorable Ted Poe, a Representative in Congress from the State of 

Texas, and chairman, Subcommittee on Terrorism, Nonproliferation, and 

Trade ................................................................................................................. 72

The Honorable William Keating, a Representative in Congress from the 

Commonwealth of Massachusetts ................................................................... 76

The Honorable Scott Perry, a Representative in Congress from the Commonwealth of Pennsylvania ............................................................................. 77

Written responses from Mr. Andrew Keller to questions submitted for the 

record by: 

The Honorable Ted Poe ....................................................................................... 78

The Honorable William Keating ......................................................................... 88

The Honorable Paul Cook, a Representative in Congress from the State 

of California ...................................................................................................... 89

The Honorable Scott Perry .................................................................................. 91

Written responses from Ms. Theresa Whelan to questions submitted for the 

record by: 

The Honorable James E. Langevin, a Representative in Congress from 

the State of Rhode Island ................................................................................ 93

The Honorable Doug Lamborn, a Representative in Congress from the 

State of Colorado .............................................................................................. 95

Written responses from Mr. William Woody to questions submitted for the 

record by the Honorable Ted Poe and the Honorable James E. Langevin ...... 98

(1)

STOPPING THE MONEY FLOW:

THE WAR ON TERROR FINANCE 

THURSDAY, JUNE 9, 2016

HOUSE OF REPRESENTATIVES,

SUBCOMMITTEE ON TERRORISM, NONPROLIFERATION, AND TRADE,

COMMITTEE ON FOREIGN AFFAIRS,

SUBCOMMITTEE ON EMERGING THREATS AND CAPABILITIES,

COMMITTEE ON ARMED SERVICES,

Washington, DC. 

The subcommittees met, pursuant to notice, at 2:10 p.m., in room 

2118, Rayburn House Office Building, Hon. Ted Poe (chairman of 

the Subcommittee on Terrorism, Nonproliferation, and Trade) presiding. 

Mr. POE. The subcommittees will come to order. 

Without objection, all members may have 5 days to submit statements, questions, and extraneous materials for the record, subject 

to the length limitation and the rules. 

I recognize myself for the opening statement. 

Time and time again, we are reminded of the massive damage 

that terrorists cause even with just a little money. Today, terrorist 

groups have more money than some small countries. ISIS is the 

richest terrorist organization in world history, bringing in over $1 

billion in 2014 alone. 

Drawing on these funds, ISIS has managed to stage terrorist attacks throughout the world and kill thousands of people. ISIS is 

not alone. Terrorists raise billions annually to carry out their 

bloody agendas. This is precisely why our Government agencies 

have been tasked with stemming the flow of money to terrorist 

groups. When we can separate the terrorists from their money, 

lives can be saved. 

According to the Treasury Department, the underlying 

vulnerabilities within the U.S. financial system today ‘‘remain 

largely the same as those identified in 2005.’’ Terrorists are still 

able to park and move cash through financial systems. 

Part of the problem is that the United States still does not have 

a comprehensive strategy across all American agencies to combat 

terrorist financing. Policies and priorities differ from one agency to 

the next in a seemingly ad hoc fashion. In fact, there isn’t even a 

clear method by which our various agencies can coordinate their efforts. Agencies working on counterterrorist finance had previously 

coordinated through the Terrorist Financing Working Group. HowVerDate 0ct 09 2002 10:48 Aug 24, 2016 Jkt 000000 PO 00000 Frm 00007 Fmt 6633 Sfmt 6633 F:\WORK\_TNT\060916\20383 SHIRL
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ever, this working group has been on a hiatus for some time and 

agencies are forced to coordinate informally. 

Another tool to counter terrorist financing that hasn’t been used: 

Designation of domestic charities. According to the Treasury Department’s Web site, the United States has not blacklisted any 

charities since the February 2009 designation of the Tamil Foundation. There are also nonconcrete metrics in place to measure the effectiveness of counterterrorist finance efforts, making it difficult to 

determine the need and appropriate tools required for a successful 

strategy. 

For instance, the counter-ISIL finance cell was established in 

late 2014 to work on intelligence collection and operations to cut 

off ISIS’ financing. The administration says that the cell has significantly improved our understanding of ISIS’ financial activity. 

This is a start, but what are the cell’s metrics of success? What are 

its goals, and how do we know if it is doing a good job? 

Beyond its own government efforts, we still have a long way to 

go when it comes to collaborating with our international partners 

to counter terror finance, to ensure our efforts are not fragmented, 

and that our respective skills and intelligence are leveraged correctly. 

Sometimes our international partners seem to be doing exactly 

the opposite of what our policy is. According to U.S. Government 

figures, terrorist groups earned over $165 million between 2000 

and 2014 from governments that make ransom payments. To better 

understand the significance of this troubling trend, Treasury Under 

Secretary David Cohen said in 2012 that kidnapping for ransom 

has become so lucrative for terrorists that it is today’s most significant source of terrorist financing. 

Denying terrorists ransom payments is not just a U.S. policy. It 

is the international standard champion by the Financial Action 

Task Force, the Counter-ISIL Financing Group, and the United Nations. 

International noncompliance with antiterror financing standards 

does not just end there. According to a Financial Action Task Force 

report, almost every country in the world has enacted antiterror financing laws, but only 33 of the 194 countries surveyed have actually reported any convictions using these laws. 

The laws are worthless unless they are put into action. We must 

do more to get our partners to implement these laws so that they 

will have already passed in their respective nations. 

Our international partners can also do more to stop the flow of 

money from private donors to terrorist groups. Between 2013 and 

2014, ISIS received $40 million from donors in Saudi Arabia, 

Qatar, and Kuwait. All those countries have terror financing laws 

on the books, but the money still flows across their borders to ISIS. 

The more we can improve on both our internal coordination and 

our international cooperation, the less money terrorists can have. 

We need more information. We need to have more information, and 

we know both wildlife trafficking and trade-based money laundering are sources for revenue for terrorists as well. We simply 

have not collected the necessary intelligence, however, and done 

the required analysis to understand these sources. 

3

Going after sources of revenue for terrorists can be a powerful 

tool to render them powerless. Terrorists need money to pay their 

fighters, buy their weapons, and pull off the attacks. If we can 

work to deny them the money, that means we are a big step closer 

to defeating terrorists worldwide. 

I will now yield to the gentleman from South Carolina to make 

his opening statement. 

Mr. WILSON. Thank you, Judge Poe, and thank you for recommending this hearing on such an important topic. And I am 

pleased that we are reviewing this subject in a joint hearing of the 

two subcommittees. 

Since I sit on your subcommittee in addition to chairing the 

Emerging Threats, I consider this a very efficient use of time. I 

would also like to thank Ranking Member Jim Langevin and Ranking Member Bill Keating for their contributions and participation 

today. 

We welcome our panel of experts from this interagency team for 

today’s hearing. I would especially like to welcome back Secretary 

Theresa Whelan from the Department of Defense. Secretary 

Whelan has appeared before the Armed Services Committee many 

times, as well as the subcommittee. She brings a wealth of knowledge and experience on important issues within her portfolio. 

And I am pleased to have the opportunity today to talk about the 

topic of countering terrorist financing with our colleagues from the 

Terrorism, Nonproliferation, and Trade Subcommittee. I am honored to be the chairman of the Emerging Threats and Capabilities 

Subcommittee as we oversee some of the most forward-looking, cutting edge, and in-demand aspects of the Department of Defense. 

As we consider this important topic today of countering terrorist 

financing, I think we should keep in mind two important frames 

of reference. First, countering the finances of terrorist groups remains a relatively new area of focus for the United States Government and interagency in particular. 

Although the attacks of September 11 serves as the most recent 

forcing function, the subsequent wars of Afghanistan and Iraq 

showed us that the unabated financing of terrorists and insurgence 

groups can prolong conflicts and frustrate our national security objectives putting American families at risk. 

The more recent rise of ISIL, or Daesh, with nearly $1 billion in 

annual revenue proves again, for our enemies, cash remains king. 

Second, we should continually keep in mind how difficult this 

problem set is. Eliminating and countering the finances of illicit 

and terrorist networks that operate in ever changing and clandestine manner is very difficult work. I encourage each of the colleagues today to ask questions of our witnesses on how they are 

resourced in this important fight to stem the flow of dollars to our 

enemies. 

I again would like to thank Judge Poe for holding this joint hearing between the two subcommittees. I look forward to hearing from 

our distinguished panel of witnesses today. 

And with that, I yield back the balance of my time. 

Mr. POE. I thank the chairman of the Armed Services Emerging 

Threats and Capabilities Subcommittee. 

4

I yield to the gentleman from Massachusetts, Mr. Bill Keating, 

for his opening statement, the ranking member of the Terrorism 

Subcommittee. 

Mr. KEATING. Well, thank you, Chairman Poe, for conducting the 

afternoon’s hearing, and I appreciate your concern for terrorist financing and your leadership on continuing this conversation both 

within Congress and externally. I would also like to thank Chairman Wilson and Ranking Member Langevin of the Armed Services 

Subcommittee on Emerging Threats and Capabilities for their 

shared focus and work on this subject as well. 

And of course, I appreciate the time of our witnesses who have 

joined from the Department of State, Treasury, Defense, and Interior to discuss this critical topic. Your ongoing attention and commitment to countering terrorist financing is the bedrock of our coordinated effort to stop the money flow, as the title of today’s hearing suggests. 

I also think it should be said strongly and with great appreciation for the work that is done by our men and women that are 

serving so well in the military. Just within the last 4 weeks, I was 

honored to join them aboard the aircraft carrier Harry S. Truman 

and see their mission in interrupting financing as well in a direct 

military sense. Their success at destroying cash depots and interrupting oil supply has been extraordinary, and their service should 

be recognized in this hearing as well. 

But as we know, terrorist financing has to be resolved at many 

levels in terms of trying to attack it, and it is a complicated, intricate, nuanced, and clandestine effort, making it difficult to identify, 

follow, and to stop. Organized groups such as ISIL rely on diversified revenue streams ranging from pirated oil fields and extortion 

to imposition of taxes on areas that it controls, to seizures, and to 

the sale of looted antiquities. 

Our concern doesn’t end with the trafficking of foreign terrorist 

organizations, however. Organized crime syndicates also fund illicit 

activities through a variety of subversive efforts. Wildlife trafficking, for example, is estimated to generate billions of dollars for 

organized crime enterprises. It has also been reported that these 

groups are using human and organ trafficking as well as—for a 

revenue source, in addition to illicitly smuggling tobacco and tobacco products. 

Not only do such black market dealings contribute to an illegal 

economy, but they fuel instability and they undermine global security. This is not to say the U.S. has not had success. Just this 

week, the U.S. Fish and Wildlife Service led efforts to institute a 

near total ban on domestic, commercial trade of elephant ivory, 

which aims at reducing the opportunities for wildlife traffickers to 

trade illegal ivory under the guise of legal products. 

Over a 3-year period, an estimated 100,000 elephants were killed 

for their ivory, which is an average of approximately one every 15 

minutes. These animals—ivory generates millions of dollars in illegal funds. 

Separately, last month, the President signed into law legislation 

that imposes tough new import restrictions on antiquities that attract trafficking out of Syria. I was proud to play a leading role in 

advancing H.R. 1493, along with the support of the Foreign Affairs 

5

Committee Chairman Ed Royce, Ranking Member Engel, and 

Chairman Judge Poe. 

These successes, however, should not allow us to become complacent. While identifying and stopping traditional financing methods, 

such as hawala and hawala trade-based money laundering, the 

cash couriers are important. Agencies must look at new and emerging ways through which organizations are able to generate funds. 

Virtual currency platforms and digital finance allows organized 

crime and terrorist groups to commit crimes anonymously. Digital 

currencies could facilitate money laundering, alleviating the need 

for criminal infrastructures at their base. 

With respect to terrorism, anonymous marketplaces on the Internet allow the sale of illegal goods and services and risk the convergence of terrorism and organized crime. We must utilize all the resources at our disposal to target every terrorist organized crime 

funding entity no matter where it comes from. 

I look forward to hearing from today’s witnesses on these subjects, as well as working with our international allies to end and 

prevent terrorist organizations from generating this type of illicit 

money. 

Thank you, and I yield back. 

Mr. POE. I thank the gentleman from Massachusetts. 

I recognize the ranking member of the Emerging Threats and 

Capabilities Subcommittee, Mr. James Langevin of Rhode Island, 

for 5 minutes for his opening statement. 

Mr. LANGEVIN. Thank you, Mr. Chairman. I want to thank you 

and Chairman Wilson and Ranking Member Keating for convening 

this hearing, and I especially want to thank our witnesses for being 

here today. 

In particular, I want to welcome Secretary Whelan here who has 

been before our subcommittee many times. I appreciate your presence, to all of you, and look forward to your testimony. 

So I am pleased to join my Foreign Affairs Committee colleagues 

on the topic of countering threat financing. The combined force of 

our committees on this issue is paramount because effective CTF 

requires the collaboration and synchronization of a multitude of 

U.S. Government agencies. Holding this joint hearing will provide 

us an opportunity to understand CTF efforts and strategies in a holistic manner and what we can do to enhance its overall effectiveness. 

Threat financing activities comes in many forms, from, as my colleagues have touched on already, from illicit drug trafficking, to 

wildlife poaching, to ISIL’s alarming oil revenues. And understanding such activities and the associated organizations and networks, of course, is the first step, including the alternative financing through traditional financial institutions, as Mr. Keating had 

talked about, understanding the role that that is playing. 

The Department of Defense plays a key role in this endeavor by 

providing threat finance intelligence, or TFI, to enhance our understanding of the challenges before us. Today, I look forward to hearing more about how such information is shared amongst agencies 

in a timely manner and used to produce synchronized goals and efforts to disrupt, degrade, and destroy such financing. 

6

I also look forward to hearing from DOD and other agencies 

about the progress that has been made when it comes to institutionalizing CTF. This collaboration in Afghanistan resulted in 

many successes, and it is imperative we have a grasp on how such 

lessons learned are being leveraged. 

With respect to the DOD, has progress been made on gaps identified in the recent capabilities-based assessment, such as CTF integration into joint plans and joint doctrine? How are we measuring 

the effectiveness of these efforts? 

And finally, I hope today will provide insight into ongoing U.S. 

Government efforts in countering ISIL’s oil revenue and the challenges we face on this front, as well as overall challenges with CTF 

that our committees could be helpful in providing solutions to when 

working with agencies. 

So with that, I thank again our witnesses for being here. And 

thank you, Mr. Chairman. I would yield back. 

Mr. POE. I thank the gentleman from Rhode Island. 

Without objection, all members may have 5 days to submit statements, questions, and extraneous material for the record subject to 

the length limitation in the rules. 

I will introduce the witnesses and give them time for opening 

statements. 

Mr. Daniel Glaser is the assistant secretary for terrorist financing in the Treasury Department’s Office of Terrorism and Financial 

Intelligence. Mr. Andrew Keller is the deputy assistant secretary 

for counterthreat finance and sanctions in the State Department’s 

Bureau of Economic and Business Affairs. Ms. Theresa Whelan 

serves as the principal deputy assistant secretary for defense for 

special operations, low intensity conflict. She is a career member 

of the Senior Executive Service and has worked for 27 years in the 

defense intelligence area. Mr. William Woody is the chief of the Office of Law Enforcement of the U.S. Fish and Wildlife Service. 

Without objection, the witnesses’ prepared statements will be 

made part of the record. 

I ask the witnesses please keep your remarks to no more than 

5 minutes. If you hear the gavel, that means you have got to stop. 

So 5 minutes, and we will start with you, Mr. Glaser. You may 

present your opening statement. 

STATEMENT OF THE HONORABLE DANIEL GLASER, ASSISTANT SECRETARY FOR TERRORIST FINANCING, U.S. DEPARTMENT OF THE TREASURY 

Mr. GLASER. Chairman Poe, Chairman Wilson, Ranking Members Keating and Langevin, thank you for inviting me to testify on 

our efforts to combat terrorist financing. Disrupting the flow of 

funds to terrorists and terrorist organizations is an integral part of 

our broader strategy to combat terrorism. Treasury is in a unique 

position to advance these efforts. 

At its core, combating terrorist financing consists of two interrelated objectives. First, cutting terrorists off from their sources of 

revenue so they cannot make money; second, denying them access 

to the international financial system so they cannot use the money 

they have. 

7

We accomplish these goals by improving financial transparency 

globally so that terrorists cannot anonymously raise, move, and use 

funds without detection, and then identifying, disrupting, and dismantling the networks supporting terrorist organizations. 

We have a range of tools available to us to do so. Financial measures, such as targeted sanctions and section 311 of the USA PATRIOT Act, law enforcement actions, and engagement with foreign 

partners in the private sector. The combined effect of these efforts 

is to create an international financial system that is a hostile environment for terrorist financing. 

I would like to briefly summarize our efforts to disrupt the financial networks of three prominent terrorist organizations: ISIL, alQaeda, and Hezbollah. I will speak first to ISIL, the vast majority 

of whose revenue, estimated at almost $1 billion in 2015, is derived 

internally from a combination of oil sales and extortion of the population and commercial activity under its control. The fact that these 

sources of revenue are derived from ISIL’s control of territory has 

meant that military action has been an important component of our 

response. 

Under Operation Title Wave II, the coalition directly targeted 

ISIL’s entire oil supply chain and destroyed tens of millions and 

possibly more than $100 million of ISIL’s bulk cash. Our response, 

however, has been broader than military action. For example, the 

Government of Iraq decided in August 2015 to ban the distribution 

of government salaries into ISIL-held areas, thereby eliminating 

ISIL’s ability to tax these substantial funds. Additionally, we have 

worked closely with the Central Bank of Iraq to secure Iraq’s financial system from access by ISIL. 

Turning now to al-Qaeda. Al-Qaeda remains a critical threat to 

the United States, and we continue to aggressively target the organization around the world. Al-Qaeda has historically received funds 

from within Gulf countries, safe haven in Afghanistan and Pakistan, and now is increasingly present in Yemen and Syria. We have 

made significant progress targeting al-Qaeda’s financing in concert 

with our partners internationally. However, the terrorist financing 

risk emanating from the Gulf remains a priority. 

Collectively, Gulf countries have pursued a wide range of actions, 

including implementing targeted financial measures and prosecuting terrorists for financing al-Qaeda, but considerable work remains to be done to ensure that terrorist financiers are unable to 

raise and move funds within Gulf countries. And we are committed 

to working with our partners in the region to see that this is done. 

Our efforts have not been limited solely to the Gulf. Treasury has 

continued to work toward disrupting and dismantling terrorist financial networks in Afghanistan and Pakistan as well. We have 

aggressively used Treasury tools to limit al-Qaeda funding streams, 

designating over 140 individuals affiliated with al-Qaeda and other 

terrorist organizations throughout Afghanistan and Pakistan. 

It is important to remember, however, that before al-Qaeda’s attack on 9/11, Hezbollah had killed more Americans than any other 

terrorist organization in history, and it continues to plot terrorist 

attacks around the world. Hezbollah receives the majority of its 

funding, hundreds of millions of dollars, from Iran, as well as millions of dollars from a global network of supporters and businesses. 

8

Our approach has focused on targeting Hezbollah both within 

Lebanon, constraining it financially through extensive cooperation 

with Lebanese authorities and banks, and globally, by targeting its 

procurement agents and financiers in Europe, Latin America, East 

Asia, and the Middle East. 

Identifying and sanctioning Hezbollah’s Iranian sponsors and enabling law enforcement and foreign partner actions, our toolkit to 

impose targeted measures against Hezbollah was recently expanded with the passage of Hizballah International Financing Prevention Act of 2015, or HIFPA. HIFPA represents a continuation 

of our policy to financially weaken Hezbollah. Foremost in ensuring 

our implementation of HIFPA is our close collaboration with the 

Central Bank of Lebanon and private Lebanese financial institutions, which are adhering to this legislation—which are adhering 

to this legislation to Hezbollah’s great consternation. 

We intend to implement HIFPA robustly in a manner that is consistent with preserving the strength and health of the Lebanese financial system and that does not target any specific community or 

sect. Our implementation intends to target one group and one 

group only: Hezbollah, the organization, its members, the entities 

it owns and controls. 

While new terrorist financing challenges will surely emerge, 

Treasury and its interagency partners will continue to employ a 

range of measures to identify, disrupt, and dismantle terrorist financial networks and work to identify and close loopholes that terrorists and other illicit actors can use to access the international 

financial system. 

Thank you for the opportunity to testify today, and I would be 

happy to answer any questions you might have. 

[The prepared statement of Mr. Glaser follows:]

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Mr. POE. Thank you, Mr. Glaser. 

Mr. Keller, you have 5 minutes. 

STATEMENT OF MR. ANDREW KELLER, DEPUTY ASSISTANT 

SECRETARY FOR COUNTER THREAT FINANCE AND SANCTIONS, BUREAU OF ECONOMIC AND BUSINESS AFFAIRS, U.S. 

DEPARTMENT OF STATE 

Mr. KELLER. Chairman Poe, Chairman Wilson, Ranking Member 

Keating, Ranking Member Langevin, distinguished members of the 

committees, thank you for the opportunity to speak here today 

about the State Department’s counterterrorism finance efforts. 

Counterterrorism finance is a top priority for the Department of 

State, and we have a wide variety of tools to disrupt terrorist financial networks. It is a complex and dynamic threat and one that 

requires the U.S. Government to utilize the full range of its resources and authorities. 

My office at the State Department helps coordinate policy and liaise with our interagency partners, including the Departments of 

Treasury and Defense, to achieve our counterterrorism goals. We 

also work closely with the State Department’s counterterrorism bureau and the Department of Treasury on counterterrorism finance 

sanctions to ensure that our sanctions promote broader U.S. foreign 

policy interests. 

The fight against ISIL is one of the top national security priorities, and it is my principal counterterrorism focus. That is where 

I will focus my remarks today. 

As you highlighted, Chairman Poe, ISIL’s revenues in 2014 and 

2015 made it the richest terrorist group in the world, yet as a result of U.S. and coalition efforts, ISIL’s revenues are on a downward trajectory, which has impacted its operations in Iraq and 

Syria. I would like to provide two examples. 

ISIL has cut salary payments to its fighters in Raqqa and Mosul 

by 50 percent, leaving many ISIL fighters to defect. And ISIL has 

increasingly resorted to arbitrary tax increases and outright theft 

to make up the funding gap, further undermining its claims to legitimacy. 

While we are encouraged by these indications of financial stress, 

we are fully aware that there is still much work to do to further 

weaken ISIL on the financial front. Our most effective method of 

disrupting ISIL’s revenues to date has been U.S. and coalition 

strikes against their oil and gas supply chain and cash storage 

sites. These efforts have reduced ISIL’s oil revenues by up to onethird and destroyed tens and potentially hundreds of millions of 

dollars’ worth of cash. 

Kinetic efforts have complemented diplomatic efforts aimed at 

ISIL’s finances. The U.S. Government helped establish and now 

coleads an international working group dedicated to counter ISIL 

finance, and we have negotiated multiple U.N. Security Council 

resolutions to increase financial pressure on ISIL. In particular, I 

would highlight Security Council Resolution 2199, which imposes 

obligations on all countries to take steps to combat ISIL financing, 

particularly in the areas of oil, antiquities, and kidnapping for ransom. 

19

The Department of State also conducts bilateral diplomatic engagement with key countries in the Middle East and around the 

world. Our Embassies consistently engage foreign government officials on specific terrorism finance matters, promote counterterrorism finance tools more generally, and encourage implementation 

of domestic and international legal framework to combat terrorism. 

In an effort to address the systemic gaps in the international system that terrorists and other criminals exploit to raise and transfer 

funds, the State Department also allocates significant funding to 

build the capacity of partner countries to counter terrorist financing. The Bureau of Counterterrorism is helping partner nations 

build their capacity to investigate and prosecute illicit financial 

transactions, while the State Department Bureau of International 

Narcotics and Law Enforcement funds programs to help countries 

identify how they can improve their antimoney laundering and 

counterterrorism finance regulations. 

With regard to trafficking in antiquities, the Department of State 

has also led outreach to prominent antiquities dealers, auction 

houses, and museum administrators. We have offered up to $5 million worth of reward money for information leading to the disruption of ISIL’s trafficking in antiquities through our Rewards for 

Justice program, and we have funded government and civil society 

training program to help protect antiquities in Iraq, Syria, and 

Libya. 

Terrorism finance is a multifaceted and dynamic problem, and 

ISIL has proven to be a resilient foe. As our efforts targeting ISIL 

financing demonstrate, counterterrorism finance is a top property 

priority for our State Department and our interagency partners. 

We will continue to use every tool available to maintain the growing effectiveness of our economic campaign. 

Thank you very much, and I look forward to your questions. 

[The prepared statement of Mr. Keller follows:]

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Mr. POE. Thank you, Mr. Keller. 

Ms. Whelan. 

STATEMENT OF MS. THERESA WHELAN, ACTING ASSISTANT 

SECRETARY FOR SPECIAL OPERATIONS/LOW INTENSITY 

CONFLICT, U.S. DEPARTMENT OF DEFENSE 

Ms. WHELAN. Chairman Wilson, Chairman Poe, Ranking Member Langevin, Ranking Member Keating, and other distinguished 

members of the subcommittees, I appreciate the opportunity to 

share information with you about the Department of Defense’s 

counterthreat finance capability. 

DOD’s counter-threat finance, or CTF, supports both military operations and U.S. Government partners, including our law enforcement colleagues. DOD CTF identifies and exploits the financial 

vulnerabilities of terrorists and transnational criminals. 

Over a decade ago, we built a small but effective CTF capability 

within the Department through our counternarcotics authorities 

and appropriations. Counternarcotics is an appropriate source of 

authority and resources, given that the drug trade remains the 

world’s most lucrative criminal enterprise. 

Funds from the illegal drug trade are often associated with other 

illicit criminal enterprises, insurgencies, and terrorist organizations, including the Taliban in Afghanistan; the Revolutionary 

Armed Forces of Colombia, the FARC; and Lebanese Hezbollah. 

Today, DOD has dedicated CTF teams at its combatant commands, at the National Guard Bureau, and at intelligence components. The CTF teams analyze financial intelligence, integrate intelligence in operations, and coordinate and execute CTF activities 

within the Department and with and in support of U.S. interagency 

partners. 

DOD is not the lead U.S. agency for conducting CTF, but DOD 

employs unique analytic capabilities to assist other partners in accomplishing the overall CTF mission. For example, DOD analysts 

help support our Department of Treasury colleagues’ efforts to develop designations against individuals and organizations engaged 

in illicit finance. 

DOD CTF analysts help to identify vulnerabilities and to create 

a comprehensive analysis for U.S. Government partners to target 

an adversary’s financial structure. CTF has proven to be a cost-effective tool against threatening forces and transnational criminal 

organizations, whether through law enforcement actions, designations, sanctions, or, as in the case of ISIL, through military actions 

against economic and financial targets. 

DOD CTF supports the Department of State and the Department 

of Treasury, which are the coleads for the U.S. Government’s effort 

to disrupt ISIL’s finances. Over the past several months, ISIL has 

lost financial capability and revenue. Coalition military operations 

informed by CTF have struck nearly two dozen ISIL bulk cash storage sites and multiple targets affiliated with ISIL’s illicit oil industry. Recent estimates indicate ISIL’s oil production has decreased 

by up to 30 percent, and their ability to generate revenue has been 

reduced by at least as much. 

In order for DOD CTF to continue supporting these and future 

successes on the battlefield and in law enforcement and diplomacy, 

31

we must ensure that our CTF capability is well grounded in our 

Department’s policy planning doctrine and training and education. 

For example, last October, the deputy secretary of Defense recertified DOD’s directive on counterthreat finance policy through 

2020. We also are working to ensure that DOD plans and joint doctrine include CTF where appropriate. 

Congress’ support for the DOD counterdrug authorities and 

counterdrug funding underpins our CTF program success. Thanks 

to congressional support, executive branch partnership, and our 

talented DOD CTF personnel who work quietly behind the scenes, 

DOD CTF continues to provide a cost-effective capability against 

international terrorists and criminal adversaries that threaten our 

Nation, its citizens, and our allies. 

Thank you for this opportunity to share with you the information 

about DOD’s counterthreat finance program, and I welcome your 

comments and questions. 

[The prepared statement of Ms. Whelan follows:]

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Mr. POE. Thank you, Ms. Whelan. 

Mr. Woody. 

STATEMENT OF MR. WILLIAM WOODY, CHIEF OF LAW 

ENFORCEMENT, U.S. FISH AND WILDLIFE SERVICE 

Mr. WOODY. Good afternoon, Chairman Poe, Chairman Wilson, 

Ranking Member Keating, Ranking Member Langevin, and members of the subcommittees. I am William Woody. I am chief of law 

enforcement for the U.S. Fish and Wildlife Service, and I appreciate the opportunity to testify before you today. 

Wildlife trafficking is a multibillion dollar illegal trade fueled by 

demand and enabled by corruption, limited legal authorities, and 

law enforcement capacity. Globally, organized criminal groups have 

seized upon wildlife trafficking as a low risk, high reward, and 

have made illegal wildlife trafficking a crisis. 

Our special agents and inspectors have specifically documented 

transnational organizations involved in trafficking of endangered 

species. We have documented Eastern European and Russian organized crime in the caviar trade, Irish organized crime in the rhino 

horn trade, Mexican drug organizations in the totoaba trade, African gangs in the elephant ivory poaching and smuggling, and 

Asian criminal groups in timber trafficking. I would like to draw 

your attention now to the slides. Of course, the slides won’t come 

up. 

Mr. POE. Is that the slide you are looking for? 

Mr. WOODY. That is the slide I am looking for. Thank you, sir. 

Mr. POE. Who are those guys? 

Mr. WOODY. This photo represents criminals arrested nationwide 

for trafficking in rhino horn, elephant ivory, totoaba, and narwhal 

tusks. A number of these individuals were arrested in our investigation named Operation Crash, which is focused on rhino horn 

trafficking. To date, Operation Crash has resulted in 41 arrests, 30 

convictions, and the wildlife and their proceeds seized in this case 

have a street value in excess of $75 million. In addition to crimes 

against wildlife, the defendants have also been charged with money 

laundering, tax evasion, falsifying documents, mail fraud, and bribery. 

Photo 2, please. Jimmy and Felix Kha were convicted of a number of crimes related to international trafficking of rhino horn. During these investigations, our agents conducted a financial analysis 

of Kha’s business, the Win Lee Corporation. Records revealed that 

large deposits were being made into bank accounts from others who 

became targets of the investigation as well. The documented foreign wire transfers confirmed foreign nationals involved in rhino 

horn trafficking here in the U.S. By the use of FinCEN records, our 

agents were able to substantiate money laundering activity in a 

scheme involving use of gold as currency and use of safety deposit 

boxes. 

Photo 3, please. The Kha and their businesses were sentenced to 

pay over $1 million in fines and penalties and restitution, and in 

addition, forfeited over $2 million in assets, including gold, cash, 

jewelry, and vehicles. 

Photo 4, please. This photo shows two Chinese nationals who had 

bribed a Customs official at the Dar es Salaam airport in Tanzania. 

40

They were able to smuggle eight suitcases full of ivory out of Tanzania destined for Hong Kong. 

Photo 5, please. This photo shows the content of the suitcases 

that were intercepted and seized in Switzerland while in transit. 

Our regional U.S. Fish and Wildlife Service attache was able to assist Tanzania authorities in their investigation and collection of forensic examination of the evidence seized. 

Photo 6. To illustrate the current illegal wildlife trade in the 

U.S., this photo shows elephant ivory and narwhal tusks forfeited 

by an antiques dealer who was sentenced in Federal court in New 

York for the unlawful import and sale of ivory in 2016. 

Photo 7. This photo is a sample of various elephant tusks, ivory 

carvings that have been interdicted and seized at the U.S. mail 

international sorting facility in Miami during the course of an ongoing multiagency enforcement operation. This operation alone has 

identified nearly 90 individuals and businesses and involves over 

250 smuggling incidents in which elephant ivory was smuggled 

from the U.S. to China. 

Next photo, please. This photo depicts over 200 swim bladders 

that were seized in a California residence drying and awaiting 

shipment. In 2014 and 2015, CBP, ICE, and Fish and Wildlife 

Service agents seized over 530 totoaba swim bladders that were 

smuggled into the U.S. Totoaba is an endangered fish found only 

in the Gulf of California whose swim bladder is highly prized as 

a delicacy. Eleven individuals smuggling totoaba have been arrested. During an interview with one of those smugglers, he stated 

that on one occasion, five totoaba swim bladders were sold for 

$50,000 to a recipient in Hong Kong. 

While we have made great strides recently to address wildlife 

trafficking, there is still much work to be done. Wildlife trafficking 

persists at unsustainable levels and the role of sophisticated, highly organized criminal networks may present an opportunity to support and fund insurgent or terrorist activities and makes even 

more an urgent threat to the wildlife communities and global security. 

I thank you for the opportunity today to present testimony, and 

I appreciate the subcommittees’ support in our efforts to combat 

wildlife trafficking. And I would be pleased to answer any questions you may have. Thank you. 

[The prepared statement of Mr. Woody follows:]

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Mr. POE. I thank all of you for your testimony before the subcommittees. 

The members of the subcommittees will have votes shortly, but 

we will take turns asking questions until the votes begin, and then 

we will resume 15 minutes after the last vote. 

I recognize myself for some questions. 

I have been making a list of the things you have commented on 

on how the bad guys get money, and let me go through those, and 

then I want you to add those that I missed. 

First of all, cash from rich donors, individual donors in foreign 

countries, they just send cash to the terrorist groups; the black 

market of goods, tobacco, for example, as the ranking member mentioned; the trafficking of people, the sale of people as sex slaves; 

ransom payments; bank robberies; oil on the black market; antiquities; drug trafficking; ISIS tax people in their areas if they are 

not loyal to ISIS, if they are Christians or some other Muslim faith 

are taxed; this disturbing news about wildlife trafficking; and then 

you have state sponsor of terror, Iran who gives money to 

Hezbollah wherever they are in the world. 

Did I leave out any? You all are awful quiet. I mean, this is disturbing news here. I am not going to be critical of what we have 

done. I just want to try to see if we can move forward and stop the 

money flow. 

Mr. Woody, your testimony is compelling. My understanding is if 

something doesn’t happen pretty soon, elephants in Africa and the 

rhinos are going to be extinct. Is that correct? 

Mr. WOODY. That would be correct, sir. 

Mr. POE. The elephant tusks end up eventually—most of them, 

not all—end up in China. Is that correct? 

Mr. WOODY. That is correct, a good majority of them do. 

Mr. POE. And rhino horns are ground for their powder, and they 

end up in Vietnam. 

Mr. WOODY. They end up in Vietnam, in China. They also use 

them for libation cups for different carvings as well too. 

Mr. POE. All right. And what about foreign charities or charities 

working in the United States as a foreign—or as a charity, do they 

raise money for terrorist groups? Any of you want to weigh in on 

that? 

Mr. GLASER. Yes, charities raise money for terrorist groups. 

Mr. POE. Like what charities? You have any names? You can 

name names in——

Mr. GLASER. No, I would be happy to name names. I don’t have 

the names at the tip of my tongue, but as recently as March 31 of 

this year, we designated two charities in Pakistan and Afghanistan 

who are actively involved in terrorist financing. 

Mr. POE. Okay. What about domestic charities in the United 

States? 

Mr. GLASER. There have been domestic charities that have been 

designated and prosecuted for terrorist financing. Holy Land Foundation is probably the largest example of that. 

Mr. POE. Okay. The Holy Land Foundation. All right. Let me ask 

you this. How do we get all you all and the folks in law enforcement working to share information, intelligence about what is 

being done worldwide on financing terror groups? Because my unVerDate 0ct 09 2002 10:48 Aug 24, 2016 Jkt 000000 PO 00000 Frm 00054 Fmt 6633 Sfmt 6633 F:\WORK\_TNT\060916\20383 SHIRL
49

derstanding is everybody is kind of doing their own thing. I am not 

saying they are doing a bad job. They are just doing their own 

thing without coordination with other American agencies and then 

foreign governments. 

Ms. Whelan, you want to weigh in on that? 

Ms. WHELAN. Yes, sir. I think—well, I know from the Department of Defense’s standpoint, we actually provide a great deal of 

support to our partners at Treasury and in law enforcement with 

our CTF teams and liaison officers. So we are in sort of regular 

contact with them on a day-to-day basis working together to share 

information. 

We have a number of enterprises within the Washington area in 

which we gather together to share information, situational awareness. So I think while there is always room for improvement, I 

think we have a pretty good basis right now of information sharing, 

certainly we feel, between the Department of Defense and the——

Mr. POE. But are we doing enough? Are we doing enough? I am 

not critical of what we are doing. I am just asking are we doing 

enough? Because of all of these different ways that the bad guys, 

outlaws raise money, how can we move forward to do even a better 

job? You got some ideas? 

Ms. WHELAN. Well, I think we can just expand on what we are 

currently doing, and we are getting better at it. Certainly, there is 

resource constraints in terms of people and in terms of intelligence 

collection assets, but we are definitely improving our coordination. 

I think we have made a lot of progress in just the last couple of 

years. 

Mr. POE. All right. I will have additional questions I will submit 

for the record for you all to answer. 

I will recognize the chairman of the subcommittee, Mr. Wilson 

from South Carolina. 

Mr. WILSON. Thank you, Judge Poe, and thank you for your obvious passion about this issue and making a difference. 

And Secretary Whelan, in your testimony, you discuss how the 

Department of Defense is working to institutionalize counterthreat 

finance capabilities across the force and within the services. Can 

you provide some additional examples of how you are doing this? 

And additionally, are you seeing demand for counterthreat finance 

experts continue, and if so, how are you managing that while other 

resources across the Department continue to diminish? And finally, 

is the counterthreat finance a high enough priority for commanders 

to pay attention and dedicate resources to so that we can properly 

institutionalize lessons learned? 

Ms. WHELAN. Thank you for the question, Mr. Chairman. 

Yes, we actually, number one, the first part is we are progressively institutionalizing counterthreat finance within the Department, and it is—it has gained tremendous amount of traction, particularly in the combatant commands. But a couple of things, additional things we are doing beyond the DOD directive that I mentioned in my testimony, we are including CTF in our professional 

military education courses. 

In fact, the National Guard Bureau has been very helpful to us 

in developing courses for CTF, for personnel within the U.S. military. Additionally, the services are now, as they manage their perVerDate 0ct 09 2002 10:48 Aug 24, 2016 Jkt 000000 PO 00000 Frm 00055 Fmt 6633 Sfmt 6633 F:\WORK\_TNT\060916\20383 SHIRL
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sonnel, they are looking for people with CTF skill sets so that they 

can provide them. There is a demand signal from the COCOMs, 

particularly CENTCOM, and it has a very significant and robust 

CTF effort. I was just down in Tampa 2 weeks ago and met with 

that team. 

So this has definitely got traction within the Department. I don’t 

see that it will lose traction. We have integrated it into our program planning and budget process, and we are also working with 

the COCOMs to integrate CTF into planning and doctrine. So I believe that we do, obviously, have resource constraints in terms of 

personnel available to devote to this, and as I mentioned briefly, 

the intelligence assets that we have to devote to this. But within 

the constraints that we are currently working under, I think that 

everyone is putting forward 100 percent effort to do more on the 

CTF front. 

Mr. WILSON. Well, we certainly look forward to working with you 

on that. 

And, Chief Woody, you have really gotten the attention of Judge 

Poe. He was extraordinarily intrigued by this particular picture. If 

you can explain it one more time, and then how is it that Fish and 

Wildlife is coordinating with law enforcement efforts across the 

United States to stop the global financing? 

Mr. WOODY. Okay. You want me to explain the picture again? 

Mr. WILSON. Yeah, one more time, please. 

Mr. WOODY. It is—those are totoaba fish bladders. Totoaba is a 

fish that is found in Sea of Cortez, and they dry the totoaba bladders out. Totoaba bladders sell, they make a soup called maw, and 

totoaba bladders, they do sell for $10,000 and higher on those. 

So that is—in that particular picture there, ICE was working a 

case in conjunction with Fish and Wildlife Service. Really what 

that is, that is a drop house, and they were moving the totoaba 

bladders up into the U.S. They were being dried in that house and 

they were awaiting shipment to another—they were making a shipment to Asia and move them there. So to coordinate——

Mr. WILSON. And one inquiry. You said Sea of Cortez. Where is 

that? 

Mr. WOODY. Or in Gulf of Mexico. Not the Gulf of Mexico. Sea 

of Cortez, California, off the coast of Baja. 

Mr. WILSON. Okay. But Colonel Cook is very familiar with this, 

so he will let us know. 

Mr. WOODY. Okay. Very good. 

Mr. WILSON. That is very serious. 

Mr. WOODY. And then the other thing, coordinating. We have—

with the executive order on wildlife trafficking, I have to say in the 

last 3 years, all the people sitting at this table, they all have people 

that sit on the wildlife task force. And we have coordinated, 

through the United States and throughout the world, on setting up 

a whole number of different things that we have never really been 

at with wildlife before. For example, with U.S. Fish and Wildlife 

Service, we are now establishing attache positions throughout the 

world. 

Currently, we have just put five people out in the regions that 

tie into State Department’s wildlife enforcement networks. We put 

five attaches out. We are planning to put another four out this 

51

year. They work very closely in the regions with the governments 

in different regions working on wildlife trafficking issues: Everything from the finance, to the trafficking, to the lab work that they 

need done as well. 

Mr. WILSON. Thank you very much. 

Mr. POE. I thank the gentleman from South Carolina. 

The committees will be in recess until 15 minutes after the last 

vote starts, and we will resume with the questions from Mr. 

Keating from Massachusetts. 

The subcommittees are in recess. 

[Recess.] 

Mr. POE. The subcommittees will come to order. 

The chair recognizes the ranking member of the Terrorism Subcommittee, Mr. Bill Keating from Massachusetts, for his questions. 

Mr. KEATING. Thank you, Mr. Chairman. 

I am curious. There has been cooperation with the United States 

and the EU in terms of the so-called SWIFT agreement, which is 

Society for Worldwide Interbank Financial Telecommunication. 

And I wanted to know, we have heard that there is concern from 

the European front that privacy issues might present problems 

with them cooperating on that. Could any of you comment on that 

being compromised by their concerns and, if there are going to be 

any alterations in that, whether that is going to be something we 

should be concerned about? 

Anyone? 

Mr. GLASER. Thank you for the question, Congressman. 

We have very close cooperation, as you stated, with the Europeans on our SWIFT program——

Mr. POE. Could you talk a little louder? 

Mr. GLASER. I am sorry. 

Mr. POE. We are 5 miles away from you up here, so would you 

talk louder? Thank you. 

Mr. GLASER. I apologize, Congressman. 

We do have very close cooperation with the Europeans on the 

SWIFT program, and privacy issues are frequently brought up as 

part of that conversation. But we have always managed to work 

through those issues, and our cooperation with the Europeans remains very strong on that program. 

Mr. KEATING. All right. 

As the chairman and I were discussing during the break, we are both struck by the fact that there is $80 billion annually that 

comes directly from illicit tobacco trade. It is now equal to cocaine 

trade in terms of illicit. 

Is there anything being done to curb that illegal trade? What is 

being done? Is that being used by any groups as well? 

Mr. Glaser again. 

Mr. GLASER. Well, I don’t have anything specifically to say about 

illicit tobacco trade. I am sure it is a source of organized crime proceeds. I have not seen any indication that it is a significant source 

of terrorist financing proceeds. Certainly, our anti-money-laundering regulatory and criminal regime would cover any proceeds of 

that——

Mr. KEATING. Would you think the same for human trafficking, 

as well? That is something you don’t hear about, but is there any 

52

way these groups are getting any kind of funds, indirectly or directly, from human trafficking? 

Mr. GLASER. Well, I do believe ISIL does derive proceeds from 

human trafficking. I would say it is more in the order of criminal 

networks that are involved in human trafficking that operate in 

ISIL territory and that ISIL would tax or charge fees for allowing 

them to participate in that activity. 

Mr. KEATING. There has been a lot of focus with ISIL on use of 

cyber networks for propaganda and recruitment, but, also, the virtual currency exchange platforms are something of a concern, as 

well. Because it is public knowledge now that those involved in the 

Paris attack used prepaid cards to rent hotel rooms the night before the attack. We also have concerns with Bitcoin and other financing mechanisms. 

Is that something you see as a new challenge or a challenge that 

you have already seen and are trying to address? 

Mr. GLASER. Certainly, the use of virtual currency—Bitcoin, prepaid cards, things like that—are emerging challenges for us. We 

have revised our anti-money-laundering regulations to require a 

certain amount of transparency with respect to how those financial 

products operate. 

The European Union has not done so yet. I have actually traveled to Brussels to have detailed discussions with them on this 

issue, and they are looking at a variety of reforms that they could 

make, actually very, very similar to the types of steps that we have 

taken. 

It is true that there are examples of terrorist organizations, including ISIL, using these types of products, but I have to say, I 

don’t think that it represents a systemic threat at this time. I think 

there are other ways that these organizations use to move funds 

that are far more significant for them. 

Mr. KEATING. Yeah. 

Mr. Keller, in particular, you know, Turkey was recently taken 

off the Financial Action Task Force gray list, which is used to describe jurisdictions with deficiencies when it comes to counterterrorism financing, because it passed new terror finance laws. 

But there are experts out there telling us that Turkey’s implementation of its terror finance laws have been poor. Do you agree 

with that assessment? And, if so, what is the State Department 

doing to encourage Turkey to substantively go after terror financing in that regard? 

Mr. KELLER. Thank you for the question, Congressman. 

I would start off by saying we work closely with Turkey on a variety of fronts. They are a member of our Counter-ISIL Finance 

Working Group. Through recent high-level engagements, we now 

have a border security group that is working on border security 

and aviation. 

We are pleased that they have come off the FATF gray list. I 

think that is a positive step. I think it is fair to say that they are 

not necessarily perfect; no country is. But we continue to work with 

them to try to encourage them to implement their laws and basically strengthen their efforts on counterterrorism and anti-moneylaundering. 

53

I think it is also important to recognize that Turkey itself has 

been victimized by ISIL terrorism. And so they have a strong incentive and are active in trying to eliminate ISIL facilitation networks in their country. 

Mr. KEATING. Yeah. 

Mr. KELLER. And I would invite any of the other panelists——

Mr. KEATING. Well, I think—thank you, Mr. Keller. I think my 

time is up, and I yield back. 

Mr. POE. I thank the gentleman from Massachusetts. 

The chair recognizes the ranking member, Mr. Langevin from 

Rhode Island, for his questions. 

Mr. LANGEVIN. Thank you, Mr. Chairman. 

I want to thank all of our witnesses again for your testimony 

here today. 

So I would like to go back to the discussion we were having earlier about lessons learned. So we have touched on how each agency, 

specifically DOD, is institutionalizing counter-threat financing. I 

am also interested in understanding how CTF is being institutionalized across the whole of government through defined roles, 

responsibilities, and organizational constructs, allowing for more 

synchronized efforts at a more strategic level. 

So, in Afghanistan, CTF was successful. Were there lessons 

learned here? 

Mr. GLASER. Thank you for the question, Congressman. 

So, just to speak about how the Treasury Department is organized for a moment and then to speak more broadly about the 

United States Government, the Treasury Department is actually 

unique among all finance ministries in the world in that we have 

one office, run by an under secretary at the Treasury Department, 

that brings together all of the expertise, all the resources, all the 

tools, all the authorities, all the contacts that we have as a finance 

ministry and puts them for the singular purpose of advancing U.S. 

national security, using financial tools to advance U.S. national security. 

We are the only finance ministry in the world with our own allsource intelligence office. We have a sanctions implementation office, we have my office, which is a policy office, and we have a financial intelligence unit, FinCEN, all under one roof. And it gives 

us a huge range of unique expertise and unique capabilities that 

we have to put at the disposal of the United States Government. 

I do think that we are actually quite well-coordinated across the 

United States Government. As I said in my opening statement, 

there are two components of our efforts against terrorist financing. 

The first component is the systemic component, the regulatory component, making sure that the international financial system and 

our financial system is transparent and is well-regulated and that 

it does not provide opportunities for terrorist groups, organized 

crime groups, or drug trafficking groups or any other group—Iran, 

rogue regimes—to gain access to the financial system. 

That is largely an effort of coordination among the Treasury Department, among regulators, among law enforcement. And we have 

a number of groups that allow us to do that. Most importantly—

and, I should say, in partnership with the private sector. And we 

have groups like the Bank Secrecy Act Advisory Group for that. We 

54

had an anti-money-laundering task force, along with the regulators. There are a number of groups that allow us to coordinate 

on that. 

The second part is the targeted part, the operational part of identifying and undermining terrorist organizations. And, again, I feel 

the government is well-coordinated on that. The National Counterterrorism Center within the intelligence community organizes intelligence analysis with respect to terrorism broadly. My counterpart 

within Treasury, the head of our intelligence office, Leslie Ireland, 

Assistant Secretary for Intelligence Analysis, is also the intelligence community’s mission manager for illicit finance. 

And then, on an organization-by-organization basis, whether it is 

Hezbollah, whether it is ISIL, whether it is al-Qaeda, there is any 

number of coordination processes that are run by the NFC that 

allow us all to get together and make that sure that we are wellcoordinated on the issue. 

Mr. LANGEVIN. Okay. Thank you. 

Mr. Keller? 

Mr. KELLER. I think I would simply add to that that, whether I 

look to my right to Assistant Secretary Glaser or to my left to Assistant Secretary Whelan, I think the counter-ISIL effort is a very 

good example of the coordination that we do on a daily basis. 

Our teams work together basically nonstop. The goal of the effort 

is to have a synchronized and sustained and aggressive campaign 

to counter ISIL’s finances, using basically all available national resources, whether they are coming on the kinetic side through DOD 

and CENTCOM, whether they are on the diplomatic side with the 

State Department, and working very closely with Treasury in diplomatic engagement multilaterally and bilaterally, or a range of 

other tools, including the State Department’s capacity-building programs. 

I would just note that those programs, I think, are some of the 

most effective things that we can do overall, in that they are trying 

to drive systemic change. So, for example, Ranking Member 

Keating had mentioned cigarette smuggling earlier. These programs aren’t necessarily targeted at cigarette smuggling or wildlife 

trafficking or whatnot. They are targeted overall at building investigatory capacity, prosecutorial capacity, judicial capacity. We work 

with customs agencies in other countries to try to strengthen all of 

it. And it can have a positive effect on our counterterrorism efforts, 

as well. 

Mr. LANGEVIN. Okay. Thank you. 

My time has expired, so I will ask Secretary Whelan and Mr. 

Woody to respond, if you would, in writing. 

And, Secretary Whelan, for the record, I have a question for you, 

which is: How is intel shared in a timely manner so that all agencies are working within an updated intel picture? So, if I had more 

time, I would get your answer, but my time has expired. 

I will yield back. 

Mr. POE. I thank the gentleman from Rhode Island. 

Ms. Whelan, submit the answer to that question to both committee chairs, the full committee chairs, and that will be dispersed 

to everyone, including the gentleman from Rhode Island. 

55

The chair recognizes Colonel Cook—I started to say former Marine, but there is no such thing as a former Marine—from California. 

Mr. COOK. Thank you, Judge. You are absolutely correct. 

Mr. Keller, if I were President of the United States, heaven forbid, but if I said to you, what do you think, one, two, or three, are 

the top countries, state-sponsored aid, financial aid, to ISIS or ISIL 

or Daesh, whatever you want to call them, who would you name, 

one, two, or three? Just briefly. 

Mr. KELLER. Congressman, I——

Mr. COOK. Real brief. 

Mr. KELLER. I think—I understand the concern about——

Mr. COOK. No, no. Just in your opinion, your opinion, I am asking you as the President of the United States, one, two, or three, 

who do you think they are? 

Mr. KELLER. It is a fair question. I don’t really have an answer——

Mr. COOK. Okay. Okay. 

Mr. KELLER [continuing]. Because we are not seeing——

Mr. COOK. Okay. 

Then let’s go back to what you were commenting on about Turkey. And I have a different impression of Turkey because of 

Erdogan. I have some issues with the—I understand the war 

against the PKK, but I am also concerned about what they are 

doing to the rest of the Kurds, which is one of our allies against 

ISIS. 

And it is almost like, are we overlooking that, that some people—

particularly with Erdogan leaning toward the Muslim Brotherhood. 

Could you address that briefly? Real briefly. I am running out of 

time. 

Mr. KELLER. I appreciate the question. I am going to have to 

take that one back. As I mentioned, my focus in this area is specifically on the counter-ISIL financial front. So I would like to take 

your question back to our Turkey experts——

Mr. COOK. Okay. 

Then let me move on to Hamas. Is Hamas helping them out with 

financing, ISIS? 

Mr. KELLER. Not that I am aware of, sir. 

Mr. COOK. So there is—okay. 

Mr. Glaser, did you want to comment on that, about the situation 

in Turkey, where, you know, a number of months ago, there were—

that they were, you know, helping out with the oil and everything 

like that with ISIS. Any comments on that at all in the intel sector? 

Mr. GLASER. I think that Turkey has stepped up its efforts on the 

counter-smuggling side. I do think Turkey, as was discussed earlier, has work to do on its financial system in terms of implementing its terrorist financing laws and making sure that its financial system is not available to ISIL. 

Mr. COOK. Yeah. You don’t want to answer my question about 

one, two, or three? 

Mr. GLASER. I don’t think——

Mr. COOK. And I am just a dumb Marine, so I have to ask simple 

answers. 

56

Mr. GLASER. No, I will answer your question directly. 

I do not think ISIL receives state sponsorship—I do not think 

ISIL receives state sponsorship from any country. I think Iran is 

the number-one state-sponsor of terrorism in the world, and they 

sponsor Hezbollah. I do not think——

Mr. COOK. No, I agree with you on that. 

Mr. GLASER [continuing]. ISIL receives state sponsorship. 

Mr. COOK. Okay. And you are not worried about states such as 

Qatar or some of the Gulf states at all that are involved with states 

that are sponsoring ISIS? 

Mr. GLASER. I do not think Qatar is a state sponsor of ISIS, no. 

Mr. COOK. Okay. Thank you. 

I yield back. 

Mr. POE. I thank the gentleman from California. 

Without objection, the chair will recognize Ms. Gabbard from Hawaii, who is a member of both full committees, unless there is objection. 

Without objection, you are recognized for 5 minutes. 

Ms. GABBARD. Thank you very much, Mr. Chairman. 

Mr. Keller and, both, Mr. Glaser, you have talked about how 

Turkey has stepped up and that they are doing more. Can you give 

us more specifics on what that is? 

Because, like many of my colleagues, we have concerns about the 

leadership in Turkey, what they have done directly and indirectly, 

what they have not done, more importantly, as well as the informal 

economy that we know ISIS is using to both smuggle cash and 

other things to boost their revenue. 

Mr. GLASER. Thank you for the question. 

With respect to Turkey, in terms of the things that I think that 

they are doing well, I think that Turkey has stepped up its 

counter-smuggling efforts along the border. And I think that they 

have done that significantly, and I think it has had an impact. 

Ms. GABBARD. Can you give some specifics about stepping up 

from nothing to what, or from here to there, and some specifics on 

the border, as well, especially the area of the border that remains 

open? 

Mr. GLASER. I am going to have to get back to you with——

Ms. GABBARD. Because it is just, I am trying to get some context 

here, because Mr. Keller said Turkey is not perfect, but perfect is 

a pretty high bar. So I am trying to figure out——

Mr. GLASER. Right. Well, I think the areas where I would say 

Turkey has a lot of work to do is in taking steps to deny ISIL access to its financial system, to its financial institutions. We have 

an active information exchange program with the Turks. We are in 

close communication with them to make sure that they understand 

what we understand with respect to the access that terrorist organizations may have to certain institutions, and I think it is important for Turkey to follow up on that information. 

Mr. KELLER. I would agree with Assistant Secretary Glaser’s assessment. 

I would also note specifically on the oil front, it is our assessment 

that ISIL is not smuggling or selling oil to Turkey or to individuals 

in Turkey, that the oil that is being produced in ISIL-controlled 

territory is being sold and consumed in ISIL-controlled territory. 

57

Ms. GABBARD. And is that something that has changed as of late, 

or were the reports that that was occurring completely false? 

Mr. KELLER. I would say that is something that we have been 

able to get a much clearer picture of as of—well, I don’t want to 

say ‘‘as of late,’’ but some of the most helpful information and insightful information we were able to glean on this issue came from 

the Abu Sayyaf raid last year. He was the emir for oil and gas and 

antiquities who was killed by U.S. Special Forces. 

And they were able to recover a treasure trove of information, including on ISIL’s oil activities. And the picture that we were able 

to develop from that information helped us assess that the oil was 

being consumed within ISIL-controlled territory and not being 

smuggled into Turkey. 

Ms. GABBARD. Are there other operations or things happening in 

this informal market or smuggling other than oil that you are 

aware of? 

Mr. KELLER. I think it is possible that antiquities are being 

smuggled out through basically the neighboring countries to Iraq 

and Syria, Turkey being one of them. 

Ms. GABBARD. Okay. 

Thank you, Mr. Chairman. 

Thank you. 

Mr. POE. The gentlelady yields back the time. 

The chair recognizes the gentleman from Pennsylvania, Mr. 

Perry, for 5 minutes and his questions. 

Mr. PERRY. Thank you, Mr. Chairman. 

Secretary Glaser, what is the current policy of the administration 

regarding U.S. dollars in Iran or—U.S. dollars are hard currency, 

right? You would characterize that as hard currency? 

Mr. GLASER. Yes. 

Mr. PERRY. And what is the current policy regarding hard currency, particularly U.S. dollars, in Iran? 

Mr. GLASER. You cannot engage in dollar transactions with Iran. 

Mr. PERRY. All right. So we are trying to ensure that they don’t 

get hard currency, particularly U.S. dollars, right? 

I am sure you are aware that the Iranians’ Guardian Council 

just approved the military budget for 2016-2017, which increased 

their military budget by 90 percent, including $1.7 billion transferred by the U.S. Treasury in January, which allegedly has nothing to do with the prisoner swap that happened—or, correction, a 

U.S. hostage swap that happened literally at the same time. 

I am just wondering, that transfer of $1.7 billion, what currency 

was that? What was that currency that was transferred? 

Mr. GLASER. I would have to go back and find the answer out 

to that for you. 

Mr. PERRY. $1.7 billion. You have no idea? 

Mr. GLASER. No, I do not know. I do not know what currency 

was——

Mr. PERRY. All right. All right. If you would, please, for the 

record, I would like the answer to that. 

You know, the fact that it went directly to the military, to the 

Iranian military, at this point, looking at ISIS taking the American 

equipment left in Iraq, which, you know, paid for with American 

tax dollars, is it fair for me to answer my constituents who say to 

58

me, haven’t we now funded both sides of this war, is it fair to say 

we have in some sense? I mean, it is not a ‘‘gotcha’’ question, but, 

I mean, literally, haven’t we essentially funded both sides of this 

war? 

Mr. GLASER. No, I don’t think that would be a fair thing to say. 

I——

Mr. PERRY. Why not? 

Mr. GLASER [continuing]. Think that we are doing everything 

that we can to attack ISIL’s finances. I think——

Mr. PERRY. Wait, wait, wait. ISIS has American-paid-for equipment, military equipment paid for by the American taxpayers, 

right? So they are on one side of the operation. And we just gave $1.7 billion to Iran in some currency; we don’t 

know right now what that is, at least you don’t know. And they 

sent it directly to the military, increased their military spending 

this year by 90 percent. That is on the other side. 

How is this not the American taxpayer being on both sides of 

this fight? 

Mr. GLASER. So ISIL got its hands on a lot of U.S. military equipment——

Mr. PERRY. Right. 

Mr. GLASER [continuing]. When they won battles in an ongoing 

war. I don’t think it would be accurate to say that the United 

States is providing ISIL military equipment. I think——

Mr. PERRY. Well, it wasn’t the Russians. 

Mr. GLASER [continuing]. It would be accurate——

Mr. PERRY. It wasn’t the Chinese. 

Mr. GLASER [continuing]. To say the United States is——

Mr. PERRY. It is not the Mexicans. 

Mr. GLASER [continuing]. Actively engaged in military operations 

against ISIL. 

Mr. PERRY. Let me ask you, with this $1.7 billion payment to 

Iran essentially at the very same time five U.S. hostages were sent 

home and the perception from Americans that it was payment in 

ransom and, as stated by Iran, that it was paid for—they called 

them spies, not hostages—doesn’t this undermine our policy that 

we would hope other nations would take to not pay ransoms? How 

do we have the moral authority to request that they not pay ransom when it appears to anybody who is looking that we have paid 

$1.7 billion to Iran for five hostages? 

Mr. GLASER. Yes, I understand the question. The fact of the matter is that that was not a ransom paid for hostages. We have been 

very consistent in our policy of no payment of ransom for hostages. 

And this is something that we have worked very closely with countries on around the world to ensure that there is a global agreement, a global consensus that payment of ransom for hostages is 

not an appropriate response to——

Mr. PERRY. So if we pay and we get hostages at the same time 

and we just say we didn’t, then that equates to it not being that? 

Essentially, suspend reality and just say, well, it is two different 

things. 

I mean, that is rhetorical. I apologize. 

Mr. Keller, hawala. If you can tell us anything you know about 

what we are doing about hawala being used for illicit purposes, 

59

particularly to fund terrorism, what you are doing, and if you have 

any ideas for how the U.S. Congress can help in that effort. 

Mr. KELLER. Thank you, Congressman. 

I think in the counter-ISIL context, for example, one of the most 

important things that we have been trying to do all along is make 

sure that ISIL is cut off from the financial system, whether it is 

a formal financial system or informal financial system. 

I think through a lot of good work, including from our Treasury 

Department, early on, they worked very closely with the Iraqis to 

cut off banks that were in ISIL-controlled territory from the international financial system. In addition, we have been working with 

the Iraqis to cut off money exchange houses and more informal operations that are engaged in hawala-type activities that are in 

ISIL-controlled territory from their ability to participate in——

Mr. PERRY. But it is not just ISIL-related. Hawala is used for 

various measures by numerous countries, not just ISIL and not just 

Iraq. So is there anything that the Congress can do in that regard 

that we haven’t done already? 

Mr. KELLER. Well, sir, I think you are exactly right, that it is not 

just ISIL-related. And I can tell you—if you indulge me, I will tell 

you one other thing that the State Department is doing, which I 

mentioned earlier, which are these capacity-building programs that 

increase the capacity for other countries on anti-money-laundering 

and counterterrorism finance programs, whether it is in their judiciary or prosecutorial services. 

These are things that can be very helpful—and we also work 

with the treasury departments around the world. These are things 

that can be very helpful as far as helping them——

Mr. PERRY. One final question in that vein, if the chairman will 

indulge me. Do you have any way to quantify when you say they 

can be helpful? So the American people are going to pay a certain 

amount to aid these other countries. How do we quantify the results? How do we quantify what we paid for and what we got? Is 

there any way? 

Mr. KELLER. That is a great question, Congressman. I would like 

to take that back and get you an answer in writing, and I will discuss that with——

Mr. PERRY. I look forward to your response. 

Mr. Chairman, I yield. 

Mr. POE. The gentleman yields back his time. 

Without objection, the document that Mr. Woody provided to 

both committees will be made part of the record. 

And, also, there may be more questions from other members of 

the committee. As soon as you receive those questions, we would 

want answers in 2 weeks. 

And I would encourage members to file those questions by tomorrow. 

And I want to thank the Armed Services Committee and the 

Subcommittee on Emerging Threats and Capabilities, Mr. Wilson 

from South Carolina, and the ranking member, Mr. Langevin from 

Rhode Island, for this joint subcommittee hearing. 

And the subcommittees are adjourned. 

[Whereupon, at 4:15 p.m., the subcommittees were adjourned.] 

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MATERIAL SUBMITTED FOR THE RECORD

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