Fnepare Office of Inspector General 

DEPARTMENT OF HOMELAND SECURITY 

Coordination Between FBI and ICE on 

Investigations of Terrorist Financing 

 

 OIG-07-55 July 2007 

Table of Contents 

Coordination Between FBI and ICE on Investigations of Terrorist Financing 

Executive Summary............................................................................................................................1

 Background...................................................................................................................................2

 Introduction..........................................................................................................................2

 History of FBI and ICE Coordination in Terrorism-Related Investigations........................3

 Development and Implementation of the MOA and the Collaborative Procedures ............5

 Results of Review .........................................................................................................................8

 FBI Review of ICE Financial Leads and Cases Yields Few Transfers ...............................8

 Transferred Cases Benefit When ICE Agents Are Detailed to JTTF ................................11

 ICE Agents’ Dissatisfaction with MOA May Lead to Failure to Pursue Leads with a 

 Terrorism Nexus ................................................................................................................17

 Changes to the MOA Are Unnecessary.............................................................................20

 Ineffective MOA Instruction to Field Agents....................................................................21

 Management Comments and OIG Analysis ...............................................................................25

Figures 

Table 1: Summary of Other ICE Law Enforcement Agreements .............................................8

Table 2: Summary of Ten Cases Transferred .........................................................................16

Appendices 

 Appendix A: Senator Grassley’s Letter ..................................................................................31

 Appendix B: Letter from Former Houston ICE SAC Webber to Senator Grassley ...............35

 Appendix C: The Memorandum of Agreement between DOJ and DHS................................38

 Appendix D: The Collaborative Procedures ...........................................................................41

 Appendix E: Purpose, Scope, and Methodology ....................................................................43

 Appendix F: ICE Response to Draft Report...........................................................................46

 Appendix G: FBI Response to Draft Report ...........................................................................49

 Appendix H: Major Contributors to this Report .....................................................................52

 Appendix I: Report Distribution............................................................................................53
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

Abbreviations 

CBP Customs and Border Protection 

DHS Department of Homeland Security 

DOJ Department of Justice 

EC Electronic Communication 

FBI Federal Bureau of Investigation 

ICE Immigration and Customs Enforcement 

JTTF Joint Terrorism Task Force 

JVU Joint Vetting Unit 

MOA Memorandum of Agreement 

NJTTF National Joint Terrorism Task Force 

OIG Office of Inspector General 

SAC Special Agent in Charge 

TFOS Terrorist Financing Operations Section 

USAO United States Attorney’s Office 

U.S.C. United States Code 

USCS United States Customs Service 

 

 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

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Executive Summary

We initiated this review jointly with the Department of Justice (DOJ) Office 

of Inspector General (OIG) at the request of Senator Charles E. Grassley, 

former Chairman of the Senate Finance Committee, to examine the 

effectiveness of a memorandum of agreement (MOA) between the 

Department of Homeland Security (DHS) and DOJ addressing the 

coordination of terrorist financing investigations. The OIGs reviewed the 

progress of the cases that were transferred under the MOA; evaluated the 

MOA’s effect on Immigration and Customs Enforcement’s (ICE) ability to 

use its expertise and experience in pursuit of terrorist financing; and 

determined whether the MOA was implemented effectively. We also 

considered whether the MOA should be revised and identified any other ICE 

agreements on law enforcement issues. 

In May 2003, DHS and DOJ signed an MOA to coordinate and deconflict 

terrorist financing cases between ICE and the Federal Bureau of 

Investigation (FBI). The MOA affirms the FBI as the lead on terrorist 

financing cases and produced a system for identifying and transferring ICE 

cases that have a nexus to terrorism to the FBI-led Joint Terrorism Task 

Forces (JTTFs). The MOA allows ICE agents to be detailed to the JTTFs to 

continue pursuing transferred cases. Some in ICE have expressed concerns 

about ICE’s ability to lend its financial crime expertise and experience to 

terrorist financing investigations. Further, Senator Grassley and some ICE 

agents stated a concern that a “turf war” mentality may be impacting such 

investigations. 

Our review determined that these concerns were unjustified. Of the more 

than 7,274 ICE cases and leads, only 11 were transferred from ICE to a 

JTTF under the MOA. We examined all 11 cases, interviewing the ICE and 

FBI agents assigned to them. Most of the cases have progressed well, 

suffering few, if any, problems in coordination or cooperation. The JTTFs 

fully employed the expertise and experience of the ICE agents who were 

detailed there to continue investigating the transferred cases. Because the 

transferred cases have been suitably investigated and ICE agents’ expertise 

and experience have been fully employed to the advantage of the 

investigations, we do not recommend modifications to the MOA. 

Nonetheless, we identified shortcomings with the implementation and 

management of the MOA by ICE and the FBI that has led to some problems 

in cooperation and coordination. We are making four recommendations, 

two each to ICE and the FBI, to overcome those issues. All four 

recommendations are resolved, however each remains open pending our 

receipt of additional information regarding ICE and the FBI’s proposed 

actions.
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

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Background 

Introduction 

Senator Charles E. Grassley, former Chairman of the Senate Finance 

Committee, requested that the DHS and DOJ OIGs conduct a joint review of 

allegations made by Joseph Webber, the former ICE Special Agent in 

Charge (SAC) in Houston, Texas, that the FBI intentionally delayed 

approval of an ICE application for a Title III electronic surveillance warrant 

in a terrorist financing investigation.1

 The Senator’s request letter is in 

Appendix A, and a copy of Mr. Webber’s letter to Senator Grassley stating 

Mr. Webber’s concerns is included in Appendix B. 

In addition, Senator Grassley asked that we jointly review whether the May 

2003 MOA between DHS and DOJ concerning terrorist financing 

investigations has been implemented effectively and assess whether it has 

affected ICE’s ability to use its expertise and experience in pursuing terrorist 

financing investigations. Senator Grassley also asked us to determine how 

the cases that were transferred under the MOA have progressed and 

determine whether the MOA should be revised and to determine whether 

ICE has any other agreements on law enforcement issues. 

The review addressing Senator Grassley’s concerns was conducted jointly 

by DHS and DOJ OIGs. To expedite delivery of the findings, the DHS and 

DOJ OIGs divided the review into two stages. The first stage was an 

examination of the facts underlying Mr. Webber’s allegation that the FBI 

intentionally delayed a specific ICE investigation. Because the principal 

allegation challenged FBI conduct, DOJ OIG led the production of the first 

stage report with DHS OIG concurrence. The results of that portion of our 

joint review were addressed in a report titled, A Review of FBI’s Actions in a 

Terrorist Financing Investigation Initiated by the U.S. Bureau of 

Immigration and Customs Enforcement, April 26, 2006, which was 

published by the DOJ OIG with DHS OIG concurrence. That report was 

completed and provided to Senator Grassley in April 2006. A redacted 

version of this report, deleting classified or law enforcement sensitive 

information, was also provided to Senator Grassley on August 31, 2006. 

The second stage of the review was a study of the effectiveness and impact 

of the MOA and the progress of other cases transferred under it. As with the 

first stage of the review, DHS OIG and DOJ OIG participated in the fact 

finding and analysis phases of the review. Because the principal focus 

1

 The Omnibus Crime Control and Safe Streets Act of 1968, Pub. L. 90-351, Title III, provided rules for obtaining wire 

tap orders in the United States. The law was codified in 18 U.S.C. §§ 2510-2520. 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

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involved ICE effectiveness and program issues, DHS OIG led the 

production of this second stage report, with the concurrence of DOJ OIG. 

History of FBI and ICE Coordination in Terrorism-Related 

Investigations 

The FBI and JTTFs

The FBI created the first JTTF in New York City in 1980 to coordinate 

federal, state, and local law enforcement efforts for the purpose of 

preventing, deterring, defeating, and responding to any terrorist attack 

within the United States. Since then, the number of JTTFs has expanded to 

more than 100 nationwide, including one at each of the FBI’s 56 field office 

locations. The majority of those JTTFs were established after the 

September 11 attacks. Although the JTTFs are maintained and managed by 

the FBI, other agencies and departments have detailed their agents to the 

JTTFs to assist in combating terrorism. Some of the other agencies involved 

in the JTTFs include the Internal Revenue Service, the Drug Enforcement 

Administration, and state and local law enforcement personnel. Currently 

there are almost 4,000 JTTF agents nationwide, including agents from the 

FBI and almost 700 agents from other federal government agencies, 

including ICE.2

The efforts of the JTTFs are coordinated through the National Joint 

Terrorism Task Force (NJTTF) at FBI headquarters. The purpose of the 

NJTTF is to provide support, coordination, and information to the various 

JTTFs, and between the JTTFs and FBI headquarters. 

Initially, the Attorney General relied upon the statutory authority granted by 

28 U.S.C. § 533 to assign the FBI “lead agency responsibilities in 

investigating all crimes for which it has primary or concurrent jurisdiction 

and which involve terrorist activities or acts in preparation of terrorist 

activities....” Several Presidential Decision Directives and the President’s 

National Strategy for Homeland Security of 2002 have further defined this 

leadership role. The FBI relies on the JTTFs to conduct counter-terrorism 

investigations throughout the United States. 

FBI’s Post-September 11 Counter-Terrorist Financing Efforts

In the aftermath of the September 11 attacks on the World Trade Center 

complex and the Pentagon, the FBI created the Financial Review Group to 

 

2

 See “Protecting America Against Terrorist Attack: A Closer Look at the FBI’s Joint Terrorism Task Forces,” FBI 

Archives, December 1, 2004, available at http://www.fbi.gov/page2/dec04/jttf120114.htm. 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

Page 4 

investigate the financing of the 19 hijackers and to ascertain fundraising 

schemes associated with the attacks. The mission of the Financial Review 

Group evolved to encompass investigation of all terrorist-related financial 

and fundraising activities. The Financial Review Group developed leads 

and distributed them to the JTTFs, as well as contributed to other 

organizations, such as the National Security Council’s Coordinating Policy 

Committee, by providing information on counter-terrorist funding activities. 

While the Financial Review Group was created as a response to the 

September 11 attacks, the FBI has had the jurisdiction and authority to 

investigate terrorist financing since at least 1994.3

In April 2002, the Financial Review Group was reorganized into the 

Terrorist Financing Operations Section (TFOS), with a similar mission to 

identify, disrupt, and dismantle terrorist-related fundraising activities, 

including using the tools enhanced by the USA PATRIOT Act.

4

 TFOS is 

responsible for coordinating, supporting, and enhancing the capabilities of 

terrorist financing investigations in the field and for managing terrorist 

financing cases in the JTTFs. The FBI has historically conducted financial 

investigations through its white collar crimes division. TFOS focuses that 

financial investigations expertise on terrorist financing cases. 

ICE’s Post-September 11 Counter-Terrorist Financing Efforts

The U.S. Customs Service (USCS) conducted financial investigations 

throughout its 200 year history, investigating financial crimes such as 

money laundering, bulk cash smuggling, intellectual property rights 

violations, and counterfeit goods trade and traffic. When DHS was 

established, ICE continued the USCS mission to investigate financial 

crimes, including those with a nexus to terrorism. 

In October 2001, in response to the September 11 attacks, the Department of 

the Treasury also began a new program to identify and disrupt terrorist 

financing programs operating within the United States or abroad. This task 

force effort, known as Operation Green Quest, was led by the USCS, but it 

also included a number of other agencies: the FBI; the Internal Revenue 

Service; the U.S. Secret Service; the Financial Crimes Enforcement 

Network; and the Bureau of Alcohol, Tobacco, Firearms and Explosives, 

among others. Operation Green Quest served a coordinating role, 

disseminating leads to the field and ensuring that different field 

investigations were not duplicated. By many accounts, Operation Green 

Quest was very successful. In its first year and a half, the program opened 

 

3

 Congressional Research Service Report, Terrorist Financing: U.S. Agency Efforts and Inter-Agency Coordination, 

August 3, 2005, p. 36. 

4

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

Act of 2001, Pub. L. 107-56, October 26, 2001, 115 Stat. 272. 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

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2,000 cases, resulting in 79 arrests, 70 indictments, and seizures of $33 

million. 

After the Homeland Security Act of 20025

 created DHS, agents from USCS 

were consolidated with agents from the Immigration and Naturalization 

Service into a new organization, ICE. Operation Green Quest also moved 

from USCS to ICE. Operation Green Quest continued until it was 

dismantled pursuant to the MOA between DHS and DOJ in May 2003. 

Conflicts Between ICE and FBI Counter-Terrorist Financing Efforts

Following September 11, 2001, coordination issues quickly arose between 

the FBI’s terrorist financing investigations and Operation Green Quest 

investigations. Both organizations and the DOJ Criminal Division’s 

Counter Terrorism Section, which guides prosecutions of terrorist financing 

cases, complained about a lack of information sharing and a general 

inability to coordinate investigative activities. The lack of coordination and 

communication led to overlaps in investigations and a potential for 

compromised investigations and risk to agents’ safety. For example, a DOJ 

employee told the OIGs that during one particular investigation, an ICE 

manager spoke about the details of an ongoing investigation on television, 

disclosing details the FBI considered to be classified. 

Development and Implementation of the MOA and the Collaborative 

Procedures 

Development of the MOA

Because of the problems in coordinating and deconflicting terrorist 

financing cases, DHS and DOJ negotiated the MOA in May 2003, ending 

Operation Green Quest and consolidating investigation of terrorist financing 

cases in the JTTFs.6 The stated purpose of the MOA was to enable the U.S. 

government to wage a seamless, coordinated campaign against sources of 

terrorist financing. The MOA recognized the FBI as the lead law 

enforcement agency in combating terrorism and terrorist financing. 

According to the MOA, ICE would continue to pursue terrorist financing 

investigations and operations through its participation in JTTFs. However, 

the MOA included a provision by which ICE could investigate terrorist 

financing outside the JTTFs provided that the FBI’s TFOS gave express 

approval. The MOA noted that both ICE and the FBI would continue 

 

5

 P.L. 107-296 (November 25, 2002). The ICE organization was announced on January 30, 2003, and USCS and 

Immigration and Naturalization Service agents were transferred to ICE in March 2003. 6

 Former DHS Secretary Tom Ridge and former Attorney General John Ashcroft signed the MOA on May 13, 2003. 

A copy of the MOA is included at Appendix C. 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

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independent investigations of money laundering and other financial crimes 

that were unrelated to terrorism. 

The MOA requires ICE to submit all “appropriate” money laundering or 

financial crime leads to the FBI to determine whether they are “related to 

terrorism or terrorist financing and to ensure effective deconfliction.” The 

MOA also directs that the TFOS Deputy Section Chief be a DHS employee, 

and it encourages ICE and JTTF members to share information related to 

terrorist financing cases to the fullest extent allowed by law and applicable 

agreements. The TFOS Section Chief, in consultation with the TFOS 

Deputy Section Chief, makes the final determination as to whether a case or 

lead is linked to terrorism or terrorist financing and whether it should be 

moved to the JTTF. According to the MOA, TFOS shall take the following 

factors into account when making a determination of whether a case is 

linked to terrorist financing: (1) strength of the terrorism or terrorist 

financing nexus; (2) impact of the investigation on non-terrorism matters; 

and, (3) stage and development of the respective investigations. Another 

provision of the MOA requires that DHS and DOJ develop specific, 

collaborative procedures for determining whether an ICE case or lead 

should be provided to TFOS and to enable TFOS to determine whether the 

case or lead is related to terrorism or terrorist financing. 

Implementation of the MOA

ICE and the FBI acted promptly to implement the MOA. ICE appointed an 

employee to serve as the Deputy Section Chief to TFOS, and former ICE 

Assistant Secretary Garcia signed the collaborative procedures on 

July 2, 2003. FBI Director Mueller signed the collaborative procedures on 

July 7, 2003. A copy of the collaborative procedures is included in 

Appendix D. 

The collaborative procedures required ICE to establish a Joint Vetting Unit 

(JVU) staffed by ICE and FBI personnel to serve as a central intake center 

for information from ICE agents about financial cases and leads that have a 

potential nexus to terrorism. ICE established the JVU, and in January or 

February 2004, the FBI appointed a TFOS Unit Chief to share JVU 

leadership with an ICE Unit Chief. The FBI JVU Unit Chief was given an 

office at ICE headquarters and access to all ICE databases. 

Under the collaborative procedures promulgated pursuant to the MOA, the 

JVU has responsibility for determining which leads and cases should be sent 

to the TFOS Deputy Section Chief for consideration. The JVU reviews case 

and lead information submitted by ICE field offices, such as names, 

addresses, nationality, and banking data. It also reviews reports from the 

FBI’s National Threat Center Section and the ICE Office of Intelligence. 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

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The JVU checks the information against appropriate FBI databases to learn 

whether the ICE information appears in any pending or closed FBI 

investigations. If the ICE lead or case is related to ongoing or closed FBI 

investigations, the JVU Unit Chief contacts the FBI or ICE field offices to 

get more information. Cases associated with FBI investigations are 

submitted to TFOS for review. In addition, regardless of whether FBI has a 

parallel case, if an ICE case involves potential criminal charges of material 

support of terrorism, the case information is presented to TFOS for review. 

The TFOS Section Chief and the Deputy Section Chief review the 

information on these cases and make a collaborative determination whether 

the case or lead must be transferred to the JTTF. A case involving charges 

of supporting terrorism must be transferred to the JTTFs regardless of 

whether FBI has a prior or parallel investigation. 

Initially, the JVU and TFOS allowed ICE and FBI field offices to coordinate 

cases, instructing them to submit to the JVU only matters that they could not 

reconcile locally. That practice changed after problems arose in the 

Houston, Texas case, the subject of the first report in this review. Now, all 

terrorism-related cases must be referred to the JVU, regardless of local ICE 

and JTTF field office cooperation and coordination.7

Other ICE Agreements Involving Law Enforcement Issues

In addition to the MOA, which is the subject of this review, ICE reported six 

agreements between it and other agencies on law enforcement issues. Four 

of the agreements existed before the creation of DHS and involved agencies 

that were transferred to ICE and Customs and Border Protection (CBP). 

Two agreements were established after the ICE was created. The six 

agreements, other than the MOA addressed in detail in this report, are 

included in the table below. 

 

7 A Review of FBI’s Actions in a Terrorist Financing Investigation Initiated by the U.S. Bureau of Immigration and 

Customs Enforcement. 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

Page 8 

Table 1: Summary of Other ICE Law Enforcement Agreements 

Agencies Involved Subject of Agreement Year 

Originally USCS (now ICE and CBP) and the 

Department of Commerce 

Export Enforcement 

Procedures 

1993 

Originally USCS (now ICE) and the Drug 

Enforcement Administration 

Title-21 Cross 

Designation Procedures 

1994 

(amended 

2000) 

Originally the Department of the Treasury (now ICE) 

and the U.S. Attorney General and the U.S. Postal 

Service Postmaster General 

Money Laundering 

Investigations 

1990 

Originally the Department of the Treasury (now ICE) 

and the U.S. Attorney General and the U.S. Postal 

Service Postmaster General 

International Drug and 

Money Laundering 

Investigations 

1994 

ICE, the U.S. Attorney’s Office, the FBI, the 

Department of Health and Human Services, the 

Department of Labor, and various state and local 

authorities in Missouri 

Human Trafficking April 2006 

ICE, the U.S. Attorney’s Office, and various state 

and local authorities in Texas, including the City of 

Austin (also includes representatives from the FBI, 

Department of Health and Human Services, the 

Department of Labor, and others) 

Established the Austin 

Human Trafficking 

Task Force 

April 2006 

Results of Review 

FBI Review of ICE Financial Leads and Cases Yields Few Transfers 

From July 2003 through December 2005, FBI and ICE personnel reviewed 

more than 7,274 leads, targets, and associates for possible transfer to JTTFs 

under the MOA. The review has occurred in three phases. FBI personnel 

conducted the first review of a select set of Operation Green Quest cases 

before the JVU was established. Later, ICE submitted to FBI headquarters 

the Operation Green Quest database of targets, leads, and associates for 

evaluation. The third review phase is the ongoing JVU evaluation of current 

cases or leads that ICE submits when cases develop a potential nexus to 

terrorism. 

The initial review began in July 2003 when TFOS sent an Electronic 

Communication (EC) to the field offices announcing the collaborative 

procedures and requesting FBI field agents to notify TFOS of any ICE cases 

that might have or might develop a nexus to terrorism. As a result, FBI field 

agents identified 30 such ICE cases. On October 30, 2003, a meeting was 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

Page 9 

held with FBI and ICE headquarters personnel, including TFOS, to examine 

the 30 ICE cases. At that meeting, ICE and the FBI agreed that 9 of the 30 

cases had a nexus to terrorism and should be transferred in accordance with 

the MOA. In November 2003, ICE notified the affected field offices that 

those nine cases were to be transferred to the local JTTFs. In addition, the 

ICE SAC for one other ICE case in Boston, Massachusetts, was notified that 

that case would not be transferred despite a nexus to terrorism. The decision 

not to transfer the case relied upon a provision within the MOA that allows 

terrorism-related cases to remain at ICE. The memorandum said that the 

case would not be transferred due to the cooperation and coordination 

shown by FBI and ICE agents in their investigations. 

The second review occurred when ICE provided the FBI with names and 

information from its Operation Green Quest database, including more than 

7,000 leads, targets, and associates of leads or targets. As of December 

2005, no cases were transferred to JTTFs as a result of the Operation Green 

Quest data review. 

The third review phase is ICE’s ongoing responsibility to transmit all leads 

and cases to the JVU that appear to have a nexus to terrorism. During the 

period between the establishment of the JVU and December 2005, ICE 

submitted 274 names and other identifying information to the JVU. 

However, none of the cases or leads submitted to the JVU transferred to the 

JTTFs as a result of this review process. 

TFOS transferred two additional cases to JTTFs upon the suggestion of 

other FBI personnel outside of the review process. In the first, a New 

Haven, Connecticut case, the JVU and TFOS were aware that ICE was 

investigating a case that was related to terrorism, but chose not to transfer it 

because the JTTF and ICE were cooperating in the investigation. However, 

others within FBI headquarters learned that ICE sought a search warrant in 

the case and suggested that TFOS transfer the case to the local JTTF. An 

ICE agent said that although the case was transferred to the JTTF in June 

2004, ICE was allowed to continue as the lead investigative agency, while 

conducting the investigation under the auspices of the JTTF. 

The second case transferred by means other than the review process was a 

Houston, Texas case. Again, the JVU and TFOS were aware of the case, 

but initially decided not to transfer it to a JTTF because they had not 

determined a nexus to terrorism. When other FBI headquarters officials 

learned that ICE sought an electronic surveillance warrant in that 

investigation, the TFOS Section Chief agreed to transfer the case to a JTTF. 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

Page 10 

 

The details of that investigation and its transfer were the subject of the first 

stage of this review.8

The 11 ICE cases that transferred to JTTFs under the MOA are: 

1. Newark, New Jersey 

2. Miami, Florida 

3. Los Angeles, California 

4. Washington, DC Alpha 

5. Washington, DC Beta 

6. Washington, DC Gamma 

7. Panama City, Florida 

8. Chicago, Illinois 

9. Orange County, California 

10. New Haven, Connecticut 

11. Houston, Texas 

Because the Houston, Texas case was reviewed in the DOJ report that was 

the first stage of this joint review, we did not include that case in this report. 

Instead, we examined the other ten cases transferred under the MOA. 

Of the ten cases, nine were active investigations at the time of the transfer. 

The target in the tenth case, Washington, DC Alpha, was indicted and fled 

the United States prior to the transfer of the case. Once transferred, the case 

could not be pursued further until the target returned to the country. We 

assessed the levels of coordination and cooperation between ICE and FBI 

agents prior to the transfer of the ten cases. Because further investigative 

activity was not indicated in the Washington, DC Alpha case, we assessed 

post-transfer interagency coordination and cooperation only for the nine 

active cases. 

8 A Review of FBI’s Actions in a Terrorist Financing Investigation Initiated by the U.S. Bureau of Immigration and 

Customs Enforcement. See fn 7, supra. 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

Page 11 

Transferred Cases Benefit When ICE Agents Are Detailed to JTTF 

In reviewing the cooperation and coordination of cases before and after they 

were transferred, the investigations benefited when ICE detailed its case 

agents to the JTTFs to assist with the investigations. In our interviews with 

ICE agents, we noted a positive shift in their impressions of FBI cooperation 

from when the ICE agents worked on the cases solely under ICE to when 

ICE agents worked on the cases through participation on the JTTFs. The 

ICE agents who had reported pre-transfer problems with the FBI said that 

cooperation and information sharing was good or improved after the case 

was transferred and they were detailed to the JTTFs. Those ICE agents who 

did not report pre-transfer problems and who were detailed to work on 

transferred cases said that the level of cooperation and coordination 

remained good after the ICE case was transferred. Moreover, all ICE agents 

who were detailed to JTTFs to work on cases transferred there reported that 

their experience and expertise had been fully used to pursue the targets. 

Those transferred investigations have been largely successful, according to 

ICE agents, with two cases resulting in convictions, an arrest in one case, 

and another close to indictment. We summarized pre-transfer and posttransfer progress in Table 2 on page 17. 

Pre-transfer Coordination and Cooperation

According to ICE agents, seven of the ten cases experienced problems with 

FBI cooperation prior to the transfer of the case to the JTTFs. Major areas 

of difficulty, according to the ICE agents, were FBI delays or refusals 

regarding investigative actions that required court approvals, such as search 

warrants, and FBI impediments to information sharing. ICE agents said that 

the FBI impeded or prevented ICE’s requests for search warrants, pen 

registers,9

 or Title III electronic surveillance warrants in four cases. The 

FBI would not share or was slow to share information from its 

investigations of the same or related targets, according to ICE agents from 

five cases. For example, the ICE agents said that among the information 

that the FBI would not share was information that ICE headquarters had 

obtained, and then shared with the FBI. The FBI classified the information 

and then refused to share it with ICE, claiming that ICE did not have a 

“need to know” the information. Agents from two of the five cases said that 

the FBI claimed that ICE agents had inadequate clearance levels or no “need 

to know.” In the third case, FBI headquarters was slow to review and at 

times required ICE agents to resubmit their security clearance 

documentation, which delayed the local JTTF from sharing the case 

 

9

 A pen register is a device that records the telephone numbers or internet protocol addresses accessed by a particular 

communication device (such as a telephone or a computer). Pen registers do not record the content of 

communications. 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

Page 12 

information for more than a year. In another case, the ICE agent familiar 

with it said that problems in information sharing occurred inadvertently as a 

result of the difficulty of exchanging information among several agencies. 

Other, more general issues were reported also, such as FBI reluctance to 

allow ICE agents to assist on search warrants that arose from information 

obtained by ICE during its investigation, and the FBI and the United States 

Attorney’s Office (USAO) not including ICE agents in meetings to discuss 

investigations associated with ICE cases. We also learned of one case in 

which FBI JTTF agents said that ICE impeded a JTTF investigation. We 

will discuss this case further in the following sections. 

We did not attempt to investigate fully the accusations that the FBI did not 

cooperate with ICE investigations before the investigations were transferred 

to the JTTFs. However, in an effort to learn the progress of three 

investigations that were transferred to JTTFs, we spoke with three FBI 

agents familiar with those cases. During those interviews, we inquired 

about ICE’s accusations of poor cooperation prior to case transfer. The FBI 

JTTF supervisor for the Miami, Florida case reported that the JTTF had an 

open investigation on some of the associates of the Miami, Florida ICE 

subject before ICE opened its case, and the ICE Miami, Florida case was a 

small part of a larger JTTF investigation. The FBI JTTF supervisor could 

not recall whether the FBI and the USAO replaced ICE’s pen registers with 

its own in April 2003. The FBI JTTF supervisor said that he had invited 

ICE agents to submit their security clearances and come to the JTTF to 

review the case information, but the ICE agents never accepted the offer. 

The FBI JTTF supervisor for the Los Angeles, California case said that ICE 

did not cooperate with the JTTF in its investigation of the Los Angeles, 

California target, despite a clear need, as the JTTF had an investigation on 

the target at the time ICE initiated its case on the same target. According to 

the FBI JTTF supervisor, cooperation between ICE and the FBI was good 

initially. For example, the day after ICE opened its Los Angeles, California 

investigation, the JTTF gave all the ECs related to the case to ICE, 

according to the JTTF supervisor. An ICE JTTF agent in Los Angeles 

confirmed that the FBI cooperated with ICE by sharing information and 

seeking assistance and expertise from all sources. The FBI JTTF supervisor 

said it was the USAO, not the JTTF, that decided to stop an ICE search 

warrant because the JTTF was considering a Title III warrant for its case. 

Cooperation with ICE broke down, according to the FBI JTTF supervisor, 

when ICE did not inform the JTTF of important activities, such as arresting 

the target, and attempting to block the FBI JTTF supervisor from 

interviewing the target. In addition, the FBI JTTF supervisor said that after 

the MOA was executed, the Los Angeles ICE SAC removed all ICE agents 

from the Los Angeles JTTF. Six months later the agents were returned to 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

Page 13 

the JTTF, but ICE field office management instructed the agents not to assist 

with any JTTF financial investigations. ICE prevented the ICE agent who 

had worked on the JTTF investigation that involved the Los Angeles, 

California target from continuing work on that investigation, and the 

investigation has suffered as a result, according to the FBI JTTF supervisor 

and an ICE agent. 

The Newark, New Jersey, Supervisory Special Agent we interviewed was 

not assigned to the ICE case until August 2004. He told the OIGs that he 

was not aware of any pre-transfer coordination problems between ICE and 

the FBI. 

Post-transfer Coordination and Cooperation

After the nine active cases were transferred to the JTTFs, ICE agents 

associated with six cases were detailed to the JTTFs to continue working on 

the investigations. In each of the six cases, the ICE agents and their 

supervisors reported that cooperation with the FBI on the JTTF was good or 

improved after the transfers. None said that the FBI tried to impede the 

investigation in any way, and all said that they had been given full access to 

FBI information and systems. The ICE agents reported that their experience 

and expertise were used in the investigations. They served as affiants on 

search warrants or arrest warrants in three of the six cases, and all reported 

either serving as the case agent or being provided equal standing with FBI 

JTTF agents. 

The six cases in which ICE agents have continued to work on the transferred 

investigations have progressed well, according to the ICE agents. The New 

Haven, Connecticut case has resulted in the target’s arrest, and the 

Washington, DC Beta and Washington, DC Gamma investigations have 

brought convictions. ICE agents working on the Panama City, Florida 

investigation said that they anticipated obtaining an indictment in the 

summer of 2006. Investigation is ongoing and active in the Chicago, Illinois 

case. The Orange County, California case concluded when the USAO 

declined prosecution. 

In the remaining three cases – Newark, New Jersey, Miami, Florida, and 

Los Angeles, California – ICE did not detail its case agent to the JTTFs 

when the investigation was transferred. Almost a year after the Newark, 

New Jersey case transferred, ICE detailed to the JTTF an agent who had not 

worked previously on the investigation.10 The ICE agent became the 

investigation’s case agent. According to the ICE agent, the FBI JTTF 

 

10 We interviewed the original ICE case agent and the agent’s supervisor, as well as the ICE agent who was detailed to 

the JTTF to investigate the case. 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

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agents handling the Newark, New Jersey case before him had done very 

little investigative work because the FBI had a large number of higher 

priority cases. However, an FBI agent familiar with the investigation said 

that one FBI JTTF agent had actively pursued the investigation. 

Once the ICE agent was detailed to the JTTF to work on the Newark, New 

Jersey case, the ICE agent actively pursued the investigation. The only 

problems the ICE agent reported were what he perceived as cumbersome 

and bureaucratic JTTF procedures that slowed the investigation. To 

overcome one of the procedural problems, the JTTF allowed the ICE agent 

to use ICE financial analysts to review some records. Using FBI analysts 

would have taken longer because a large volume of other priority work had 

to be completed. The investigation progressed until November 2005, when 

the ICE agent transferred to a new unit in ICE. The JTTF supervisor for the 

case said that he anticipated closing the criminal investigation because the 

target had slowed suspicious activities and recently obtained information 

may undercut the suspected link between the target and terrorism. 

As with the Newark, New Jersey investigation, when the Miami, Florida and 

Los Angeles, California cases were transferred, the ICE agents who had 

worked on the investigations were not detailed to the JTTFs. Unlike the 

Newark, New Jersey case, however, ICE did not detail another ICE agent to 

the JTTF to assist in the investigation, or assign the ICE agent already 

serving on the JTTF to the newly transferred case. Although ICE agents in 

the Miami, Florida and Los Angeles, California cases were invited to 

continue their investigations on the JTTFs, ICE field agents decided not to 

detail the ICE case agents due to the problems that they had experienced 

previously with the FBI and JTTFs.11 ICE involvement in the Miami, 

Florida and Los Angeles, California cases ended after the cases were 

transferred. Accordingly, the ICE agents did not know the current status of 

the Miami, Florida and Los Angeles, California cases. 

The Los Angeles, California and Miami, Florida FBI JTTF case supervisors 

also said that the transferred ICE criminal investigations have continued to 

be active, although neither the Los Angeles, California nor the Miami, 

Florida target has been indicted. The Miami, Florida investigation has 

resulted in four indictments against the target’s associates on mail fraud and 

money laundering charges. 

11 In addition, the ICE agents familiar with the Miami, Florida investigation said that after the case transferred, ICE 

was asked to provide financial investigation training to JTTF members and to allow the former ICE case agent to 

interview the target. An ICE agent said she refused the requests due to the poor cooperation that ICE had experienced 

with the FBI prior to the transfer of the case. 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

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In the Los Angeles, California case, the JTTF is monitoring pen registers, 

preparing an application for a Title III warrant, and has seized illegal drugs 

and money. JTTF agents have indicted one of the target’s associates on 

money laundering and illegal drug charges. The JTTF will attempt to use 

the indictment to obtain cooperation from the target and more information 

against the Los Angeles, California target, according to the FBI JTTF 

supervisor. 

In summary, before the nine active cases were transferred, ICE agents from 

seven of the cases reported poor levels of cooperation between ICE and the 

FBI. Once the cases were transferred, ICE agents were assigned to six of 

the cases. In the seventh, an ICE agent was detailed to the JTTF to work on 

the case almost one year later. All seven cases have progressed, some with 

tangible investigative outcomes. The ICE JTTF agents report good 

cooperation between the FBI and ICE agents involved with the cases. In the 

two cases in which ICE did not detail an agent to work on the case, the JTTF 

agents continued to pursue the investigations despite a lack of ICE 

involvement. Also, in these two cases the FBI reported, and an ICE agent 

familiar with one case confirmed, poor levels of cooperation from ICE. 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

Page 16 

Table 2: Summary of Ten Cases Transferred 

Case Before Case Transferred After Case Transferred 

ICE agents said 

that FBI 

Prevented or 

Delayed ICE 

Pen Registers, 

Search 

Warrants or 

Title IIIs 

ICE agents 

said that FBI 

Prevented or 

Delayed 

Information 

Exchange 

ICE Agent 

Working 

Case on 

JTTF 

Cooperation Case Status 

Newark, 

New Jersey 

Yes Yes Not initially. 

ICE detailed 

an agent to 

JTTF and 

case almost 

one year 

later. 

Good Suspicious activity has 

slowed. Links to terrorism 

may be dispelled. 

Criminal case may be 

closed or moved to 

another squad as a result. 

Miami, 

Florida 

Yes Yes, but FBI 

said it 

attempted to 

share 

information. 

No ICE field 

agents 

refused to 

train FBI 

agents and to 

conduct 

interview of 

target. 

4 targets associated with 

the ICE target were 

indicted. ICE target 

investigation moved to 

another JTTF team. 

Los 

Angeles, 

California 

Yes, but FBI 

said the USAO 

blocked the 

search 

warrants. 

No No Former ICE 

JTTF agent 

directed not 

to assist in 

investigation. 

Investigation ongoing. 

Pen registers up, illegal 

narcotics and cash seized. 

Preparing Title III 

application, and target’s 

associate indicted. 

Washington, 

DC Alpha 

Yes No Not 

Applicable 

Not 

Applicable 

Target indicted and fled 

U.S. before transfer to 

JTTF. 

Washington, 

DC Beta 

No Yes, but 

unintentional.

Yes Good One conviction; 

investigation ongoing. 

Washington, 

DC Gamma 

No Yes Yes Good Conviction. 

Panama 

City, Florida 

No Yes Yes Good Indictment pending. 

Chicago, 

Illinois 

No No Yes Good Investigation ongoing. 

Orange 

County, 

California 

No No Yes Good USAO declined 

prosecution in 2005. 

New Haven, 

Connecticut 

No No Yes Good Arrest. 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

Page 17 

ICE Agents’ Dissatisfaction with MOA May Lead to Failure to Pursue 

Leads and Cases with Potential Terrorism Nexus

ICE agents have misperceptions of the MOA and its procedures, and some 

resent the MOA and the FBI. As a result, ICE agents and headquarters 

officials reported some ICE agents fail to pursue leads and cases that might 

develop a nexus to terrorism. Further, agents may not be sending potential 

terrorism related leads and cases to the JVU or to the JTTFs. The failure to 

pursue or report terrorism related cases would violate the terms of the MOA 

and would be detrimental to national security. However, none of the ICE 

agents we interviewed provided specific instances of violations and agents 

spoke of the matter in more broad terms. We have no direct evidence that 

any ICE agent has actually been derelict. 

Nine agents from three field offices and ICE headquarters told us that they 

or other agents drop leads that appear to have a terrorism nexus, or choose to 

ignore a terrorism nexus and select violations unrelated to terrorism, in order 

to continue the case without FBI involvement. One senior field office 

manager provided a hypothetical choice between a case that does not have a 

potential nexus to terrorism and another that might develop such a nexus. 

The field office manager said that if a case agent came across two leads in 

the course of an investigation, one that led to illegal narcotics charges, and 

one that might result in a nexus to terrorism, the agent would develop the 

case on the narcotics-related lead. He added that agents should normally 

send the lead with the potential link to terrorism to the JTTF, but that this 

does not always happen. 

Within 18 months of its inception, Operation Green Quest had opened 2,000 

cases and obtained 79 arrests, 70 indictments, and seizures of $33 million. 

However, according to a June 25, 2003, memo from the ICE Deputy 

Assistant Director for Financial Programs, Operation Green Quest 

investigations rarely developed into terrorist financing cases. In 

confirmation of that assertion, only nine of the 2,000 cases were transferred 

initially. The other cases were primarily financial crimes without a 

terrorism nexus. While not conclusive, the fact that only two cases have 

been transferred to the JTTFs in the more than two years since the initial 

review of former Operation Green Quest cases supports the contention that 

ICE agents do not pursue leads and cases with potential terrorism links. 

However, there may be other reasons for the low number of transferred 

cases. Some ICE agents have suggested that before and immediately after 

September 11, 2001, terrorist financiers operated more openly, making them 

relatively easy to identify. Since then, however, terrorist financiers, 

realizing that their activities are likely being monitored by law enforcement, 

may have become more careful to avoid detection. In response to our draft 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

Page 18 

 

report, ICE officials named another reason why the number of cases 

transferred to JTTFs is low. The officials said that ICE now deconflicts 

certain leads with the FBI before ICE begins an investigation. Accordingly, 

leads that might have a terrorism nexus are transferred before ICE opens a 

case. 

Some ICE agents reported to us highly negative views and significant 

misinformation about JTTF handling of terrorist financing cases under the 

MOA. In our interviews ICE agents told us that: 

• The FBI-led JTTF does not actively pursue terrorist financing cases 

that transfer to the JTTF;12

• The FBI’s long-term intelligence gathering strategy precludes 

criminal convictions in some cases;13

• FBI JTTF agents have such a large caseload that they are unable to 

address terrorist financing cases;14 and, 

• The FBI is unable to lead terrorist financing cases under the JTTF 

because the FBI agents lack the expertise and experience to conduct 

such investigations.15

However, the evidence we encountered indicates that the FBI’s strategies, 

priorities, and alleged inexperience with financial crimes cases have not 

hampered the investigation of transferred ICE cases or prevented ICE agents 

from actively pursuing transferred cases when ICE has detailed an agent to 

the JTTF to assist in the investigation. The issues reported by ICE agents 

have not held back the progress of the six investigations that were 

transferred with the ICE case agent to the JTTF. As for the cases in which 

the ICE case agent was not detailed to the JTTF, Miami, Florida and Los 

Angeles, California, the JTTF has continued active criminal investigations 

in those cases. 

Regarding the FBI’s focus on other priorities, only one of the nine active 

cases that transferred, Newark, New Jersey, appeared affected. The ICE 

agent assigned to the Newark, New Jersey case almost a year after it went to 

the JTTF said that FBI JTTF agents had not pursued the investigation since 

the case was transferred because of their large case load of higher priority 

investigations. However, when ICE detailed an agent to the JTTF to work 

on the case, the investigation progressed satisfactorily. 

12 Five of these agents had experience with a transferred case that ICE perceives to be going poorly. One agent was 

involved in a case that was not transferred to the JTTF, but that agent encountered problems with the FBI. 13 ICE agents from three field offices made this allegation. 

14 ICE agents from two field offices discussed this issue. 

15 ICE agents from five field offices cited this concern. 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

Page 19 

Another misperception held by ICE agents is that ICE will not receive a 

share of the recognition for successful cases. ICE has received credit for 

some of the investigative successes in cases that have transferred to JTTFs. 

In three of the six cases in which the ICE case agent was detailed to the 

JTTF, the ICE agent was the affiant on court ordered investigative activities, 

such as search and arrest warrants. 

Other ICE agents said that they would not want a detail to the JTTFs to 

work transferred cases because they would not want to be governed by an 

FBI management structure, which they believed would treat them 

inequitably. A similar complaint was that in moving to the JTTF, an agent 

would lose operational control of the case. However, the ICE agents who 

were detailed to JTTFs to work on the investigations told the OIGs that they 

served as the case agents or had status equal to the FBI JTTF agents. No 

one complained of inequitable treatment, and some said that they wished 

ICE would encourage more agents to work on the JTTFs. 

Even though they had no JTTF experience, three agents from two field 

offices said that the MOA was a means by which the FBI could “take” or 

“steal” cases from ICE, and one of those agents believed that if a case were 

transferred, ICE would no longer have an opportunity to work it. However, 

the only transferred cases that were not investigated by ICE agents were 

cases where ICE chose not to detail the agent to the JTTF. When ICE 

detailed an ICE case agent with a case to the JTTF, the ICE agents said that 

they continued as the case agent or had equal standing with the other JTTF 

agents. The perception that the FBI takes cases away from ICE agents was 

not supported. 

Four ICE agents from two field offices said that the MOA undercuts the ICE 

mission to target support for terrorism by requiring terrorism-related cases 

to be transferred to the JTTFs. Although these agents recognize that the FBI 

has the lead on terrorism investigations, they said that ICE has the expertise 

to combat terrorist financing and a mission to protect the country from 

terrorist attacks as a member of DHS. However, ICE fulfilled its mission 

when it detailed its case agents to continue investigative work on ICE cases 

that transferred to the JTTFs. For example, when an ICE agent transferred 

with the case, three of the six resulted in arrests or convictions, two are 

being investigated actively, and one was closed after the USAO declined 

prosecution. By detailing ICE agents to the JTTFs to work terrorism-related 

cases, ICE can pursue its mission and leverage its experience and expertise 

in financial crimes with a nexus to terrorism. 

Two ICE headquarters employees acknowledged that ICE field agents 

suffered from misperceptions of the purpose and effect of the MOA. One 

ICE headquarters agent confirmed that ICE agents believe that the FBI uses 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

Page 20 

the MOA to steal ICE cases, but stated that such allegations were incorrect. 

Another senior ICE official said that ICE was “self-limiting” with regard to 

terrorist financing cases – that is, ICE agents would not pursue leads and 

cases with a potential link to terrorism, to avoid transfer to the JTTF. The 

headquarters employee said that the agents’ misperceptions of the MOA 

were partly to blame for their dissatisfaction with it. 

However, ICE management has not implemented measures to overcome its 

agents’ misperceptions. Aside from a few case-specific visits to the field, 

ICE management has not adequately communicated with its field agents to 

alleviate the misinterpretations of the MOA that have contributed to the 

alleged reluctance to pursue terrorism-related cases through the JTTFs. 

In summary, we encountered suspicion and hostility from ICE agents 

towards the MOA, but their claims about the way the JTTFs operate were 

unfounded. We were also extremely troubled that ICE agents would say 

that their agents declined to undertake a case of potential national security 

significance for such petty reasons. We know of no investigation that was 

ignored for such reasons, and there are alternative explanations for the low 

numbers of cases transferred after the initial review of the 2,000 

investigations. On closer examination, the discussions to which we were 

privy fell into more general characterizations of what “other agents” might 

do rather than the actions of agents we interviewed. Thus, while the 

hostility to the FBI’s dominance in the field of terrorist financing 

investigations is palpable, we have no direct evidence that any ICE agent 

has actually been derelict. 

However, even a discussion along these lines is unacceptable and violates 

the agent’s duties and responsibility. ICE should act to defuse the 

misperceptions about the MOA and ensure that the terms of the agreement 

are enforced and obeyed. 

Changes to the MOA Are Unnecessary 

ICE field agents recommended several changes to the MOA in order to 

address the issues that they perceived as hampering terrorist financing 

investigations. Three agents suggested that ICE be allowed to work terrorist 

financing cases in a coordinated manner with the JTTFs by allowing ICE 

concurrent jurisdiction. Coordinating but not transferring a case with a 

terrorism nexus has been successful in some instances. In Atlanta, Georgia 

and Boston, Massachusetts, ICE agents and JTTF agents were coordinating 

independent cases that appear to have a nexus to terrorism, but were not 

transferred to the JTTF. The ICE agents working on those cases are not on 

the JTTF, yet they report that the coordination between ICE and the JTTF is 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

Page 21 

working well. For example, the agents said that they served as the affiants 

on court documents and that the FBI has given ICE full access to JTTF case 

information. Criminal complaints have been issued in the case in Boston, 

Massachusetts. The ICE agents in Atlanta, Georgia said that the FBI 

requested their assistance and that the case is progressing. The agents said 

that coordinating cases without transferring them to the JTTFs works well. 

This sample of cases is too small to draw broad conclusions, but the fact that 

some investigations can operate successfully without an MOA does not 

mean all can. The MOA resulted from prior problems, and there is 

insufficient evidence supporting a need to relinquish FBI authority over 

terrorist financing investigations or to nullify the MOA. We therefore 

disagree with the suggested changes proposed by some ICE agents. In fact, 

the evidence indicates that the cases that were transferred from ICE to the 

JTTFs have been pursued aggressively, and when ICE agents have been 

detailed to the JTTFs to continue working on the investigations, their 

expertise has been used fully. 

Moreover, before the MOA was in place, ICE and the FBI complained of 

poor coordination and communication. The FBI said that terrorist financing 

cases might have been compromised due to those conditions. Now, when 

cases are worked on JTTFs, a single chain of command ensures coordination 

and information exchange. In addition, with almost all transferred cases, the 

FBI has employed the expertise of ICE agents to bring the full weight of the 

law to investigations of terrorist financing. 

Ineffective MOA Instruction to Field Agents 

ICE management has not communicated the MOA’s purpose and procedures 

adequately to its field agents. In addition, FBI agents have little 

understanding of the MOA and its procedures. As a result, not only are 

some ICE and FBI agents confused about the MOA’s procedures and effect, 

but ICE agents may be dropping leads and cases as a result of their 

misperceptions. The fact that misperceptions persist suggests that ICE and 

FBI’s outreach and education on the MOA remain ineffective. 

ICE Instruction to Field Agents

In addition to the misperceptions discussed in previous sections, ICE agents 

do not have a clear understanding of basic screening procedures for 

determining whether a case should be transferred to a JTTF under the MOA. 

Ten ICE agents from eight field offices said that cases with a potential nexus 

to terrorism should be vetted through local FBI and JTTF offices, but they 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

Page 22 

did not realize that the JVU should also receive that information for the 

same purpose. 

ICE made its field offices aware of the MOA and collaborative procedures 

through three memoranda issued in 2003. The first memorandum was sent 

to the field offices on June 2, 2003, from the ICE Interim Director of 

Customs Investigations. It notified all ICE SACs of the MOA and the 

termination of Operation Green Quest. The ICE Deputy Assistant Director 

for Financial Programs sent a second memorandum to all SACs on 

June 25, 2003, which served as a reminder of the MOA and noted that the 

MOA would likely affect only a small number of ICE investigations because 

Operation Green Quest leads rarely involved terrorist financing. Finally, 

ICE outlined the provisions of the MOA and introduced the collaborative 

procedures to all ICE SAC offices in a third memorandum dated 

August 7, 2003. Since that memorandum, there has been no other written 

communication from ICE headquarters to the field offices regarding the 

MOA or its related procedures. 

In addition to issuing the memoranda, the ICE Deputy Section Chief of 

TFOS briefed the ICE SACs on the MOA and its procedures at two annual 

ICE SAC conferences. However, officials from ICE headquarters have not 

communicated directly with field office financial crimes supervisors or 

agents about the MOA and its procedures. 

ICE only communicated the procedures and purpose of the MOA to ICE 

SACs through three memoranda and through the annual SAC conferences, 

and did not attempt to train its field agents or supervisory agents about the 

MOA. Relying on the ICE SACs to present the information and ensure that 

it is understood has not served as an effective mechanism to inform agents. 

As a result, serious misperceptions are hampering effective enforcement of 

the MOA and, according to agents and officials alike, may cause ICE agents 

to consider abandoning leads and cases, rather than risk having them 

transferred to JTTFs. Given the level of misunderstanding and even 

hostility towards the MOA, ICE officials should implement measures to 

educate field agents on the MOA and its procedures, the successes of the 

transferred cases, and the satisfactory experiences ICE agents encountered 

when detailed to the JTTFs. 

FBI Instruction to Field Agents

The FBI’s implementation of the MOA was more thorough than ICE’s, but 

also had shortcomings. The FBI issued five ECs to the field, the most recent 

in February 2005, and provided training on the MOA and its procedures to 

the field agents. 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

Page 23 

 

The first EC was sent to FBI field offices in May 2003, shortly after the 

MOA was finalized. The EC summarized the MOA and required each field 

office to send a designated terrorist financing coordinator to a headquarters 

meeting to learn more about the MOA and TFOS. The FBI notified all field 

offices of the establishment of the collaborative procedures on July 8, 2003, 

via an EC. The EC also required each office to notify TFOS of any ICE 

financial investigations that had an existing or developing nexus to 

terrorism. 

The FBI sent two ECs in 2004, reminding the field offices of the MOA and 

the procedures established to fulfill it. On April 12, 2004, FBI headquarters 

sent an EC to all FBI field offices, legal attaches overseas, and International 

Terrorism Operations Section personnel.16 The EC again summarized the 

MOA and added that TFOS would provide overall operational command to 

terrorist financing investigations on the JTTFs. It also stressed the 

importance of information sharing with members of the JTTFs and ensuring 

that ICE agents detailed to the JTTFs are given a “fully integrated role.” 

Three months later, on July 13, 2004, TFOS distributed an EC to FBI field 

offices updating them on the implementation of the MOA, explaining the 

role of the JVU, and noting that ICE agents detailed to the JTTFs to 

continue working on the transferred cases should be given “significant 

roles” in the investigations. 

After difficulties arose in the Houston, Texas case, the FBI sent another EC 

to the field. The February 2005 EC from the TFOS Section Chief reminded 

the FBI field offices to comply with the MOA and cautioned that there had 

been instances where FBI field offices had not accepted ICE field office 

recommendations to transfer terrorist financing cases to the JTTFs. Those 

failures, the EC noted, proved problematic for FBI headquarters. The EC 

included copies of the MOA and collaborative procedures. 

In addition to the ECs, the FBI has provided various training sessions to its 

field office personnel on the MOA and its procedures. The first training was 

given in 2003 to field office terrorist financing case coordinators who had 

been appointed in accordance with the May 2003 EC. Since that initial 

training, training has been repeated each year at the annual terrorist 

financing case coordinators meeting in Washington, DC. After issues arose 

with the Houston, Texas case in 2005, the FBI began including MOA 

procedures and compliance in the regular training TFOS administers to 

JTTF field offices. Part of the training emphasizes that the transfer of cases 

under the MOA is not to be made informally at the discretion of the field 

16 The International Terrorism Operations Section is a part of the Investigative Operations Branch of the FBI. It 

“supports, coordinates, and provides oversight of FBI international counterterrorism operations. 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

Page 24 

offices. The MOA and its procedures are also addressed in an annual 

conference of FBI supervisory special agents. 

Despite its ongoing communications and training, several FBI agents with 

whom we spoke did not know that ICE should vet cases through the JVU if 

they suspect a nexus to terrorism. Five of the seven FBI field office 

personnel with whom we spoke were not familiar with the JVU. As FBI 

field offices do not have a large role in the vetting process supporting the 

MOA, the field agents’ confusion over vetting procedures is not very 

problematic. However, it would be advantageous for FBI agents to 

understand the purpose and importance of the vetting process under the 

MOA. Doing so would enhance coordination activities with TFOS and 

ensure that the JTTFs do not agree to coordinate ICE cases with a nexus to 

terrorism without express approval from TFOS. 

For the cases that were transferred, FBI agents, either through the ECs and 

training or by their own initiative, have followed the MOA’s instruction that 

ICE agents be fully integrated into the investigation, factors which have 

contributed to the success of the MOA. The FBI should ensure that its field 

offices continue the practice of making detailed ICE agents the case agents 

for transferred ICE cases and provide the ICE agents the opportunity, when 

appropriate, to serve as the affiant on search and arrest warrants. ICE agents 

who developed cases that were transferred to the JTTFs have a sense of 

ownership and pride in their investigations. Additionally, they have 

expertise and experience not just in the transferred case, but also in general 

immigration and customs matters. Their special expertise should be 

recognized to best pursue all investigative avenues that may arise in a case. 

We are recommending that the Assistant Secretary for ICE: 

Recommendation 1: Routinely communicate with ICE agents the purpose 

and impact of the MOA and its collaborative procedures, as well as the 

successes of cases in which ICE case agents transferred to JTTFs to 

continue investigating a case. 

Recommendation 2: Convey to ICE agents their responsibility to report 

potential terrorism leads and cases to the JVU. Promote the detailing of ICE 

agents to the JTTFs by communicating that working on the JTTFs is a 

priority for ICE, for the department, and an opportunity for ICE to 

investigate terrorist financing. 

We are recommending that the FBI Director: 

Recommendation 3: Ensure that the FBI field agents understand the role 

of the JVU and understand that ICE cases with a nexus to terrorism will be 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

Page 25 

investigated solely through the NJTTF, JTTFs, and TFOS, except as 

expressly approved by TFOS. 

Recommendation 4: Encourage FBI field offices to continue full 

utilization and integration of detailed ICE agents investigating transferred 

ICE cases. 

Management Comments and OIG Analysis 

We evaluated the technical and formal comments submitted by ICE and the 

FBI and have made changes to the report where we deemed appropriate. 

Below is a summary of each bureau’s written response to the report’s 

recommendations and our analysis of the response. A copy of ICE’s 

response, in its entirety, is recorded in Appendix F and Appendix G contains 

the FBI response, in its entirety. 

The draft report was provided to ICE and the FBI under the provisional 

classification of “SECRET” and with it was an unclassified summary. Both 

the ICE and the FBI responses address the report and the summary. 

However, as the report has subsequently been determined not to contain 

classified information, the summary is not necessary and will not be 

published. Accordingly, we performed an analysis on only the responses to 

the report. 

Further, we made three recommendations to ICE in the draft report, but 

subsequently have combined two of those recommendations. In this report, 

recommendation 1 and 2 are directed to ICE, and recommendation 3 and 4 

are directed to the FBI. Further, the FBI provided alternative language for 

recommendation 3 to address any potential confusion from “informal” 

coordination if a potential or probable terrorism nexus is developed. We 

agree with the FBI’s proposed changes to the recommendation and have 

modified it. 

ICE Response 

ICE made two comments that merit modifying the report and two comments 

that do not. First, we agree with ICE that the report should note the FBI 

appointed a TFOS Unit Chief as the co-lead of the JVU. Second, we also 

agree the language about statements that ICE agents may fail to pursue 

terrorism-related cases should be changed. We modified the report 

accordingly. 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

Page 26 

However, we did not modify the report in response to two comments that 

dispute the accuracy of the report’s findings related to ICE’s actions to 

inform and educate their investigators of the MOA and collaborative 

procedures. We asked several ICE officials and ICE investigators in the 

field to describe any training or other information they received related to 

the MOA and collaborative procedures. The report reflects what they said. 

In addition, during our fieldwork we requested ICE to provide: 

 “Any policies, instructions, directives, procedures, notices, 

etc. related to submission of names, email addresses, 

telephone numbers, or other identifying information to DOJ 

in accordance with the MOA.” 

 “All such documents since the implementation of the MOA 

through the present.” 

 “All communication to ICE field offices.” 

Other than the three memoranda referenced in the report, we did not receive 

any documents from ICE in response to our request. 

ICE Response to Recommendations 

Recommendation 1: Routinely communicate with ICE agents the purpose 

and impact of the MOA and its collaborative procedures, as well as the 

successes of cases in which ICE case agents transferred to JTTFs to 

continue investigating a case. 

ICE Response: In its response, ICE listed a variety of activities by which it 

communicates with its agents about the MOA and successful ICE 

investigations. ICE said it regularly disseminates the MOA and the 

collaborative procedures that govern ICE’s responsibilities under the MOA, 

and that those documents are available on ICE’s internal website. ICE 

reported it has provided guidance and instruction to all Special Agents-inCharge, Deputy and Assistant Special Agents-in-Charge, and financial 

group supervisors on their responsibilities under the MOA. ICE said that 

the MOA and its procedures were presented in basic and advanced agent 

training classes as well. Additionally, ICE reported that it uses various 

communication methods, such as the ICE website and news releases, to 

provide employees information about all successful ICE investigations on 

both JTTF and non-JTTF related cases. 

OIG Analysis: ICE’s response outlines efforts to communicate with its 

agents about the MOA, the collaborative procedures, and investigative 

successes. However, ICE’s outlined activities do not fully address the intent 

of this recommendation, which is: to improve ICE agents’ attitude toward 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

Page 27 

the MOA, the collaborative procedures, and working with the JTTFs. To 

dispel the negative attitude toward the MOA, ICE needs to instill a better 

understanding of the purpose and impact of the MOA and collaborative 

procedures. This understanding would help dispel the negative attitude 

some ICE agents have toward the MOA, the collaborative procedures, and 

working on the JTTFs. 

We made this recommendation because many ICE agents expressed dislike 

for MOA and for investigating a terrorism-related case on a JTTF. We 

determined, however, that ICE agents who were detailed to JTTFs to 

continue working their transferred cases were satisfied with the JTTF 

environment, and most achieved successes with their cases. By contrast, 

none of the transferred cases for which an ICE agent refused a detail to the 

JTTF achieved the same level of investigative success. 

This recommendation is resolved, but remains open pending our receipt of 

additional information. To close this recommendation, ICE should provide 

us with the content of its memoranda, training materials, and other 

communications that are directed at educating its agents about the MOA and 

collaborative procedures, as well as successful investigations on the JTTFs. 

The content of those documents should reflect the MOA’s purpose to align 

ICE and FBI efforts to pursue terrorism-related cases; describe the limited 

impact of the MOA on ICE; and, explain the successes that ICE agents have 

achieved in terrorism-related cases while working on the JTTFs. In 

addition, the past and future distribution frequency for each of those 

communications should be indicated. 

Recommendation 2: Convey to ICE agents their responsibility to report 

potential terrorism leads and cases to the JVU. Promote the detailing of ICE 

agents to the JTTFs by communicating that working on the JTTFs is a 

priority for ICE, for the department, and an opportunity for ICE to 

investigate terrorist financing. 

ICE Response: ICE responded it continues to convey the importance of the 

proper handling and sharing of potential financial terrorism leads. ICE’s 

increased education, understanding, and promotion of the MOA have 

resulted in a shift in methodology of how terrorist finance investigations are 

worked collaboratively between ICE and the FBI. Cases are now vetted and 

coordinated at the onset, both at the field and headquarters level and ICE 

agents share information and deconflict cases with the JTTFs. ICE reported 

those efforts have significantly minimized the number of ICE cases that 

have been moved to the JTTF, and have promoted a better coordination 

between ICE and the FBI. As a result of those improvements, ICE suggests 

the need for the MOA be re-examined. ICE also said that it contributes 

significantly to the JTTFs, and will continue to detail agents to the JTTFs on 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

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a case-by-case basis. Finally, ICE reported that all of its criminal 

investigative work is a priority. 

OIG Analysis: In its response, ICE provided some information about the 

effect of its educational efforts. This recommendation is resolved, but 

remains open pending our receipt of additional information. To close this 

recommendation, ICE should provide more detailed information regarding 

the actions it has taken, including documentation of its efforts to educate 

ICE investigators about their duties under the MOA and collaborative 

procedures, and to promote the detailing of its investigators to the JTTFs. 

ICE should also provide documentation to support the number of ICE agents 

working on JTTFs for fiscal years 2004 through 2006. 

ICE reported that all criminal acts investigated by ICE, are a priority for 

ICE. However, some ICE agents said if a lead or a case developed a 

potential terrorism nexus, an ICE agent would not pursue the lead or the 

terrorism aspect of the case because the lead or case would have to be 

transferred to a JTTF. 

Regarding ICE’s response that its efforts have changed the deconfliction and 

information exchanges between ICE and the JTTFs, we want a step-by-step 

explanation of how an ICE agent currently shares information about 

potential terrorism leads and cases with the JVU and JTTFs. 

ICE also suggested that the necessity of the MOA be re-examined in light of 

the improved coordination between ICE and FBI. One of our objectives was 

to examine whether the MOA should be abolished. Our fieldwork does not 

support terminating the MOA or that its necessity be re-examined. 

FBI Response

The FBI made a comment that warrants modifying the report. It said the 

discussion of the second ICE case to transfer to a JTTF, by means other than 

the review process, should be characterized differently. The text should 

state that the JVU and TFOS did not transfer the case initially because it did 

not have a terrorism nexus. The case was transferred after TFOS discovered 

such a nexus. 

We modified the report to state the TFOS managers did not transfer the case 

initially because they did not determine a terrorism nexus. However, the 

report’s description of why the case eventually was transferred reflects the 

information that we received from many sources. Accordingly, we did not 

make a change to the description of the transfer. 
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FBI Response to Recommendations 

Recommendation 3 (formerly 4): Ensure that the FBI field agents 

understand the role of the JVU and understand that ICE cases with a nexus 

to terrorism may not be “coordinated” without express approval from TFOS. 

FBI Response: The FBI responded it and ICE both desire for their agents 

to coordinate matters with each other and the way the recommendation is 

currently worded might be too ambiguous. The FBI provided alternative 

language for the recommendation to address any potential confusion from 

informal coordination if a potential or probable terrorism nexus is 

developed. The FBI reported the TFOS training to JTTFs and Terrorists 

Financing Coordinators stresses that if there is a doubt or question by field 

agents or field supervisors in these matters, TFOS should be contacted for 

guidance. The FBI did not provide additional information on how or 

whether it would fulfill the intent of the recommendation further. 

OIG Analysis: This recommendation is resolved, but remains open 

pending our receipt of additional information. However, we have no direct 

authority to compel the FBI to provide such information. We do encourage 

the FBI to regularly disseminate information explaining the role of the JVU 

and the prohibition on coordinating cases without TFOS approval to its field 

agents. Documentation from the FBI to this effect would close this 

recommendation. 

In addition, we agree with the FBI’s proposed changes to the 

recommendation and have modified it accordingly. 

Recommendation 3 (Revised): Ensure that the FBI field agents understand 

the role of the JVU and understand that ICE cases with a nexus to terrorism 

will be investigated solely through the NJTTF, JTTFs, and TFOS, except as 

expressly approved by TFOS. 

Recommendation 4 (formerly 5): Encourage FBI field offices to continue 

full utilization and integration of detailed ICE agents investigating 

transferred ICE cases. 

FBI Response: In its response, the FBI concurred with our 

recommendation, but did not indicate how it would fulfill it. 

OIG Analysis: This recommendation is resolved, but remains open 

pending our receipt of additional information. However, we have no direct 

authority to compel the FBI to provide such information. We do urge the 

FBI to encourage its field offices to fully utilize and integrate ICE agents 
Coordination Between FBI and ICE on Investigations of Terrorist Financing 

Page 30 

working at JTTFs on transferred ICE cases. Documentation from the FBI to 

this effect would close this recommendation. 
Appendix A 

Senator Grassley’s Letter

Page 31 

Coordination Between FBI and ICE on Investigations of Terrorist Financing 
Appendix A 

Senator Grassley’s Letter

Page 32 

Coordination Between FBI and ICE on Investigations of Terrorist Financing 
Appendix A 

Senator Grassley’s Letter

Page 33 

Coordination Between FBI and ICE on Investigations of Terrorist Financing 
Appendix A 

Senator Grassley’s Letter

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Appendix B 

Letter from Former Houston ICE SAC Webber to Senator Grassley 

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Appendix B 

Letter from Former Houston ICE SAC Webber to Senator Grassley

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Appendix B 

Letter from Former Houston ICE SAC Webber to Senator Grassley

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Appendix C 

The Memorandum of Agreement between DOJ and DHS

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Appendix C 

The Memorandum of Agreement between DOJ and DHS

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Appendix C 

The Memorandum of Agreement between DOJ and DHS

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Appendix D 

The Collaborative Procedures

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Appendix D 

The Collaborative Procedures 

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Appendix E 

Purpose, Scope, and Methodology 

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Purpose, Scope, and Methodology 

This review was initiated at the request of Senator Charles E. Grassley, 

former Chairman of the Senate Committee on Finance, after receiving a 

complaint from the former ICE SAC in Houston that the FBI improperly 

delayed the approval of an application for a criminal wiretap warrant in an 

ICE terrorist financing investigation named the Houston, Texas case. 

Senator Grassley asked DHS and DOJ OIGs to conduct a joint review of the 

Houston, Texas investigation, as well as a review of the implementation and 

effectiveness of an MOA between DHS and DOJ that governed the conduct 

of terrorist financing investigations by ICE and the FBI. Senator Grassley 

asked that in assessing the MOA we review the ten investigations that were 

transferred under the MOA to the JTTFs, (those other than the Houston, 

Texas investigation that was the subject of the ICE SAC’s complaint) to 

determine whether they had suffered delays similar to those in the Houston, 

Texas case and whether ICE expertise and experience in financial crimes 

cases was being leveraged to enhance investigations of terrorist financing. 

We were also asked to determine what modifications, if any, should be 

made to the MOA. At a meeting on June 9, 2005, due to the broad nature of 

the request, Senator Grassley’s staff agreed that our review would not need 

to address Senator Grassley’s seventh question regarding ICE’s 

investigative priorities and that the eighth question would be limited to a 

survey of agreements on law enforcement issues. Appendix A contains a 

copy of the Senator’s request letter. 

The review was divided into two stages; the first stage examined the former 

ICE SAC’s complaint, and the second reviewed the implementation and 

effectiveness of the MOA and progress of the ten transferred cases. DHS 

and DOJ OIGs participated equally in both stages of the review. Each was 

active in the planning, fact-finding, and analysis tasks for the review. To 

expedite delivery of the reviews, DOJ OIG was responsible for drafting the 

report of the findings and conclusions of the first stage of the review.17 DOJ 

OIG issued the first stage report upon receiving concurrence and approval 

from DHS OIG. Similarly, DHS OIG drafted this second stage report, and 

obtained the DOJ OIG’s concurrence and approval prior to its issuance. 

The overall objectives of this review were to: 

• Assess the progress of the ten transferred cases; 

17 A Review of FBI’s Actions in a Terrorist Financing Investigation Initiated by the U.S. Bureau of Immigration and 

Customs Enforcement. See fn 7, supra. 
Appendix E 

Purpose, Scope, and Methodology 

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• Examine the implementation of the MOA; 

• Evaluate whether ICE expertise can be applied in terrorist financing 

cases under the terms of the MOA. 

• Determine whether the MOA should be revised. 

To accomplish the fact-finding portion of our second stage review, we spoke 

with senior ICE, FBI, and DOJ officials familiar with the MOA and ICE’s 

terrorist financing investigations to learn about the MOA’s history, 

implementation, and impact. 

To determine the progress of the ten cases, we conducted telephone 

interviews of 29 ICE case agents, supervisors, Resident Agents in Charge, 

and Assistant Special Agents in Charge, who were responsible for the ICE 

cases before they were transferred.18 In three cases, the ICE agents did not 

know the progress of the investigation subsequent to the transfer of the case 

to the JTTF.19 To discover subsequent progress, we interviewed three FBI 

JTTF agents who were involved with the cases after their transfer. 

To ascertain the success of the implementation of the MOA and determine 

its effectiveness and impact, we asked the 29 ICE agents and the three FBI 

JTTF agents to describe the MOA and its procedures, as well as its effect. 

We asked the same questions of five ICE financial investigation group 

supervisors in five geographically diverse cities from which ICE 

investigations had not been transferred.20 We also conducted a telephone 

interview of FBI field personnel in Seattle, Washington to confirm 

information that we had received from an ICE agent there. 

Additionally, we conducted an interview of an ICE Assistant Special Agent 

in Charge from the Washington, DC field office because he requested to 

speak to us, and we interviewed an ICE JTTF agent in Miami, Florida who, 

we learned, had very limited involvement with one of the cases that had 

been transferred. 

18 The cases originated in ICE field offices located in Chicago, Illinois; Los Angeles, California; Miami, Florida; New 

Haven, Connecticut; Newark, New Jersey; Orange County, California; Panama City, Florida; and Washington, DC. 

Three of the investigations that were transferred to the JTTF originated in the Washington, DC field office. The six 

other cities each had one case that was transferred. For some of the investigations, we interviewed more than one ICE 

case agent because during the life of the investigation more than one agent had been assigned. 

19 Miami, Florida; Los Angeles, California; Newark, New Jersey. The Miami, Florida and Los Angeles, California 

agents did not have any knowledge of case progress after the investigation transferred to the JTTF. The Newark, New 

Jersey ICE agent had been detailed to the JTTF to work on the transferred investigation and was knowledgeable of 

case progress until very recently when he was re-assigned and had ceased to be active in the JTTF investigation. 20 Atlanta, Georgia; Boston, Massachusetts; Denver, Colorado; Minneapolis/St. Paul, Minnesota; and Seattle, 

Washington. 
Appendix E 

Purpose, Scope, and Methodology 

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We obtained and reviewed multiple documents from ICE, the FBI, and DOJ 

that assisted in our review. We also toured the JVU facility to better 

understand its operations. 

We conducted our fieldwork between November 2005 and January 2006. 

Our work was conducted under the authority of the Inspector General Act of 

1978, as amended, and according to the Quality Standards for Inspections 

issued by the President’s Council on Integrity and Efficiency. 
Appendix F 

ICE Response to Draft Report

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Appendix F 

ICE Response to Draft Report

Page 47 

Coordination Between FBI and ICE on Investigations of Terrorist Financing 
Appendix F 

ICE Response to Draft Report

Page 48 

Coordination Between FBI and ICE on Investigations of Terrorist Financing 
Appendix G 

FBI Response to Draft Report

Page 49 

Coordination Between FBI and ICE on Investigations of Terrorist Financing 
Appendix G 

FBI Response to Draft Report

Page 50 

Coordination Between FBI and ICE on Investigations of Terrorist Financing 
Appendix G 

FBI Response to Draft Report

Page 51 

Coordination Between FBI and ICE on Investigations of Terrorist Financing 
Appendix H 

Major Contributors to this Report

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Department of Homeland Security OIG

David Hiles, Chief Inspector, Office of Inspections 

Marcia Moxey Hodges, Chief Inspector, Office of Inspections 

Elizabeth Kingma, Senior Inspector, Office of Inspections 

Michelle Streit, Inspector, Office of Inspections 

Michael Zeitler, Inspector, Office of Inspections 

Department of Justice OIG

Patricia A. Sumner, Investigative Counsel, Oversight and Review Division 

Judy A. Sutrich, Program Analyst, Oversight and Review Division 
Appendix I 

Report Distribution

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Department of Homeland Security

Secretary 

Deputy Secretary 

General Counsel 

Chief of Staff 

Deputy Chief of Staff 

Executive Secretariat 

Assistant Secretary, Policy 

Assistant Secretary, Public Affairs 

Assistant Secretary, Legislative and Intergovernmental Affairs 

Assistant Secretary, Immigration and Customs Enforcement 

Director, ICE Office of Investigations 

Chief Security Officer 

Chief Privacy Officer 

DHS OIG Liaison 

ICE Audit Liaison

Federal Bureau of Investigation

Assistant Director for the Inspection Division 

Office of Management and Budget

Chief, Homeland Security Branch 

DHS’ Program Examiner 

Congress

Congressional Oversight and Appropriations Committees, as appropriate 
Additional Information and Copies 

To obtain additional copies of this report, call the Office of Inspector General (OIG) at 

(202) 254-4199, fax your request to (202) 254-4305, or visit the OIG web site at 

www.dhs.gov/oig. 

OIG Hotline 

To report alleged fraud, waste, abuse or mismanagement, or any other kind of criminal 

or noncriminal misconduct relative to department programs or operations: 

• Call our Hotline at 1-800-323-8603; 

• Fax the complaint directly to us at (202) 254-4292; 

• Email us at DHSOIGHOTLINE@dhs.gov; or 

• Write to us at: 

DHS Office of Inspector General/MAIL STOP 2600, Attention: 

Office of Investigations - Hotline, 245 Murray Drive, SW, Building 410, 

Washington, DC 20528. 

The OIG seeks to protect the identity of each writer and caller.