JULY 2011

Addressing Converging 

Threats to National Security

STR ATEGY TO COMBAT 

TR A NSNATIONA L 

ORGANIZED CRIME

Transnational organized crime refers to those self-perpetuating associations of individuals who operate transnationally for the purpose of obtaining power, influence, monetary and/or commercial gains, 

wholly or in part by illegal means, while protecting their activities through a pattern of corruption and/

or violence, or while protecting their illegal activities through a transnational organizational structure 

and the exploitation of transnational commerce or communication mechanisms. There is no single 

structure under which transnational organized criminals operate; they vary from hierarchies to clans, 

networks, and cells, and may evolve to other structures. The crimes they commit also vary. Transnational 

organized criminals act conspiratorially in their criminal activities and possess certain characteristics 

which may include, but are not limited to:

• In at least part of their activities they commit violence or other acts which are likely to intimidate, 

or make actual or implicit threats to do so;

• They exploit differences between countries to further their objectives, enriching their organization, expanding its power, and/or avoiding detection/apprehension;

• They attempt to gain influence in government, politics, and commerce through corrupt as well 

as legitimate means;

• They have economic gain as their primary goal, not only from patently illegal activities but also 

from investment in legitimate businesses; and

• They attempt to insulate both their leadership and membership from detection, sanction, and/

or prosecution through their organizational structure.

the white house

washington

July 19, 2011

In the National Security Strategy, I committed my Administration to the pursuit of four

enduring national interests: security, prosperity, respect for universal values, and the shaping of

an international order that can meet the challenges of the 21st century. The expanding size,

scope, and influence of transnational organized crime and its impact on U.S. and international

security and governance represent one of the most significant of those challenges.

During the past 15 years, technological innovation and globalization have proven to be an

overwhelming force for good. However, transnational criminal organizations have taken

advantage of our increasingly interconnected world to expand their illicit enterprises.

Criminal networks are not only expanding their operations, but they are also diversifying

their activities, resulting in a convergence of transnational threats that has evolved to become

more complex, volatile, and destabilizing. These networks also threaten U.S. interests by forging

alliances with corrupt elements of national governments and using the power and influence of

those elements to further their criminal activities. In some cases, national governments exploit

these relationships to further their interests to the detriment of the United States.

Despite a long and successful history of dismantling criminal organizations and

developing common international standards for cooperation against transnational organized

crime, not all of our capabilities have kept pace with the expansion of 21st century transnational

criminal threats. Therefore, this strategy is organized around a single, unifying principle: to

build, balance, and integrate the tools of American power to combat transnational organized

crime and related threats to our national security – and to urge our partners to do the same. To

this end, this strategy sets out 56 priority actions, starting with ones the United States can take

within its own borders to lessen the impact of transnational crime domestically and on our

foreign partners. Other actions seek to enhance our intelligence, protect the financial system and

strategic markets, strengthen interdiction, investigations, and prosecutions, disrupt the drug trade

and its facilitation of other transnational threats, and build international cooperation.

While this Strategy is intended to assist the United States Government in combating

transnational crime, it also serves as an invitation for enhanced international cooperation. We

encourage our partners and allies to echo the commitment we have made here and join in 

building a new framework for international cooperation to protect all our citizens from the

violence, harm, and exploitation wrought by transnational organized crime.

Sincerely,

Table of Contents

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

I. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

II. Transnational Organized Crime: A Growing Threat to National and International Security . . 5

III. Strategy to Combat Transnational Organized Crime . . . . . . . . . . . . . . . . 13

Priorty Actions:

Start at Home: Taking Shared Responsibility for Transnational Organized Crime . . . . . 15

Enhance Intelligence and Information Sharing . . . . . . . . . . . . . . . . . . 17

Protect the Financial System and Strategic Markets against Transnational 

Organized Crime . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 

Strengthen Interdiction, Investigations, and Prosecutions . . . . . . . . . . . . . 22

Disrupt Drug Trafficking and Its Facilitation of Other Transnational Threats . . . . . . . 24

Build International Capacity, Cooperation, and Partnerships . . . . . . . . . . . . .26

★ 1 ★

Executive Summary

The Strategy to Combat Transnational Organized Crime applies all elements of national power to protect 

citizens and U.S. national security interests from the convergence of 21st century transnational criminal 

threats. This Strategy is organized around a single unifying principle: to build, balance, and integrate the 

tools of American power to combat transnational organized crime and related threats to national security—and to urge our foreign partners to do the same. The end-state we seek is to reduce transnational 

organized crime (TOC) from a national security threat to a manageable public safety problem in the 

United States and in strategic regions around the world. The Strategy will achieve this end-state by 

pursuing five key policy objectives:

1. Protect Americans and our partners from the harm, violence, and exploitation of transnational 

criminal networks. 

2. Help partner countries strengthen governance and transparency, break the corruptive power 

of transnational criminal networks, and sever state-crime alliances. 

3. Break the economic power of transnational criminal networks and protect strategic markets 

and the U.S. financial system from TOC penetration and abuse. 

4. Defeat transnational criminal networks that pose the greatest threat to national security by 

targeting their infrastructures, depriving them of their enabling means, and preventing the 

criminal facilitation of terrorist activities. 

5. Build international consensus, multilateral cooperation, and public-private partnerships to 

defeat transnational organized crime. 

The Strategy also introduces new and innovative capabilities and tools, which will be accomplished by 

prioritizing within the resources available to affected departments and agencies. 

A new Executive Order will establish a sanctions program to block the property of and prohibit transactions with significant transnational criminal networks that threaten national security, foreign policy, or 

economic interests.

A proposed legislative package will enhance the authorities available to investigate, interdict, and 

prosecute the activities of top transnational criminal networks.

A new Presidential Proclamation under the Immigration and Nationality Act (INA) will deny entry to 

transnational criminal aliens and others who have been targeted for financial sanctions.

A new rewards program will replicate the success of narcotics rewards programs in obtaining information that leads to the arrest and conviction of the leaders of transnational criminal organizations that 

pose the greatest threats to national security.

An interagency Threat Mitigation Working Group will identify those TOC networks that present a sufficiently high national security risk and will ensure the coordination of all elements of national power 

to combat them. 

★ 3 ★

I. Introduction

“Combating transnational criminal and trafficking networks requires a multidimensional strategy 

that safeguards citizens, breaks the financial strength of criminal and terrorist networks, disrupts illicit 

trafficking networks, defeats transnational criminal organizations, fights government corruption, 

strengthens the rule of law, bolsters judicial systems, and improves transparency. While these are major 

challenges, the United States will be able to devise and execute a collective strategy with other nations 

facing the same threats.” 

— National Security Strategy, May 2010

In January 2010, the United States Government completed a comprehensive review of international 

organized crime—the first on this topic since 1995. Based on the review and subsequent reporting, 

the Administration has concluded that, in the intervening years, international —or transnational—

organized crime has expanded dramatically in size, scope, and influence and that it poses a significant 

threat to national and international security. In light of the review’s findings, we have adopted the term 

“transnational organized crime” (TOC) to describe the threats addressed by this Strategy. While the term 

“international organized crime” has been commonly used in the past, “transnational organized crime” 

more accurately describes the converging threats we face today. As emphasized in the National Security 

Strategy: “...these threats cross borders and undermine the stability of nations, subverting government 

institutions through corruption and harming citizens worldwide.”

In years past, TOC was largely regional in scope, hierarchically structured, and had only occasional links 

to terrorism. Today’s criminal networks are fluid, striking new alliances with other networks around the 

world and engaging in a wide range of illicit activities, including cybercrime and providing support 

for terrorism. Virtually every transnational criminal organization and its enterprises are connected and 

enabled by information systems technologies, making cybercrime a substantially more important 

concern. TOC threatens U.S. interests by taking advantage of failed states or contested spaces; forging 

alliances with corrupt foreign government officials and some foreign intelligence services; destabilizing 

political, financial, and security institutions in fragile states; undermining competition in world strategic 

markets; using cyber technologies and other methods to perpetrate sophisticated frauds; creating the 

potential for the transfer of weapons of mass destruction (WMD) to terrorists; and expanding narcotrafficking and human and weapons smuggling networks. Terrorists and insurgents increasingly are 

turning to criminal networks to generate funding and acquire logistical support. TOC also threatens the 

interconnected trading, transportation, and transactional systems that move people and commerce 

throughout the global economy and across our borders. 

In October 2010, the national security advisors of 44 nations gathered in Sochi, Russia to discuss transnational crime. Representing the United States, former National Security Advisor General James L. Jones, 

USMC, Ret. warned of the TOC threats to international security and urged immediate international 

action, saying: 
★ 4 ★

STRATEGY TO COMBAT TRANSNATIONAL ORGANIZED CRIME

“In a world full of transnational threats, transnational crime is in an ascendant 

phase... This lethal nexus of organized crime, narco-trafficking, and terrorism is a 

threat that the United States, Russia and all of us share and should be working together 

to combat... Today, right now, we have an opportunity for cooperation not just 

between the United States and Russia, but among all nations represented here today. 

It’s up to us to seize the moment...” 

The various elements of this Strategy flow from a single unifying principle: we will build, balance, and 

integrate the tools of American power to combat TOC and related threats to national security and urge our 

foreign partners to do the same. To this end, the Strategy recognizes TOC as a significant threat to national 

and international security and emphasizes U.S. planning, priorities, and activities accordingly. The 

Strategy addresses TOC and drug trafficking as increasingly intertwined threats to maximize the impact 

of U.S. resources. It also provides a framework to direct U.S. power against those TOC actors, activities, 

and networks that are determined to pose the greatest threat to national and international security.

This Strategy establishes priority actions in several key areas. It starts by taking a hard look at what actions 

the United States can take within its own borders to lessen the threat and impact of TOC domestically 

and on our foreign partners. The other priority actions seek to:

• Enhance Intelligence and Information Sharing;

• Protect the Financial System and Strategic Markets Against Transnational Organized Crime; 

• Strengthen Interdiction, Investigations, and Prosecutions;

• Disrupt Drug Trafficking and Its Facilitation of Other Transnational Threats; and

• Build International Capacity, Cooperation, and Partnerships.

This Strategy complements but does not replicate the work of other major U.S. security initiatives. It is 

guided by the National Security Strategy and interlocks with other U.S. strategies and initiatives, to include 

the National Drug Control Strategy, the National Strategy for Counterterrorism, the International Strategy 

for Cyberspace, the National Strategy to Combat Weapons of Mass Destruction, the U.S.-Mexico Merida 

Initiative, the Law Enforcement Strategy to Combat International Organized Crime, the National Strategy 

for Maritime Security, Countering Piracy Off the Horn of Africa: Partnership & Action Plan, and several other 

U.S. security assistance, counterdrug, and capacity-building efforts around the world. 

The Interagency Policy Committee (IPC) on Illicit Drugs and Transnational Criminal Threats will oversee 

a whole-of-government approach to implementing this Strategy. Co-chaired by the National Security 

Staff and the Office of National Drug Control Policy, this IPC will issue implementation guidance, establish 

performance measures, and receive regular progress updates from the interagency community. This 

IPC will be informed by and work with other IPCs such as the Maritime Security IPC. With a new Strategy 

to Combat Transnational Organized Crime and an array of new authorities and tools, this Administration 

is committing itself to ensuring that we rise to the national security challenges of the 21st century and 

ensure an international order that protects the safety and well-being of our citizens. 
★ 5 ★

II. Transnational Organized Crime: 

A Growing Threat to National 

and International Security

Transnational organized crime (TOC) poses a significant and growing threat to national and international 

security, with dire implications for public safety, public health, democratic institutions, and economic 

stability across the globe. Not only are criminal networks expanding, but they also are diversifying their 

activities, resulting in the convergence of threats that were once distinct and today have explosive and 

destabilizing effects. This Strategy organizes the United States to combat TOC networks that pose a 

strategic threat to Americans and to U.S. interests in key regions. 

Penetration of State Institutions, Corruption, and Threats to Governance. Developing countries 

with weak rule of law can be particularly susceptible to TOC penetration. TOC penetration of states is 

deepening, leading to co-option in a few cases and further weakening of governance in many others. 

The apparent growing nexus in some states among TOC groups and elements of government—including intelligence services—and high-level business figures represents a significant threat to economic 

growth and democratic institutions. In countries with weak governance, there are corrupt officials who 

turn a blind eye to TOC activity. TOC networks insinuate themselves into the political process in a variety 

of ways. This is often accomplished through direct bribery (but also by having members run for office); 

setting up shadow economies; infiltrating financial and security sectors through coercion or corruption; 

and positioning themselves as alternate providers of governance, security, services, and livelihoods. As 

they expand, TOC networks may threaten stability and undermine free markets as they build alliances 

with political leaders, financial institutions, law enforcement, foreign intelligence, and security agencies. TOC penetration of governments is exacerbating corruption and undermining governance, rule 

of law, judicial systems, free press, democratic institution-building, and transparency. Further, events in 

Somalia have shown how criminal control of territory and piracy ransoms generate significant sums of 

illicit revenue and promote the spread of government instability. 

Threats to the Economy, U.S. Competitiveness, and Strategic Markets. TOC threatens U.S. economic 

interests and can cause significant damage to the world financial system through its subversion, exploitation, and distortion of legitimate markets and economic activity. U.S. business leaders worry that U.S. 

firms are being put at a competitive disadvantage by TOC and corruption, particularly in emerging 

markets where many perceive that rule of law is less reliable. The World Bank estimates about $1 trillion 

is spent each year to bribe public officials, causing an array of economic distortions and damage to 

legitimate economic activity. The price of doing business in countries affected by TOC is also rising as 

companies budget for additional security costs, adversely impacting foreign direct investment in many 

parts of the world. TOC activities can lead to disruption of the global supply chain, which in turn diminishes economic competitiveness and impacts the ability of U.S. industry and transportation sectors to 

be resilient in the face of such disruption. Further, transnational criminal organizations, leveraging their 

relationships with state-owned entities, industries, or state-allied actors, could gain influence over key 
★ 6 ★

STRATEGY TO COMBAT TRANSNATIONAL ORGANIZED CRIME

commodities markets such as gas, oil, aluminum, and precious metals, along with potential exploitation 

of the transportation sector. 

Crime-Terror-Insurgency Nexus. Terrorists and insurgents increasingly are turning to TOC to generate funding and acquire logistical support to carry out their violent acts. The Department of Justice 

reports that 29 of the 63 organizations on its FY 2010 Consolidated Priority Organization Targets list, 

which includes the most significant international drug trafficking organizations (DTOs) threatening 

the United States, were associated with terrorist groups. Involvement in the drug trade by the Taliban 

and the Revolutionary Armed Forces of Colombia (FARC) is critical to the ability of these groups to fund 

terrorist activity. We are concerned about Hizballah’s drug and criminal activities, as well as indications 

of links between al-Qa`ida in the Lands of the Islamic Maghreb and the drug trade. Further, the terrorist 

organization al-Shabaab has engaged in criminal activities such as kidnapping for ransom and extortion, 

and may derive limited fees from extortion or protection of pirates to generate funding for its operations. 

While the crime-terror nexus is still mostly opportunistic, this nexus is critical nonetheless, especially if 

it were to involve the successful criminal transfer of WMD material to terrorists or their penetration of 

human smuggling networks as a means for terrorists to enter the United States. 

Expansion of Drug Trafficking. Despite demonstrable counterdrug successes in recent years, particularly against the cocaine trade, illicit drugs remain a serious threat to the health, safety, security, and 

financial well-being of Americans. The demand for illicit drugs, both in the United States and abroad, 

fuels the power, impunity, and violence of criminal organizations 

around the globe. Mexican DTOs are escalating their violence to 

consolidate their market share within the Western Hemisphere, 

protect their operations in Mexico, and expand their reach into the 

United States. In West Africa, Latin American cartels are exploiting 

local criminal organizations to move cocaine to Western Europe and 

the Middle East. There have also been instances of Afghan DTOs 

operating with those in West Africa to smuggle heroin to Europe and 

the United States. Many of the well-established organized criminal 

groups that had not been involved in drug trafficking—including 

those in Russia, China, Italy, and the Balkans—are now establishing 

ties to drug producers to develop their own distribution networks and markets. The expansion of drug 

trafficking is often accompanied by dramatic increases in local crime and corruption, as the United 

Nations has detected in regions such as West Africa and Central America.

Human Smuggling. Human smuggling is the facilitation, transportation, attempted transportation, 

or illegal entry of a person or persons across an international border, in violation of one or more countries’ laws, either clandestinely or through deception, whether with the use of fraudulent documents 

or through the evasion of legitimate border controls. It is a criminal commercial transaction between 

willing parties who go their separate ways once they have procured illegal entry into a country. The 

vast majority of people who are assisted in illegally entering the United States and other countries are 

smuggled, rather than trafficked. International human smuggling networks are linked to other transnational crimes including drug trafficking and the corruption of government officials. They can move 

With the expansion of the 

drug trade, illicit drugs 

have become more lethal 

over the years. The number 

of Americans who died 

each year from accidental 

overdoses from all drugs, but 

mostly illicit ones, more than 

tripled from 1992 to 2007, 

increasing to 38,000.
★ 7 ★

criminals, fugitives, terrorists, and trafficking victims, as well as economic migrants. They undermine the 

sovereignty of nations and often endanger the lives of those being smuggled. In its 2010 report The 

Globalization of Crime: A Transnational Organized Crime Threat Assessment, the United Nations Office on 

Drugs and Crime (UNODC) estimated that the smuggling of persons from Latin America to the United 

States generated approximately $6.6 billion annually in illicit proceeds for human smuggling networks.

Trafficking in Persons. Trafficking in Persons (TIP), or human trafficking, refers to activities involved 

when one person obtains or holds another person in compelled service, such as involuntary servitude, 

slavery, debt bondage, and forced labor. TIP specifically targets the trafficked person as an object of 

criminal exploitation—often for labor exploitation or sexual exploitation purposes—and trafficking 

victims are frequently physically and emotionally abused. Although TIP is generally thought of as an 

international crime that involves the crossing of borders, TIP victims can also be trafficked within their 

own countries. Traffickers can move victims between locations within the same country and often sell 

them to other trafficking organizations.

Weapons Trafficking. Criminal networks and illicit arms dealers also play important roles in the black 

markets from which terrorists and drug traffickers procure some of their weapons. As detailed in the 

2010 UNODC report The Globalization of Crime, “The value of the documented global authorized trade 

in firearms has been estimated at approximately $1.58 billion in 2006, with unrecorded but licit transactions making up another $100 million or so. The most commonly cited estimate for the size of the illicit 

market is 10% - 20% of the licit market.” According to the head of UNODC, these “illicit arms fuel the 

violence that undermines security, development and justice” worldwide. U.S. Federal law enforcement 

agencies have intercepted large numbers of weapons or related items being smuggled to China, Russia, 

Mexico, the Philippines, Somalia, Turkmenistan, and Yemen in the last year alone. 

Intellectual Property Theft. TOC networks are engaged in the theft of critical U.S. intellectual property, 

including through intrusions into corporate and proprietary computer networks. Theft of intellectual 

property ranges from movies, music, and video games to imitations of popular and trusted brand names, 

to proprietary designs of high-tech devices and manufacturing processes. This intellectual property 

theft causes significant business losses, erodes U.S. competitiveness in the world marketplace, and in 

many cases threatens public health and safety. Between FY 2003 and FY 2010, the yearly domestic value 

of customs seizures at U.S. port and mail facilities related to intellectual property right (IPR) violations 

leaped from $94 million to $188 million. Products originating in China accounted for 66% of these IPR 

seizures in FY 2010. 

Cybercrime. TOC networks are increasingly involved in cybercrime, which costs consumers billions 

of dollars annually, threatens sensitive corporate and government computer networks, and undermines worldwide confidence in the international financial system. Through cybercrime, transnational 

criminal organizations pose a significant threat to financial and trust systems—banking, stock markets, 

e-currency, and value and credit card services—on which the world economy depends. For example, 

some estimates indicate that online frauds perpetrated by Central European cybercrime networks 

have defrauded U.S. citizens or entities of approximately $1 billion in a single year. According to the U.S. 

Secret Service, which investigates cybercrimes through its 31 Electronic Crimes Task Forces, financial 

crimes facilitated by anonymous online criminal fora result in billions of dollars in losses to the Nation’s 

STRATEGY TO COMBAT TRANSNATIONAL ORGANIZED CRIME
★ 8 ★

STRATEGY TO COMBAT TRANSNATIONAL ORGANIZED CRIME

financial infrastructure. The National Cyber Investigative Joint Task Force, led by the Federal Bureau 

of Investigation (FBI), functions as a domestic focal point for 18 federal departments or agencies to 

coordinate, integrate, and share information related to cyber threat investigations, as well as make the 

Internet safer by pursuing terrorists, spies, and criminals who seek to exploit U.S. systems. Pervasive 

criminal activity in cyberspace not only directly affects its victims, but can imperil citizens’ and businesses’ 

faith in these digital systems, which are critical to our society and economy. Computers and the Internet 

play a role in most transnational crimes today, either as the target or the weapon used in the crime. The 

use of the Internet, personal computers, and mobile devices all create a trail of digital evidence. Often 

the proper investigation of this evidence trail requires highly trained personnel. Crimes can occur more 

quickly, but investigations proceed more slowly due to the critical shortage of investigators with the 

knowledge and expertise to analyze ever increasing amounts of potential digital evidence.

The Critical Role of Facilitators. Connecting these converging threats are “facilitators,” semi- legitimate 

players such as accountants, attorneys, notaries, bankers, and real estate brokers, who cross both the licit 

and illicit worlds and provide services to legitimate customers, criminals, and terrorists alike. The range 

of licit-illicit relationships is broad. At one end, criminals draw on the public reputations of licit actors to 

maintain facades of propriety for their operations. At the other end are “specialists” with skills or resources 

who have been completely subsumed into the criminal networks. For example, TOC networks rely on 

industry experts, both witting and unwitting, to facilitate corrupt transactions and to create the necessary infrastructure to pursue their illicit schemes, such as creating shell corporations, opening offshore 

bank accounts in the shell corporation’s name, and creating front businesses for their illegal activity 

and money laundering. Business owners or bankers are enlisted to launder money, and employees of 

legitimate companies are used to conceal smuggling operations. Human smugglers, human traffickers, arms traffickers, drug traffickers, terrorists, and other criminals depend on secure transportation 

networks and safe locations from which to stage smuggling activity or to store bulk cash or narcotics 

for transport. They also depend on fraudulently created or fraudulently obtained documents, such as 

passports and visas, to move themselves or their clients into the United States and illegally reside here.

Transnational criminal networks such as organized crime groups, drug traffickers, and weapons dealers 

at times share convergence points—places, businesses, or people—to “launder” or convert their illicit 

profits into legitimate funds. Many of these disparate networks also appear to use the same casinos, 

financial intermediaries, and front companies to plan arms and narcotics deals because they view them 

as safe intermediaries for doing business. Cash-intensive and high-volume businesses such as casinos 

are especially attractive, particularly those in jurisdictions that lack the political will and oversight to 

regulate casino operations or fail to perform due diligence on casino licensees. Illicit networks similarly 

abuse some of the same financial intermediaries and front companies in regions where government 

or law enforcement corruption is prevalent, with officials receiving either revenues from the criminal 

businesses or ownership stakes in the legitimate-appearing commercial entity. 
★ 9 ★

Regional Priorities

TOC—a global problem—manifests itself in various regions in different ways.

Western Hemisphere: TOC networks—including transnational gangs—have 

expanded and matured, threatening the security of citizens and the stability of 

governments throughout the region, with direct security implications for the 

United States. Central America is a key area of converging threats where illicit 

trafficking in drugs, people, and weapons—as well as other revenue streams—

fuel increased instability. Transnational crime and its accompanying violence are 

threatening the prosperity of some Central American states and can cost up to 

eight percent of their gross domestic product, according to the World Bank. The 

Government of Mexico is waging an historic campaign against transnational criminal organizations, 

many of which are expanding beyond drug trafficking into human smuggling and trafficking, weapons 

smuggling, bulk cash smuggling, extortion, and kidnapping for ransom. TOC in Mexico makes the U.S. 

border more vulnerable because it creates and maintains illicit corridors for border crossings that can be 

employed by other secondary criminal or terrorist actors or organizations. Farther south, Colombia has 

achieved remarkable success in reducing cocaine production and countering illegal armed groups, such 

as the FARC, that engage in TOC. Yet, with the decline of these organizations, new groups are emerging 

such as criminal bands known in Spanish as Bandas Criminales, or Bacrims. 

Afghanistan/Southwest Asia: Nowhere is the convergence of transnational 

threats more apparent than in Afghanistan and Southwest Asia. The Taliban and 

other drug-funded terrorist groups threaten the efforts of the Islamic Republic of 

Afghanistan, the United States, and other international partners to build a peaceful and democratic future for that nation. The insurgency is seen in some areas of 

Afghanistan as criminally driven—as opposed to ideologically motivated—and in 

some areas, according to local Afghan officials and U.S. estimates, drug traffickers 

and the Taliban are becoming indistinguishable. In other instances, ideologically 

Mexico Los Zetas Cartel 

Leaders Heriberto LazcanoLazcano and Miguel Angel 

Treviño Morales

Colombia: From Recipient to Provider of Assistance

After years of intensive capacity building assistance in Colombia, the United States is working to transfer 

financial and operational responsibility for institutional development to the Government of Colombia. 

Colombia now is an exporter of law enforcement and justice sector capabilities, providing assistance and 

advice for police, prosecutors, protection programs, and judiciary, criminal law, and procedure development. This reality is the result of the success of U.S. assistance in Colombian capacity building, a success the 

United States aims to replicate with other partner states. On July 2, 2008, the world witnessed the extraordinary courage and capability of Colombian forces during their daring rescue of 15 hostages—including 3 

Americans—who had been held captive for years in the jungles by FARC guerrillas. The rescue was accomplished without firing a shot.

INTERPOL Fugitive 

Dawood Ibrahim, South 

Asia “Company D” 

STRATEGY TO COMBAT TRANSNATIONAL ORGANIZED CRIME
★ 10 ★

STRATEGY TO COMBAT TRANSNATIONAL ORGANIZED CRIME

driven insurgent networks are either directly trafficking in narcotics or have linked up with DTOs to 

finance their criminal actions. The threatening crime-terror-insurgency nexus in this region is illustrated 

by cases such as that of INTERPOL fugitive Dawood Ibrahim, the reputed leader of South Asia’s powerful “D Company.” He is wanted in connection with the 1993 Mumbai bombing and is sanctioned under 

United Nations Security Council Resolution 1267 (Taliban/al-Qa`ida).

Russia/Eurasia: Russian and Eurasian organized crime networks represent a significant threat to economic growth and democratic institutions. Russian organized crime syndicates and criminally linked 

oligarchs may attempt to collude with state or state-allied actors to undermine competition in strategic 

markets such as gas, oil, aluminum, and precious metals. At the same time, TOC networks in the region 

are establishing new ties to global drug trafficking networks. Nuclear material trafficking is an especially 

prominent concern in the former Soviet Union. The United States will continue to cooperate with Russia 

and the nations of the region to combat illicit drugs and TOC. 

The Balkans: A traditional conduit for smuggling between east and west, the Balkans has become 

an ideal environment for the cultivation and expansion of TOC. Weak institutions in Albania, Kosovo, 

and Bosnia and Herzegovina have enabled Balkan-based TOC groups to seize control of key drug and 

human trafficking routes and Western European markets. The Balkans region has become a new entry 

point for Latin American cocaine, a source of synthetic drugs, and a transit region for heroin chemical 

precursors for use in the Caucasus and Afghanistan. Excess weapons are smuggled to countries of 

concern. Insufficient border controls and the ease of acquiring passports enable the transit of criminals 

and terrorist figures to Western Europe. Cooperation between the United States and the European 

Union, as well as bilateral cooperation with the countries in the region to foster legal institution building, 

economic progress, and good governance in the Balkans will be key to eliminating the environment 

supporting TOC.

West Africa: West Africa has become a major transit point for illegal drug shipments to Europe and for Southwest Asian heroin to the United States. It has also 

become both a source of—and transit point for—methamphetamine destined 

for the Far East. West Africa also serves as a transit route for illicit proceeds flowing 

back to source countries. TOC exacerbates corruption and undermines the rule of 

law, democratic processes, and transparent business practices in several African 

states that already suffer from weak institutions. Due to its lack of law enforcement 

capabilities, its susceptibility to corruption, its porous borders, and its strategic 

location, Guinea-Bissau remains a significant hub of narcotics trafficking on the verge of developing 

into a narco-state. While many officials within the Government of Guinea-Bissau recognize the extent 

of the drug problem and express a willingness to address it, a crippling lack of resources and capacity 

remains a hindrance to real progress in combating drug trafficking. The recent re-appointment of U.S. 

Treasury-designated drug kingpin Jose Americo Bubo Na Tchuto as Naval Chief of Staff is likely to further 

entrench drug cartels in the permissive operating conditions prevailing in Guinea-Bissau. In the Gulf 

of Guinea, maritime criminals operate in areas of weak governance, kidnapping oil workers, stealing 

oil from pipelines, and causing environmental damage that harms the citizenry. The United States will 

work with African governments, European partners, and multilateral institutions to counter this threat 

to development, democratic processes, and the rule of law in the region.

Jose Americo Bubo Na 

Tchuto, 

U.S. Treasury-designated 

drug kingpin
★ 11 ★

Asia/Pacific: TOC networks and DTOs are integrating their activities in the Asia/Pacific 

region. Due to the region’s global economic ties, these criminal activities have serious 

implications worldwide. The economic importance of the region also heightens the 

threat posed to intellectual property rights, as a large portion of intellectual property 

theft originates from China and Southeast Asia. Human trafficking and smuggling 

remain significant concerns in the Asia/Pacific region, as demonstrated by the case of 

convicted alien smuggler Cheng Chui Ping, who smuggled more than 1,000 aliens into 

the United States during the course of her criminal career, sometimes hundreds at a 

time. TOC networks in the region are also active in the illegal drug trade, trafficking precursor chemicals 

for use in illicit drug production. North Korean government entities have likely maintained ties with 

established crime networks, including those that produce counterfeit U.S. currency, threatening the 

global integrity of the U.S. dollar. It is unclear whether these links persist. The United States will continue 

to improve its understanding of the TOC threats in the Asia/Pacific region and will work with partner 

nations to develop a comprehensive response.

Cheng Chui Ping, 

convicted alien 

smuggler

STRATEGY TO COMBAT TRANSNATIONAL ORGANIZED CRIME

★ 13 ★

III. Strategy to Combat 

Transnational Organized Crime

For decades, the United States and other countries have dismantled scores of criminal organizations 

around the world. The U.S. experience with La Cosa Nostra, as well as Colombia’s experience with the 

Medellin and Cali Cartels—and even the FARC—prove that it is possible to constrain, shrink, disrupt and 

dismantle criminal and insurgent groups once considered to be untouchable.

This Strategy builds upon such past experience. Today the threat from TOC is more complicated because 

criminal networks are more fluid and are using increasingly sophisticated tactics. TOC can exploit the 

interconnected nature of our modern trading, transportation, and transactional systems that move 

people and commerce throughout the global economy and across our borders. Countering TOC today 

requires an integrated and comprehensive approach. This Strategy sets out such an approach to raise 

international awareness about the reality of the TOC threat to international security; galvanize multilateral 

action to constrain the reach and influence of TOC; deprive TOC of its enabling means and infrastructure; 

shrink the threat TOC poses to citizen safety, national security, and governance; and ultimately defeat the 

TOC networks that pose the greatest threat to national security. TOC presents sophisticated and multifaceted threats that cannot be addressed through law enforcement action alone. Accordingly, we will 

establish an interagency Threat Mitigation Working Group to identify those TOC networks that present a 

sufficiently high national security threat as to merit the focused use of complementary law enforcement 

and non-law enforcement assets and that may be vulnerable to whole-of-government responses. The 

Working Group will ensure the coordination of all elements of national power to effectively protect our 

borders, people, economy, and financial system from the threats posed by the most dangerous and 

sophisticated of these transnational criminal networks.

This Strategy sets out five overarching policy objectives that are consistent with the vision and priorities 

of the National Security Strategy:

1. Protect Americans and our partners from the harm, violence, and exploitation of transnational criminal networks. Our priority is the safety, security, and prosperity of American citizens 

and the citizens of partner nations. We will target the networks that pose the gravest threat to 

citizen safety and security, including those that traffic illicit drugs, arms, and people—especially women and children; sell and distribute substandard, tainted and counterfeit goods; rob 

Americans of their prosperity; carry out kidnappings for ransom and extortion; and seek to 

terrorize and intimidate through acts of torture and murder. 

2. Help partner countries strengthen governance and transparency, break the corruptive power 

of transnational criminal networks, and sever state-crime alliances. The United States needs 

willing, reliable and capable partners to combat the corruption and instability generated by TOC 

and related threats to governance. We will help international partners develop the sustainable 

capacities necessary to defeat transnational threats; strengthen legitimate and effective public 

safety, security, and justice institutions; and promote universal values. We will also seek to sever 
★ 14 ★

STRATEGY TO COMBAT TRANSNATIONAL ORGANIZED CRIME

the powerful strategic alliances that form between TOC and states, including those between 

TOC networks and foreign intelligence services.

3. Break the economic power of transnational criminal networks and protect strategic markets 

and the U.S. financial system from TOC penetration and abuse. TOC networks—using bribery, 

fraud, and violence—have the capacity to disrupt economic activity and put legitimate businesses at a distinct competitive disadvantage. We will attack the financial underpinnings of the 

top transnational criminals; strip them of their illicit wealth; sever their access to the financial 

system; expose their criminal activities hidden behind legitimate fronts; and protect strategic 

markets and the U.S. financial system. 

4. Defeat transnational criminal networks that pose the greatest threat to national security, by 

targeting their infrastructures, depriving them of their enabling means, and preventing the 

criminal facilitation of terrorist activities. We will target, disrupt, and defeat the TOC networks 

that pose the greatest threat to the safety and security of Americans and U.S. national security 

interests. These include criminal networks—including transnational criminal gangs—that traffic 

drugs, bulk cash, arms, people, sensitive documents, or other contraband. Further, we will seek 

to prevent collaboration between criminal and terrorist networks and deprive them of their 

critical resources and infrastructure, such as funding, logistical support for transportation, staging, procurement, safe havens for illicit activities, and the facilitation of services and materiel, 

which could include WMD material. 

5. Build international consensus, multilateral cooperation, and public-private partnerships to 

defeat transnational organized crime. We will build new partnerships—with industry, finance, 

academia, civil society and non-governmental organizations—to combat TOC networks that 

operate in the illicit and licit worlds. We will also fight criminal networks with an alliance of 

legitimate networks, and ensure the freedom of the press so that the media and journalists 

may safely expose the harms inflicted by TOC. We will expand and deepen our understanding, cooperation, and information sharing at home with State and local agencies, with foreign 

partners, and with multilateral institutions. Internationally, we will further international norms 

against tolerating or sponsoring crime in all its forms, including in cyberspace.
★ 15 ★

Priority Actions

Start at Home: Taking Shared Responsibility for Transnational 

Organized Crime

I reiterated that the United States accepts our shared responsibility for the drug violence. So to combat 

the southbound flow of guns and money, we are screening all southbound rail cargo, seizing many more 

guns bound for Mexico, and we are putting more gunrunners behind bars. And as part of our new drug 

control strategy, we are focused on reducing the demand for drugs through education, prevention and 

treatment... We are very mindful that the battle President Calderón is fighting inside of Mexico is not 

just his battle; it’s also ours. We have to take responsibility just as he’s taking responsibility.

—President Barack Obama speaking at a joint press conference 

with Mexican President Felipe Calderón, March 3, 2011

We must begin our effort to disrupt TOC by looking inward and acknowledging the causes that emanate 

from within our own borders to fuel and empower TOC. The demand for illegal drugs within the United 

States fuels a significant share of the global drug trade, which is a primary funding source for TOC 

networks and a key source of revenue for some terrorist and insurgent networks. Any comprehensive 

strategy to defeat TOC must seek to reduce the demand for drugs and other illegal goods that finance 

TOC networks. The President’s National Drug Control Strategy emphasizes prevention, early intervention, 

treatment, and innovative criminal justice approaches to drive down drug use, and calls for continued 

support for the millions of Americans who are in recovery from addiction. Supported by a budget that 

increases resources for vital prevention and treatment programs, the National Drug Control Strategy

seeks to reduce the size of the illegal drug market in the United States, depriving TOC networks of 

revenue while helping more of our citizens break the cycle of drug abuse and reducing the adverse 

consequences to our communities.

We must also stop the illicit flow from the United States of weapons and criminal proceeds that empower 

TOC networks. The Administration has placed an increased emphasis on stemming these outbound 

flows, dedicating additional law enforcement, investigative, and prosecution resources to targeting 

TOC, such as deploying additional U.S. Customs and Border Protection “outbound teams” to our borders, 

screening outbound rail and vehicle traffic for weapons and bulk currency, and by investing additional 

resources in the integrated Border Enforcement Security Task Forces along the U.S.-Mexico border to 

investigate the organizations involved in cross-border crimes. We will also work with Congress to seek 

ratification or accession to key multilateral instruments related to countering the illicit trafficking of 

weapons. 

Further, we will work with our international partners to build their law enforcement capacities, strengthen 

their judicial institutions, and combat the corrosive threat of corruption, while also recognizing that the 

United States itself is not immune to public corruption. Continued vigilance is required to ensure the 

integrity of U.S. officials and institutions as we face the new and converging threats posed by TOC. In 
★ 16 ★

STRATEGY TO COMBAT TRANSNATIONAL ORGANIZED CRIME

addition to the greater vigilance required by our governmental institutions, American businesses and 

individuals need to inform law enforcement about criminal activity and reduce their vulnerability to 

fraud schemes, intellectual property theft, and identity theft. Acknowledging our own challenges and 

aggressively addressing them here at home represent the first essential steps in building the cooperative 

multilateral approach required to defeat TOC.

Actions

A. Reduce the demand for illicit drugs in the United States, thereby denying funding to illicit trafficking 

organizations.

B. Continue to attack drug trafficking and distribution networks and their enabling means within the 

United States to reduce the availability of illicit drugs.

C. Sever the illicit flow across U.S. borders of people, weapons, currency, and other illicit finance 

through investigations and prosecutions of key TOC leadership, as well as through the targeting of 

TOC networks’ enabling means and infrastructure. 

D. Identify and take action against corporate and governmental corruption within the United States.

E. Work with Congress to secure ratification of the Inter American Convention against the Illicit 

Manufacturing of and Trafficking in Firearms, Ammunition, Explosives and Other Related Materials.

F. Seek accession to the Protocol against the Illicit Manufacturing of and Trafficking in Firearms, their 

Parts and Components and Ammunition, supplementing the UN Convention against Transnational 

Organized Crime.

Project Deliverance: Targeting Mexican Drug Trafficking Networks in the United States

On June 9, 2010 the DEA-led interagency Special Operations Division executed a coordinated takedown 

in support of Project Deliverance, a 22-month multi-agency network of law enforcement investigations 

targeting the transportation infrastructure of Mexican transnational criminal organizations in the United 

States, especially along the Southwest border. During the final takedown, 429 arrests took place in 16 

states through coordination among more than 3,000 Federal, State, and local law enforcement officers. In 

total, Project Deliverance has led to 2,266 arrests and the seizure of $154 million, 1,262 pounds of methamphetamine, 2.5 tons of cocaine, 1,410 pounds of heroin, 69 tons of marijuana, 501 weapons, and 527 

vehicles during the entire course of the operation.
STRATEGY TO COMBAT TRANSNATIONAL ORGANIZED CRIME

★ 17 ★

Enhance Intelligence and Information Sharing

A shift in U.S. intelligence collection priorities since the September 11, 2001 attacks left significant gaps 

in TOC-related intelligence. Meanwhile, the TOC threat has worsened and grown in complexity over the 

past 15 years. The fluid nature of TOC networks, which includes the use of criminal facilitators, makes 

targeting TOC increasingly difficult. 

Enhancing U.S. intelligence collection, analysis, and counterintelligence on TOC is a necessary first step, 

but should be accompanied by collaboration with law enforcement authorities at Federal, State, local, 

tribal, and territorial levels and enhanced sharing with foreign counterparts. We will also supplement our 

understanding of TOC involvement in licit commercial sectors to better enable policymakers to develop 

specific interventions. Our aim is enhanced intelligence that is broad-based and centered on substantially upgraded signals intelligence (SIGINT), human intelligence (HUMINT) and open sources intelligence 

(OSINT). This effort will be aided through greater information sharing with foreign partners and closer 

cooperation among intelligence, law enforcement, and other applicable agencies domestically. 

We will augment our intelligence in step with the new TOC threats described previously. The 

Administration will review its current intelligence priorities, including the National Intelligence Priorities 

Framework, and determine how best to enhance our intelligence against the highest-level TOC threats 

to national security. Priorities will include:

• Enhancing SIGINT and HUMINT collection on TOC threats, especially taking into account the 

potential role of TOC to facilitate WMD terrorism;

• Employing the Open Source Center to draw upon “grey” literature, smaller press outlets that 

cover crime in foreign countries, and social media fora to develop profiles of individuals, companies, and institutions linked to TOC networks; 

• Coordinating with the interagency International Organized Crime Intelligence and Operations 

Center (IOC-2) to utilize existing resources and databases of the Organized Crime Drug 

Enforcement Task Force (OCDETF) Fusion Center (OFC) and SOD to share intelligence, de-conflict 

operations, and produce actionable leads for investigators and prosecutors working nationwide;

• Expanding collection and immigration, customs, transportation, and critical infrastructure 

screening capabilities in TOC “hotspots” around the world;

• Developing protocols to ensure appropriate TOC data flows to agencies conducting screening 

and interdiction operations to disrupt TOC activities at the border and at critical points of the 

supply chain;

• Using specialized intelligence centers such as the El Paso Intelligence Center, the Bulk Cash 

Smuggling Center, the National Export Enforcement Coordination Center, and the Cyber Crimes 

Center to coordinate the collection and analysis of intelligence regarding various aspects of the 

TOC threat;

• Using the National Intellectual Property Rights Coordination Center, an interagency and international law enforcement task force established in 2000 and led by ICE, to assist with combating 
★ 18 ★

STRATEGY TO COMBAT TRANSNATIONAL ORGANIZED CRIME

intellectual property theft and maintaining the integrity of public health, public safety, the 

military, and the U.S. economy; and

• Enhancing Department of Defense support to U.S. law enforcement through the Narcotics and 

Transnational Crime Support Center.

Actions

A. Enhance U.S. intelligence collection, analysis, and counterintelligence on TOC entities that pose the 

greatest threat to national security.

B. Develop greater synergies between intelligence analysts, collectors, and counterintelligence personnel; 

ensure their efforts directly support operational law enforcement needs and screening requirements.

C. Strengthen ties among U.S. intelligence and counterintelligence, law enforcement, and military entities, while strengthening cooperation with international intelligence and law enforcement partners.

D. Develop and foster stronger law enforcement and Intelligence Community relationships among 

Federal, State, local, tribal, and territorial authorities.

E. Support multilateral senior law enforcement exchanges to promote the sharing of criminal intelligence and enhance cooperation, such as the “Quintet of Attorneys-General” and the “Strategic 

Alliance Group” fora established with the United Kingdom, Canada, New Zealand, and Australia. 

F. Update the National Intelligence Priorities Framework to ensure that it is aligned with current TOC 

threats. 

G. Enhance support to Intelligence Community analysis of TOC by the Office of the Director of National 

Intelligence, specifically by the National Intelligence Council and the National Intelligence Managers.

H. The National Counterproliferation Center shall develop a plan that assesses the links between TOC 

and WMD proliferators.

I. Establish a comprehensive and proactive information-sharing mechanism to identify TOC actors 

and exclude them from the United States or uncover them within the United States. 

INFORMATION SHARING TO COMBAT TRANSNATIONAL ORGANIZED CRIME

The Special Operations Division

Established in 1994, the Special Operations Division (SOD) is a DEA-led multi-agency operations coordination center with participation from Federal law enforcement agencies, the Department of Defense, 

the Intelligence Community, and international law enforcement partners. SOD’s mission is to establish 

strategies and operations to dismantle national and international trafficking organizations by attacking 

their command and control communications. Special emphasis is placed on those major drug trafficking 

and narco-terrorism organizations that operate across jurisdictional boundaries on a regional, national, 

and international level. SOD provides foreign- and domestic-based law enforcement agents with timely 

investigative information that enables them to fully exploit Federal law enforcement’s investigative authority under Title III of the U.S. Code. SOD coordinates overlapping investigations, ensuring that tactical and 

operational intelligence is shared among law enforcement agencies.
STRATEGY TO COMBAT TRANSNATIONAL ORGANIZED CRIME

★ 19 ★

The Organized Crime Drug Enforcement Task Force Fusion Center

Created in June 2006, the Organized Crime Drug Enforcement Task Force (OCDETF) Fusion Center (OFC) 

serves as a central data warehouse for drug intelligence, financial intelligence, and related investigative 

information, and is designed to conduct cross-agency integration and analysis of such data with a view 

to creating comprehensive intelligence pictures of targeted organizations, including those identified as 

Consolidated Priority Organization Targets—the United States’ most wanted international drug and money 

laundering targets. The OFC provides agencies with operational human and financial intelligence, and is 

staffed with agents and analysts detailed from 14 participating investigative agencies. These personnel 

conduct analysis to produce investigative leads, develop target profiles, and identify links between drug 

organizations and other criminal activity in support of drug investigations. 

The International Organized Crime Intelligence and Operations Center

In May 2009, Attorney General Eric Holder announced the establishment of the International Organized 

Crime Intelligence and Operations Center (IOC-2), an entity that marshals the resources and information of 

U.S. law enforcement agencies and Federal prosecutors to collectively combat the threats posed by international criminal organizations. Understanding that international criminal organizations are profit-driven, 

IOC-2 also works with investigators and prosecutors to target the criminal proceeds and assets of international criminal organizations. In recognition of the demonstrated interrelationship between criminal 

organizations that engage in illicit drug trafficking and those that engage in international organized crime 

involving a broader range of criminal activity, IOC-2 works in close partnership with the OFC and SOD.

The Bulk Cash Smuggling Center 

ICE established the National Bulk Cash Smuggling Center (BCSC) in 2009 to combat bulk cash smuggling. 

The BCSC is an operations support facility providing real-time investigative assistance to the Federal, State, 

and local officers involved in enforcement and interdiction of bulk cash smuggling and the transportation 

of illicit proceeds. The BCSC is partnered with the El Paso Intelligence Center to further identify and target 

the financial infrastructure of drug trafficking organizations. These organizations seek to avoid traditional 

financial institutions by repatriating illicit proceeds through commercial and private aircraft, passenger and 

commercial vehicles, maritime vessels, and pedestrians crossing at our U.S. land borders. These combined 

interagency efforts, successful financial investigations, Bank Secrecy Act requirements, and anti-money 

laundering compliance by financial institutions has strengthened formal financial systems and forced 

criminal organizations to seek other means to transport illicit funds across our borders. 

The EPIC Border Intelligence Fusion Section 

The El Paso Intelligence Center (EPIC), managed by the DEA, was established in 1974 to support enforcement efforts against drug and alien smuggling along the Southwest border. EPIC has grown over time to 

better support Federal, State, local and tribal law enforcement. The DHS Office of Intelligence and Analysis 

established the Border Intelligence Fusion Section (BIFS) at EPIC in November 2010 with the objective of 

providing U.S. law enforcement, border enforcement, and investigative agencies with multi-source intelligence and law enforcement information to support investigations, interdictions, and other law enforcement operations related to the Southwest border. The BIFS is a joint, collaborative effort of the Department 

of Homeland Security, Department of Justice, Department of Defense, and partners in the Intelligence 

Community and, as a multi-source/all threats intelligence section at EPIC, the BIFS will access and analyze 

intelligence and information received by and developed at EPIC in order to produce a common intelligence 

picture and common operating picture.
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STRATEGY TO COMBAT TRANSNATIONAL ORGANIZED CRIME

Protect the Financial System and Strategic Markets Against Transnational 

Organized Crime 

Transnational criminals are now more entrepreneurial and sophisticated, and their growing infiltration 

of licit commerce and economic activity fundamentally threatens the free markets and financial systems 

that are critical to the stability and efficiency of the global economy. TOC threatens free markets because 

it disregards the laws and norms that legitimate businesses respect, thereby reaping an unfair competitive advantage. By eroding market integrity, quality, and competitiveness and using financial systems 

to move, conceal, and increase illicit funds, transnational criminals exploit and undermine not only the 

interests of the United States but also those of all countries promoting the rule of law. 

By carefully following strategic and emerging markets for indicators of criminal interest, the United States 

can detect, disrupt, and reduce the economic power of TOC. To do so, the United States will work with 

our international partners to deter or sever crime-state alliances, raise awareness to alert businesses that 

may be unwitting facilitators for criminal enterprises, and continue to develop appropriate safeguards to 

protect the legitimate flow of trade and investment. By targeting criminal assets and opportunities, the 

United States and its allies can markedly reduce the profitability, growth, and evolution of TOC networks.

However, some TOC activity is inherently harder to detect and deter. The United States will place special emphasis on IPR violations and cybercrimes due to their particular impact on the economy and 

consumer health and safety. The United States remains intent on improving the transparency of the 

international financial system, including an effort to expose vulnerabilities that could be exploited by 

terrorist and other illicit financial networks. At the same time, the United States will enhance and apply 

our financial tools and sanctions more effectively to close those vulnerabilities, disrupt and dismantle 

illicit financial networks, and apply pressure on the state entities that directly or indirectly support TOC. 

We will continue to monitor TOC infiltration of the global economy to better protect the financial system 

and freeze the assets of criminal networks under expanded Presidential sanctions authorities and/or 

seize them under existing forfeiture laws. 

Actions

A. Implement a new Executive Order to prohibit the transactions and block the assets under U.S. 

jurisdiction of TOC networks and their associates that threaten critical U.S. interests.

B. Prevent or disrupt criminal involvement in emerging and strategic markets.

C. Increase awareness and provide incentives and alternatives for the private sector to reduce facilitation of TOC.

D. Develop a mechanism that would make unclassified data on TOC available to private sector partners. 

E. Implement the Administration’s joint strategic plan on intellectual property enforcement to target, 

investigate, and prosecute intellectual property crimes committed by TOC.

F. Enhance domestic and foreign capabilities to combat the increasing involvement of TOC networks 

in cybercrime and build international capacity to forensically exploit and judicially process digital 

evidence. 
STRATEGY TO COMBAT TRANSNATIONAL ORGANIZED CRIME

★ 21 ★

G. Use authorities under the USA PATRIOT Act to designate foreign jurisdictions, institutions, or classes 

of transactions as ‘‘primary money-laundering concerns,” allowing for the introduction of various 

restrictive measures on financial dealings by U.S. persons with those entities.

H. Identify foreign kleptocrats who have corrupt relationships with TOC networks and target their 

assets for freezing, forfeiture, and repatriation to victimized governments. 

I. Work with Congress to enact legislation to require disclosure of beneficial ownership information of 

legal entities at the time of company formation in order to enhance transparency for law enforcement and other purposes.

J. Support the work of the Financial Action Task Force, which sets and enforces global standards to 

combat both money laundering and the financing of terrorism.

The Mogilevich Organization

Semion Mogilevich is wanted by the United States for fraud, racketeering, and money laundering and was 

recently added to the FBI’s Ten Most Wanted fugitives list. Mogilevich and several members of his criminal organization were charged in 2003 in the Eastern District of Pennsylvania in a 45-count racketeering 

indictment with involvement in a sophisticated securities fraud and money-laundering scheme, in which 

they allegedly used a Pennsylvania company, YBM Magnex, to defraud investors of more than $150 million. 

Even after that indictment—and being placed on the FBI’s Ten Most Wanted list—Mogilevich has continued to expand his criminal empire. Mogilevich was arrested by Russian police on tax charges in January 

2008 and was released pending trial in July 2009. Other members of his organization remain at large.
STRATEGY TO COMBAT TRANSNATIONAL ORGANIZED CRIME

★ 22 ★

Strengthen Interdiction, Investigations, and Prosecutions

This Strategy sets priorities and objectives to help law enforcement and other applicable agencies at the 

Federal, State, local, territorial and tribal levels work together in a collaborative manner to target TOC 

networks—their leaders as well as their enabling means and infrastructure—in the United States and 

abroad. It is equally important that we build strong working relationships with our international partners 

to harmonize our efforts, and to ensure that they have the capabilities and regulatory and legislative 

frameworks to prevent, reduce, and eliminate TOC threats. 

Building upon the improved information sharing described earlier, the United States will leverage 

consolidated TOC databases to provide more accurate intelligence on known TOC members and their 

associates so they can more easily be denied entry to the United States or access to lawful immigration 

status, employment, or secure facilities.

This Strategy pursues TOC through criminal investigations and interdiction focused on both the networks and their leadership. Criminal investigations will use an integrated approach that incorporates 

financial, weapons, and TOC-related corruption investigations into a comprehensive attack on the 

entire criminal organization. Interdiction efforts will focus on depriving TOC networks of their products, 

proceeds, infrastructure, and enabling means. The use of multi-agency task forces such as the ICE-led 

Border Enforcement Security Task Forces will remain essential to our efforts to investigate and interdict 

TOC threats at our borders.

To address recent TOC trends, the Administration will work with Congress on a range of legislative solutions to allow or enhance the prosecution of TOC enterprises and significant TOC activity that affects 

the United States. We will also enhance our anti-money laundering and forfeiture authorities to target 

TOC networks that pose threats to national and international security. 

Actions

A. Work with Congress to enhance U.S. authorities to identify, investigate, interdict, and prosecute top 

transnational criminal networks.

B. Utilize rewards programs to assist in gathering information leading to the arrest or conviction of 

top transnational criminals.

C. Issue a new Presidential Proclamation under the Immigration and Nationality Act to refuse visas/

deny entry to TOC-affiliated aliens, corrupt foreign officials, and other persons designated for financial sanctions pursuant to the International Emergency Economic Powers Act.

D. Develop a strategy that denies TOC networks and individuals in the United States access to their 

infrastructure and their enabling means.

E. Deny visas to TOC members and associates and capture top TOC figures who take refuge in the 

United States or partner countries.

F. Fully integrate financial, weapons, and TOC-related corruption investigations into comprehensive 

organizational attack activities and operations.
STRATEGY TO COMBAT TRANSNATIONAL ORGANIZED CRIME

★ 23 ★

G. Strengthen cooperation with international police organizations, such as Interpol, Europol, 

Ameripol, and the International Association of Chiefs of Police (IACP), to facilitate cross-border 

police cooperation.

H. Strengthen efforts to interdict illicit trafficking in the air and maritime domains.

I. Develop and implement a whole-of-government plan to counter kidnapping for ransom in order 

to disrupt the funding for terrorists, pirates, and other bad actors. 

J. Deny TOC access to secure facilities and locations. 

The U.S. Secret Service’s Cyber Intelligence Efforts

The U.S. Secret Service leverages technology and information obtained through private partnerships to 

monitor developing technologies and trends in the financial payments industry. The information obtained 

is used to enhance the U.S. Secret Service’s capabilities to prevent and mitigate attacks against the financial 

and telecommunications infrastructures. This approach to intelligence collection and sharing has resulted 

in the successful apprehension of individuals charged with committing some of the world’s most advanced 

cybercrimes during such investigations as those of the Heartland and TJX Intrusions, Maksym Yastremskey, 

Albert Gonzalez, and others. In FY 2010, the U.S. Secret Service arrested 1,217 suspects for cybercrime 

related violations, with a fraud loss of $507 million.

Defending U.S. Borders against TOC

In 2006, amidst rising crime on the Southwest border, ICE and CBP worked with other Federal, State, local, 

and foreign partners to establish the Border Enforcement Security Task Force (BEST), designed to attack 

TOC networks that exploit our borders and threaten the American public. Since then, this initiative has 

grown to 21 BESTs arrayed along the Southwest and Northern borders as well as at major seaports. These 

BESTs have seized more than 36,000 pounds of cocaine, 550 pounds of heroin, 485,000 pounds of marijuana, 4,300 weapons, and $68 million, and led to the arrests of 5,910 individuals. 
★ 24 ★

STRATEGY TO COMBAT TRANSNATIONAL ORGANIZED CRIME

Disrupt Drug Trafficking and Its Facilitation of Other Transnational Threats

In recent years, new developments in technology and communications equipment have enabled TOC 

networks involved in drug trafficking and other illicit activities to plan, coordinate, and perpetrate their 

schemes with increased mobility and anonymity. As a result, many DTOs have developed into versatile, 

loose networks that cooperate intermittently but maintain their independence. They operate worldwide 

and employ sophisticated technology and financial savvy. These criminal networks bribe government 

officials and take advantage of weak border security and ill-equipped law enforcement to facilitate their 

operations. Along emerging trafficking routes, such as the transit route through West Africa to Europe, 

criminal networks are spreading corruption and undermining fledgling democratic institutions. Due 

to the enormous profits associated with drug trafficking, the illegal trade is also a way to finance other 

transnational criminal and terrorist activities. 

To diminish these threats, we will continue ongoing efforts to identify and disrupt the leadership, 

production, intelligence gathering, transportation, and financial infrastructure of major TOC networks. 

By targeting the human, technology, travel, and communications aspects of these networks, we will be 

able to monitor and gather intelligence to identify the full scope of the TOC networks, their members, 

financial assets, and criminal activities. We will continue ongoing efforts to enhance collaboration among 

domestic law enforcement agencies and our foreign counterparts in order to strengthen our ability to 

coordinate investigations and share intelligence to combat drug trafficking and TOC. Continued use 

of economic sanctions under the Foreign Narcotics Kingpin Designation Act (Kingpin Act) to pursue 

transnational drug organizations will enhance our ability to disrupt and dismantle TOC networks. The 

Kingpin Act also may be used to prosecute persons involved in illegal activities linked to drug trafficking, such as arms trafficking, bulk cash smuggling, or gang activity. Enhanced intelligence sharing and 

coordination among law enforcement and intelligence agencies, the military, and our diplomatic community will enable the interagency community to develop aggressive, multi-jurisdictional approaches 

to dismantle TOC networks involved in drug trafficking. 

The United States will continue to aggressively target the nexus among TOC networks involved in drug 

trafficking, terrorist groups, piracy on the high seas, and arms traffickers. In FY 2002, the DEA formally 

established the Counter-Narco-Terrorism Operations Center (CNTOC) within SOD, which coordinates 

all DEA investigations and intelligence linked to narco-terrorism and is central to U.S. efforts to disrupt 

these crime-terror relationships. The United States will utilize its bilateral maritime counterdrug agreements and operational procedures to facilitate cooperation in counterdrug operations. We must attack 

these organizations as close to the source as we can by forward deploying our law enforcement and 

intelligence assets. All-source intelligence is used by U.S. Coast Guard assets in the transit zone to extend 

our borders by interdicting and apprehending traffickers.

The United States will continue its longstanding cooperation with the international community in our 

joint efforts to disrupt the world drug trade through support for drug crop reduction, promotion of 

alternative livelihoods, and partner nation capacity building. Our counternarcotics efforts will apply 

all available tools to ensure that improvements are permanent and sustainable by international allies. 

These efforts will include complementary and comprehensive assistance programs across the prevention, intervention, and enforcement spectrum. By disrupting and dismantling the world’s major TOC 
STRATEGY TO COMBAT TRANSNATIONAL ORGANIZED CRIME

★ 25 ★

networks involved in drug trafficking, we will be able to reduce the availability of illicit drugs, inhibit 

terrorist funding, improve national and international security, and bring TOC networks to justice. 

Actions

A. Work with international partners to reduce the global supply of and demand for illegal drugs and 

thereby deny funding to TOC networks.

B. Sever the links between the international illicit drug and arms trades, especially in strategic regions 

that are at risk of being destabilized by these interconnected threats.

C. Sustain pressure to disrupt Consolidated Priority Organization Targets, as they often have a particularly corrupting influence or provide support to terrorism.

D. Maximize use of the Kingpin Act to pursue transnational drug organizations. 

E. Develop a comprehensive approach to dismantle DTOs with connections to terrorist organizations.

F. Work with international partners to shut down emerging drug transit routes and associated corruption in West Africa.

G. Coordinate with international partners to prevent synthetic drug production, trafficking, and precursor chemical diversion.

Countering Illicit Finance for Drug Traffickers & Terrorists

In February 2011, the U.S. Department of the Treasury, based upon an investigation by the DEA, announced 

the identification of the Lebanese Canadian Bank (LCB) as a financial institution of primary money laundering concern under Section 311 of the USA PATRIOT Act. The Department of the Treasury found there 

was reason to believe LCB managers were complicit in facilitating the money-laundering activities of an 

international narcotics trafficking and money laundering network controlled by Ayman Joumaa who was 

designated as a drug Kingpin on January 26, 2011 pursuant to the Kingpin Act. This network moved illegal 

drugs from South America to Europe and the Middle East via West Africa and laundered hundreds of millions of dollars monthly through accounts held at LCB, as well as through trade-based money laundering 

involving consumer goods throughout the world, including through used car dealerships in the United 

States. The U.S. Government also found reason to believe there were links between the international 

narcotics trafficking and money laundering network, LCB, and the terrorist organization Hizballah.

International Drug Enforcement Conference

The annual DEA-led International Drug Enforcement Conference (IDEC), which has been held annually 

for the past 28 years, is a major contributor to international cooperation and capacity building. The IDEC 

brings the top drug law enforcement leaders and senior investigators from over 100 nations to a single 

venue where yearly agendas are set for cooperation, intelligence sharing, and case prioritization. IDEC—

the world’s largest international drug law enforcement conference—has produced concrete results year 

after year. During the conferences, DEA and partner nations jointly develop plans to build greater law 

enforcement and investigatory capacity. In addition, host nation personnel and U.S. law enforcement 

exchange information on priority investigatory targets. 
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STRATEGY TO COMBAT TRANSNATIONAL ORGANIZED CRIME

Build International Capacity, Cooperation, and Partnerships

Sustainable progress against TOC requires both political commitment and effective law enforcement 

and criminal justice capacities on a worldwide basis. TOC threatens the security and well-being of people 

around the world and jeopardizes the functioning of the global economy. Not all of these threats are 

equally visible to international audiences. Absent broad recognition of these shared threats, our collaboration with international partners to confront TOC will be constrained by limited political will. The 

United States will reach out directly to the international business community and the general public to 

convey that both nations and individuals share a common enemy in TOC and have a common stake in 

addressing this threat. 

For nations that have the will to fulfill their international law enforcement commitments but lack the 

necessary means, the United States is committed to partnering with them to develop stronger law 

enforcement and criminal justice institutions necessary for ensuring the rule of law. Over the past 

decade, important gains have been made in developing criminal justice capacities in key regions of the 

world. The goal of the United States is to promote the expansion of such achievements on a worldwide 

basis, to the point where international law enforcement capabilities and cooperation among states are 

self-sustaining. Great progress also has been made in developing a common normative framework for 

international cooperation against TOC threats. The challenge for the United States and other countries 

over the next decade is to bring the promise of this worldwide regime into practice. The United States 

will encourage international partners to dedicate the necessary political capital and resources toward 

making the promise of these commitments a reality. The United States will pursue this through both a 

renewed commitment to multilateral diplomacy and by leveraging bilateral partnerships to elevate the 

importance of combating TOC as a key priority of U.S. diplomacy. For example, in February 2011, the 

United States and the United Kingdom established the Organized Crime Contact Group, to be chaired by 

the UK Home Secretary and the Assistant to the President for Homeland Security and Counterterrorism. 

In addition, the United States deploys hundreds of law enforcement attachés to its missions abroad 

to develop and maintain foreign contacts essential to combating immediate threats to public safety 

and security. The United States will continue to place a high priority on the provision of international 

technical assistance through our missions abroad and will continue to improve the coordination of 

these programs.

The United States will leverage all possible areas of cooperation, including legal instruments such as 

the UN Convention against Transnational Organized Crime (the Palermo Convention), the UN Convention 

against the Illicit Traffic in Narcotic Drugs and Psychotropic Substances, and the protocols to which the 

United States is a party, to obtain the assistance of international partners and to raise international 

criminal justice, border security, and law enforcement standards and norms. The United States will 

strengthen its engagement with the United Nations in this regard and leverage the growing role of 

regional and other multilateral institutions that have risen in significance and influence over the past 

decade. Additionally, the United States will continue to pursue cooperation with other countries and 

with partners such as the European Union, the G-8, the G-20, and new inter-regional platforms across the 

Pacific and Atlantic in developing leading-edge initiatives and political commitments to combat TOC. 

The United States also will seek to develop informal partnerships with states that share U.S. goals to 

prevent TOC networks from abusing the benefits of globalization. By promoting flexible networks of law 
STRATEGY TO COMBAT TRANSNATIONAL ORGANIZED CRIME

★ 27 ★

enforcement and diplomatic partners, the United States can leverage the expertise and infrastructure 

of committed governments and respond more quickly to changing dynamics in transnational criminal 

threats. The United States convened a meeting of 25 countries and jurisdictions across the Pacific in 

April 2009 to consider common approaches and strengthen cooperation against transnational criminal 

networks that span East Asia, the Pacific, and Latin America. The United States hosted a similar event in 

May 2011 with the European Union to generate enhanced partnerships against trans-Atlantic criminal 

networks operating across Latin America, West Africa, and Europe. By building cooperative platforms 

and networks incrementally, the United States will generate greater collective action, joint cases, and 

common strategic approaches with our international partners to combat transnational criminal threats. 

Actions

A. Raise international awareness of TOC and build multilateral cooperation against it.

B. Partner with countries able to contribute key law enforcement resources, other donors, and the 

United Nations to launch a new International Police Peacekeeping Operations Support Program to 

enhance policing and law enforcement capacity in ungoverned spaces.

C. Leverage assets to enhance foreign capabilities, including counterterrorism capacity building, 

foreign law enforcement cooperation, military cooperation, and the strengthening of justice and 

interior ministries. 

D. Implement a public diplomacy strategy to reduce the demand for illicit goods and services that 

fuels TOC.

E. Implement the Central American Citizen Security Partnership to strengthen courts, civil society 

groups and institutions that uphold the rule of law in the region.

F. Implement the State Department’s West Africa Citizen Security Initiative to combat transnational 

criminal threats in the region. 

G. Initiate new dialogue in multilateral fora to combat corruption and illicit trade, to include, as part of 

the Administration’s intellectual property enforcement strategy, stemming the flow of dangerous 

counterfeit products. 

H. Build partnerships with other donors, private sector experts, nongovernmental organizations, civil 

society groups, the media, and academia that focus on supporting political will for criminal justice 

reform.

I. Increase international scientific research, data collection, and analysis to assess the scope and impact 

of TOC and the most effective means to combat it. 

J. Institutionalize the U.S.-UK Organized Crime Contact Group to deepen bilateral cooperation and 

galvanize multilateral collaboration against TOC.

K. Finalize the U.S.-Mexico 21st Century Border Action Plan agreements on law enforcement 

cooperation. 

L. Expand cooperation with the United Nations to promote implementation of the United Nations 

Convention against Transnational Organized Crime, including through the development of an 

appropriate review mechanism.
STRATEGY TO COMBAT TRANSNATIONAL ORGANIZED CRIME

★ 28 ★

M. Strengthen capacities for program management, internal controls, and contract administration to 

prevent the diversion or improper use of foreign assistance in countries threatened by TOC-related 

corruption.

N. Increase collaboration with international partners to improve their capacity to support immigration, 

customs, transportation, and critical infrastructure screening requirements and to harmonize their 

standards for screening and identification. 

Combating Transnational Crime: The Multilateral Framework

Five major international agreements underpin and provide near global scope to our efforts to combat 

TOC and corruption: the United Nations Convention against Transnational Organized Crime (UNTOC), its 

three supplementary protocols against trafficking in persons, migrant smuggling, and illicit trafficking in 

firearms, and the United Nations Convention against Corruption (UNCAC). The United States strongly supports the framework provided by these instruments, especially with regard to prosecuting and investigating transnational crime and corruption, engaging in mutual legal assistance, and supplementing bilateral 

extradition treaties. These agreements set the point of departure for many of our bilateral law enforcement 

partnerships around the globe and help bring the international community into agreement with U.S. 

standards. The key challenge remaining is to promote wider implementation of the Conventions through 

support for capacity building and by otherwise encouraging international partners to dedicate the necessary political capital and resources toward realizing the potential of these groundbreaking instruments.