GAO 

United States Government Accountability Office

Report to Congressional Requesters

COMBATING 

TERRORISM 

U.S. Agencies Report 

Progress Countering 

Terrorism and Its 

Financing in Saudi 

Arabia, but Continued 

Focus on Counter 

Terrorism Financing 

Efforts Needed 

September 2009 

GAO-09-883 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

September 2009

COMBATING TERRORISM

U.S. Agencies Report Progress Countering Terrorism 

and Its Financing in Saudi Arabia, but Continued 

Focus on Counter Terrorism Financing Efforts

Needed 

Highlights of GAO-09-883, a report to 

congressional requesters 

The U.S. government strategy to collaborate with Saudi Arabia on 

counterterrorism utilizes existing diplomatic and security-related efforts to 

create an active antiterrorism coalition by enhancing the Saudi government’s 

ability to combat terrorists and prevent financial support to extremists. These 

objectives are contained in Department of State’s (State) Mission Strategic 

Plans (MSP) for Saudi Arabia for fiscal years 2006 through 2009, and also 

reflected in a January 2008 report from State to the Congress on its strategy 

for Saudi Arabia. The MSPs include performance targets to measure progress 

on efforts to combat terrorism and its financing, such as providing security 

training to the Saudi government, strengthening Saudi financial institutions, 

and implementation of relevant Saudi regulations. 

U.S. and Saudi officials report progress on countering terrorism and its 

financing within Saudi Arabia, but noted challenges, particularly in preventing 

alleged funding for terrorism and violent extremism outside of Saudi Arabia. 

In April 2009, State assessed progress related to its goal of building an active 

U.S.-Saudi antiterrorist coalition as “on target.” U.S. and Saudi officials report 

progress in enhancing the Saudi government’s ability to combat terrorists, and 

note the Saudi government’s efforts have disrupted Al Qaeda’s terrorist 

network within Saudi Arabia. However, these officials noted Saudi Arabia’s 

neighbor, Yemen, is emerging as a base from which Al Qaeda terrorists can 

launch attacks against U.S. and Saudi interests. U.S. and Saudi officials also 

report progress on efforts to prevent financial support to extremists, citing, 

for example, the Saudi government’s regulations on sending charitable 

contributions overseas, and the arrest and prosecution of individuals 

providing support for terrorism. However, U.S. officials remain concerned 

about the ability of Saudi individuals and charitable organizations to support 

terrorism outside of Saudi Arabia, and noted limited Saudi enforcement 

capacity and terrorists’ use of cash couriers as challenges. Despite these 

concerns, some performance targets related to countering terrorism financing 

were removed from State’s current MSP. According to State officials, these 

changes were made either because a specific target was no longer considered 

feasible or because progress was made toward the target. 

Goal, Objectives, Assessment, and Challenges of U.S. Collaboration with Saudi Arabia on 

Counterterrorism 

Build an 

active 

antiterrorist 

coalition

Goal Objectives U.S. Agencies’ Assessment Challenges

Enhance the 

Saudi 

government’s ability 

to combat terrorists

Saudi government’s efforts have 

disrupted Al Qaeda’s terrorist 

network within Saudi Arabia

Yemen is emerging as a base 

for Al Qaeda to plan attacks

against U.S. and Saudi 

interests

Progress made in preventing 

financial support to extremists, 

but concerns remain about the 

ability of Saudi individuals and 

charitable organizations to 

support terrorism outside Saudi 

Arabia

Limited capacity of Saudi 

government, the use of cash 

couriers by terrorist financiers, 

and circumvention of cash 

declarations laws pose 

challenges to combating 

terrorism financing

Prevent 

financial 

support to 

extremists

Source: GAO analysis of U.S. agency information.

The U.S. government considers the 

Kingdom of Saudi Arabia a vital 

partner in combating terrorism. 

The strong diplomatic relationship 

between the United States and 

Saudi Arabia, founded more than 

70 years ago, was strained by the Al 

Qaeda attacks of September 11, 

2001, that were carried out in large 

part by Saudi nationals and killed 

thousands of U.S. citizens. 

 

GAO was asked to report on (1) the 

U.S. government strategy to 

collaborate with and assist the 

Kingdom of Saudi Arabia to 

counter terrorism and terrorism 

financing, and (2) U.S. government 

agencies’ assessment of and the 

Saudi government’s views on 

progress toward the goals of this 

strategy. GAO analyzed relevant 

U.S. and Saudi strategy, planning, 

and evaluation documents related 

to efforts since 2005, and discussed 

these efforts with subject matter 

experts and U.S. and Saudi officials 

in Washington, D.C., and Riyadh 

and Jeddah, Saudi Arabia. 

GAO submitted a copy of this 

report to intelligence agencies, the 

National Security Council, and the 

Departments of Defense, Energy, 

Homeland Security, Justice, State, 

and Treasury for their review and 

comment. 

What GAO Recommends

GAO recommends the Secretary of 

State direct the U.S. mission in 

Saudi Arabia to reinstate certain 

targets related to preventing 

financing of terrorism outside of 

Saudi Arabia. State agreed with this 

recommendation. 

View GAO-09-883 or key components.

For more information, contact Zina D. Merritt 

at (202) 512-5257 or merrittz@gao.gov. 
Page i GAO-09-883 

Contents 

Letter 1

Background 4 

U.S. Government Strategy Is to Create an Active Antiterrorism 

Coalition with Saudi Arabia, but Some Targets to Measure 

Progress toward This Goal Have Been Removed 11 

U.S. Agencies and Saudi Officials Report Progress in Combating 

Terrorism and Its Financing in Saudi Arabia, but Challenges 

Persist, Particularly in Preventing Alleged Funding for Terrorism 

and Violent Extremism outside of Saudi Arabia 16 

Conclusion 41 

Recommendation for Executive Action 42 

Agencies Comments, Third-Party Views, and Our Evaluation 42 

Appendix I Objectives, Scope and Methodology 44 

Appendix II Time Line of Key Events in U.S. and Saudi 

Relations, 1750-2004 47 

Appendix III Saudi Ministries and Agencies that Have Functions 

Related to Countering Terrorism and Terrorism 

Financing 50 

Appendix IV U.S. Agencies Providing Training and Technical 

Assistance to Saudi Arabia, 2005-2008 51 

Appendix V Comments from the Department of State 52 

Appendix VI Comments from the Department of Defense 54 

Appendix VII GAO Contact and Staff Acknowledgments 55 

 U.S.-Saudi Counterterrorism Efforts 
Related GAO Products 56

Table 

Table 1: Selected Legislation and Associated Reporting 

Requirements on Efforts to Counter Terrorism and 

Terrorism Financing, Including Efforts Related to Saudi 

Arabia 10 

Figures 

Figure 1: Map of the Kingdom of Saudi Arabia 5 

Figure 2: Interactive Time Line of Key Events in U.S. and Saudi 

Relations, 1750-2004 8 

Figure 3: Objectives and Performance Targets of Mission Strategic 

Plan for Saudi Arabia, Fiscal Years 2006-2009 14 

Figure 4: U.S. Agencies’ Assessment of Progress as of August 2009 

on Mission Strategic Plan Performance Targets Related to 

Combating Terrorists, Fiscal Years 2006-2008 17 

Figure 5: Saudi Arabia’s National Campaign against Extremism and 

Terrorism, Examples of Public Outreach 23 

Figure 6: Sample of Saudi Literature (with Translated Titles) 

Designed to Combat Extremist Ideology 25 

Figure 7: U.S. Agencies’ Assessment of Progress as of August 2009 

on Mission Strategic Plan Performance Targets Related to 

Preventing Financial Support to Extremists, Fiscal Years 

2006-2008 30 

Figure 8: Official Saudi Customs Declaration Form 38 

Page ii GAO-09-883 U.S.-Saudi Counterterrorism Efforts
Abbreviations 

DHS Department of Homeland Security 

DOD Department of Defense 

DOE Department of Energy 

DOJ Department of Justice 

FAA Foreign Assistance Act 

FATF Financial Action Task Force 

FBI Federal Bureau of Investigation 

FIU Financial Intelligence Unit 

ICE U.S. Immigration and Customs Enforcement 

IIRO International Islamic Relief Organization 

INCSR International Narcotics Control Strategy Report 

MOI Ministry of Interior 

MSP Mission Strategic Plan 

NSC National Security Council 

OPM-MOI Office of Program Management–Ministry of Interior 

SAMA Saudi Arabian Monetary Agency 

UN United Nations 

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Page iii GAO-09-883 U.S.-Saudi Counterterrorism Efforts
Page 1 GAO-09-883 

 

United States Government Accountability Office

Washington, DC 20548 

 

September 24, 2009 

The Honorable Harry Reid 

Majority Leader 

United States Senate 

The Honorable Howard L. Berman 

Chairman 

The Honorable Ileana Ros-Lehtinen 

Ranking Member 

Committee on Foreign Affairs 

House of Representatives 

The U.S. government considers the Kingdom of Saudi Arabia a vital 

partner in combating terrorism and advancing other U.S. foreign policy 

priorities, such as achieving security in Iraq, advancing the IsraeliPalestinian peace process, and ensuring stability in world oil markets. The 

strong diplomatic relationship between the United States and Saudi 

Arabia, founded more than 70 years ago, was strained by the Al Qaeda 

attacks of September 11, 2001, that were carried out in large part by Saudi 

nationals and killed thousands of U.S. citizens. Nevertheless, the United 

States and Saudi Arabia currently have an ongoing dialogue on a range of 

counterterrorism issues, which include high-level discussions and 

working-level collaboration. 

The National Commission on Terrorist Attacks upon the United States 

(9/11 Commission) was established in 2002 to prepare a full account of the 

circumstances surrounding the September 11, 2001, terrorist attacks, 

including alleged Saudi links to the attacks.1

 The 9/11 Commission’s 2004 

report found no evidence that the Saudi government funded Al Qaeda, but 

noted that terrorist groups like Al Qaeda raised funds from Saudi 

individuals and charitable organizations headquartered in Saudi Arabia. In 

addition, media reports continue to contain allegations that some Saudi 

individuals and charitable organizations support terrorism and violent 

extremism outside of Saudi Arabia. In 2003 and 2004, a series of terrorist 

attacks against both Saudi and U.S. interests were launched in Saudi 

Arabia, prompting the Saudi government to intensify its efforts to combat 

1

The National Commission on Terrorist Attacks upon the United States is an independent 

bipartisan entity created by the Congress. 

 U.S.-Saudi Counterterrorism Efforts 
 

terrorism, including targeting sources of violent extremism within the 

country. 

In 2004, the 9/11 Commission recommended that the United States openly 

engage the government of Saudi Arabia to build a cooperative 

counterterrorism relationship. In August 2007, the President signed the 

Implementing Recommendations of the 9/11 Commission Act of 2007, 

which required that the President of the United States report on a longterm strategy to work with the Saudi government to, among other things, 

combat terrorism through such measures as preventing the financing of 

terrorists by Saudi institutions and citizens.2

 Additionally, it required that 

the report provide an assessment of Saudi Arabia’s progress in these areas 

since 2001. Also, at the request of the Congress, in 2005, we reported on 

allegations that Saudi private entities and individuals had financed or 

supported violent extremism.3

 In our report, we noted that the threat of 

global propagation of violent extremism was emerging not only from Saudi 

sources, but also from sources in other countries, such as Iran, Kuwait, 

and Syria, as well as from indigenous groups within some countries. In 

2005, we also reported on U.S. government efforts to combat terrorist 

financing abroad that included standards setting and training and technical 

assistance in areas such as preventing cash couriers, which refers to 

criminals’ cross-border movements of cash.4

This report provides information on U.S. and Saudi efforts to address 

alleged terrorism and terrorism financing since 2005. Specifically, we 

report on (1) the U.S. government strategy to collaborate with and assist 

the Kingdom of Saudi Arabia to counter terrorism and terrorism financing, 

and (2) U.S. government agencies’ assessment of and Saudi government 

views on progress toward the goals of the U.S. strategy to collaborate with 

and assist the Kingdom of Saudi Arabia. 

To address these objectives, we reviewed and analyzed relevant U.S. 

strategy, planning, and evaluation documents related to U.S.-Saudi efforts 

 

2

Implementing Recommendations of the 9/11 Commission Act of 2007, August 3, 2007 

(Pub. L. No. 110–53, Sec. 2043). 

3

GAO, International Affairs: Information on U.S. Agencies’ Efforts to Address Islamic 

Extremism, GAO-05-852 (Washington, D.C.: Sept. 16, 2005). 

4

GAO, Terrorist Financing: Better Strategic Planning Needed to Coordinate U.S. Efforts 

to Deliver Counter-Terrorism Financing Training and Technical Assistance Abroad, 

GAO-06-19 (Washington, D.C.: Oct. 24, 2005). 

Page 2 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

to counter terrorism and terrorism financing efforts since 2005. While we 

did not assess the key elements of a strategy as identified by GAO for the 

U.S. counterterrorism strategy related to Saudi Arabia as stated in the 

Mission Strategic Plans (MSP), we used the performance targets stated in 

these documents as criteria against which we assessed progress. Further, 

we obtained and examined documentation from Saudi officials regarding 

their domestic activities to counter terrorism and its financing. We 

discussed U.S.-Saudi counterterrorism efforts with U.S. officials from the 

Departments of State (State), Treasury (Treasury), Homeland Security 

(DHS), Defense (DOD), Justice (DOJ), Energy (DOE), National Security 

Council (NSC), and the intelligence community; Saudi officials from the 

Royal Embassy of Saudi Arabia in Washington, D.C.; and subject matter 

experts from a variety of academic institutions and nongovernmental 

organizations. Additionally, we traveled to Riyadh and Jeddah, Saudi 

Arabia, where we visited the Prince Mohammed bin Nayef Center for 

Advisory and Care in Riyadh—a counseling program designed to 

reeducate violent extremists—and met with U.S. officials from State, 

Treasury, DOJ, DOD, and DHS; Saudi officials from the Saudi Arabian 

Monetary Agency (SAMA), and the Ministries of Foreign Affairs, Interior, 

and Islamic Affairs; and representatives from the Saudi charitable 

organization the World Assembly of Muslim Youth. (See appendix I for a 

complete description of our scope and methodology.) 

We conducted this performance audit from July 2008 through September 

2009 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. 

In this report we recommend that the Secretary of State direct the U.S. 

mission in the Kingdom of Saudi Arabia to reinstate, in consultation with 

relevant U.S. agencies, performance measures related to preventing the 

flow of alleged financial support, through mechanisms such as cash 

couriers, to terrorists and extremists outside Saudi Arabia. 

In commenting on a draft of this report, State concurred with our 

recommendation, and committed to reinstating performance indicators 

relating to Saudi enforcement of cash courier regulations in its Mission 

Strategic Plan for Saudi Arabia. DOD stated that it concurs with our 

report. We also received technical comments from DOD, DOE, NSC, State, 

Treasury, and the intelligence community. Additionally, consistent with 

Page 3 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

our protocols, we provided a copy of the draft report to Saudi officials, 

who described the report as a fair and detailed review of U.S. and Saudi 

efforts and offered technical comments. We incorporated technical 

comments as appropriate. 

Background 

Kingdom of Saudi Arabia Saudi Arabia is known as the birthplace of Islam and is the site of Islam’s 

two holiest shrines located in Mecca and Medina. (See figure 1 for a map 

of Saudi Arabia.) Millions of Muslims from all over the world visit Mecca 

to undertake the pilgrimages of hajj and umrah.5

 Like hajj, charitable 

giving, or zakat, is one of the five pillars or duties of Islam.6

 Zakat, a form 

of tithe or charity payable for those in need, is an annual flat rate of 2.5 

percent of a Muslim’s assessable capital. Zakat is broader and more 

pervasive than Western ideas of charity, functioning as a form of income 

tax, educational assistance, and foreign aid. 

 

5

The annual pilgrimage of hajj is one of the five pillars of Islam and required to be 

undertaken by all Muslims who are physically and financially able to do so at least once in 

their lifetime. Another pilgrimage to Mecca is called the umrah, which, unlike the hajj, can 

be undertaken at any time of the year and is not considered compulsory. 

6

Islam has five pillars or duties required of all observant Muslims. These duties are: (1) 

shahada (profession of monotheistic faith), (2) salat (praying five times a day), (3) zakat

(charitable giving), (4) sawm (fasting annually as a religious observance), and (5) hajj

(pilgrimage to Mecca). 

Page 4 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

Figure 1: Map of the Kingdom of Saudi Arabia

a

2009 (estimate) 

b

2008 (estimate) 

Islam is a source of political legitimacy and guidance for the Saudi 

government, and the country is governed on the basis of Islamic law or 

Sharia. As far back as the mid-eighteenth century, the founder of the Saudi 

ruling dynasty, Muhammad bin Saud, allied himself with the conservative 

Muslim scholar, Muhammad bin Abdul Wahhab. The teachings of Abdul 

Page 5 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

Wahhab, which called for a strict interpretation of Islam, form the basis of 

Islam as practiced by the majority of people in Saudi Arabia.7

The Saudi government is a monarchy headed by the king of Saudi Arabia, 

who also serves as the Prime Minister and the Custodian of the Two Holy 

Mosques in Mecca and Medina. The current king is King Abdullah bin 

Abdulaziz Al-Saud. The king is expected to retain consensus of important 

elements in Saudi society, such as the Saudi royal family and religious 

leaders. The Saudi royal family consists of thousands of members, some of 

whom head government ministries. 

In the mid-1940s, Saudi Arabia started large scale oil production, and by 

the 1970s an increase in oil prices led to a rapid increase in Saudi Arabia’s 

per capita income, making it comparable to that of developed countries 

during this time period.8

 In part, this prosperity, combined with the Islamic 

religious obligation toward charitable giving or zakat, led to the 

establishment of charitable organizations headquartered in Saudi Arabia, 

known as multilateral charitable organizations. These organizations—

which include the Muslim World League and the World Assembly of 

Muslim Youth—were established in the 1960s and 1970s by Saudi royal 

decree to spread Islam and provide humanitarian assistance around the 

world, and received funds from the Saudi government and citizens. 

U.S.-Saudi Relations Relations between the United States and Saudi Arabia have a long 

historical context. Since the establishment of the modern Saudi state in 

1932, and throughout the Cold War, the governments of the United States 

and Saudi Arabia developed a relationship based on shared interests, 

including energy production and combating communism.9

 For instance, 

both Saudi Arabia and the United States became major supporters of the 

Afghan mujahideen’s struggle against the Soviet invasion in 1979.10

However, U.S. foreign policies related to the Middle East, such as the 

 

7

Muhammad bin Abdul Wahhab called for a return to the fundamentals of Islam as 

embodied in the Quran, Islam’s holy book, and life of the Prophet Mohammad. 

8

In contrast, according to World Bank reporting, from 1980 to 1992 Saudi Arabia’s gross 

national product per capita declined on average by 3.3 percent annually. 

9

For more information on U.S.-Saudi relations, also see Congressional Research Service, 

Saudi Arabia: Background and U.S. Relations, August 13, 2009. 

10Muslims from many countries, including Saudi Arabia, joined the Afghan mujahideen as 

an expression of their religious solidarity as well as to fight communism. 

Page 6 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

Israeli-Palestinian conflict, have at times tested U.S.-Saudi government 

relations and fueled a growing anti-American sentiment among some 

segments of the Saudi population, as well as in many countries with 

predominantly Muslim populations. (See figure 2 for more information on 

the historical development of U.S.-Saudi relations.) As we have reported 

previously,11 this negative perception of U.S. foreign policy, as well as 

other factors such as economic stagnation, a disproportionate youth and 

young adult population,12 and repressive and corrupt governments in 

certain Middle Eastern countries, have contributed to the global spread of 

an extremist ideology promoting hatred, intolerance, and violence that 

threatens U.S. national security interests. 

 

11GAO-05-852. 

12Saudi officials and counterterrorism experts told us that those attracted to extremism 

tend to be young adult males. 

Page 7 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
Saudi power and influence expands

1750 1900 1910 1920 1930 1940 1950 1960 1970 1980 1990 2000 2010

1979

1970s

1960s

1945

1940s

1948

1980s 1991

1994

2000:

1995

1996

1993

1932

INSTRUCTIONS

Roll your mouse over 

the date to see more 

information. To print 

expanded information, 

see Appendix II.

Mid-18th Century

1902 to 1926

Modern 

Kingdom of 

Saudi

Arabia 

established

1933

U.S.-Saudi 

diplomatic 

relations 

established

Alliance between 

Muhammad bin 

Saud and a 

conservative 

Muslim leader

Saudi

Arabia allies

with the 

United 

States in 

fighting 

communism

1953

First U.S. 

military 

training 

mission 

organized 

under the 

terms of the 

U.S. and 

Saudi

mutual 

defense 

assistance 

agreement 

First

multilateral 

charitable 

organization 

founded in 

Saudi Arabia

United States 

establishes 

military 

installations in 

Saudi Arabia

Bombing of 

the World 

Trade Center 

kills 6

Saudi Arabia 

recognizes 

the Taliban 

regime in 

Afghanistan

• Saudi 

government 

strips 

Osama bin 

Laden of 

citizenship

• Islamists 

arrested in 

Saudi Arabia

Terrorist 

attack in 

Saudi Arabia 

kills 5 

Americans

Bombings in 

Saudi Arabia 

kill 19 

Americans

• Start of the 

Palestinian 

uprising 

strains 

U.S.-Saudi 

relations

• Attack on 

USS Cole

Saudi Arabia 

and United 

States aid the 

mujahideen

against the 

Soviets in 

Afghanistan

Oil production 

creates great 

wealth in 

Saudi Arabia

• Iran is

established 

as an Islamic

state

• Soviets invade 

Afghanistan

• Extremists 

attack Grand 

Mosque in 

Mecca

2001

2003

2004

2003 to present

Escalation in 

terrorist attacks 

in Saudi Arabia 

and Saudi 

government 

retaliation

Iraqi insurgency 

attracts foreign 

fighters, 

including Saudis

• Al Qaeda 

attacks United 

States

• Saudi Arabia 

condemns 

September 

11th attacks on 

the United 

States

• U.S. and allied 

forces attack

the Taliban 

and Al Qaeda 

in Afghanistan

• United States 

begins military 

operations in 

Iraq 

• Major terrorist

incidents in 

Saudi Arabia

Saudi Arabia 

starts large 

scale oil 

production

Saudi King

meets with

President

Roosevelt

State of

Israel

established

1997

UN Security 

Council 

adopts 

Resolution 

1267 

1999

Mid-18th Century

Source: GAO.

1950s

Figure 2: Interactive Time Line of Key Events in U.S. and Saudi Relations, to 1750-2004

Page 8 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

According to the U.S. government and experts, some Saudi individuals and 

charitable organizations have knowingly or unknowingly provided 

financial assistance for terrorism and violent extremism. For example, 

according to a report by the 9/11 Commission, some charitable 

organizations, such as the Saudi-based Al Haramain Islamic Foundation, 

had been exploited by extremists as funding mechanisms to further their 

goal of violence against non-Muslims. U.S. government and other expert 

reports have linked some Saudi donations to the global propagation of 

religious intolerance and support to terrorist activities. For example, 

Osama bin Laden and Al Qaeda have Saudi roots and accumulated millions 

of dollars using legitimate charities, nongovernmental organizations, and 

mosques, as well as businesses such as banks and other financial 

institutions, to help raise and move their funds. However, experts agree 

that it is difficult to determine the extent to which donors are aware of the 

ultimate disposition of the funds provided.13

Saudi Government Efforts 

to Combat Terrorism and 

Terrorism Financing, 2003-

2005 

Although the Saudi government took actions to combat terrorists 

following the September 11, 2001, attacks, Al Qaeda’s attacks against 

Saudi and U.S. citizens in Saudi Arabia in 2003 and 2004 marked a turning 

point in the Saudi government’s efforts to combat terrorism and terrorism 

financing, as the Saudi government came to see Al Qaeda as a threat to the 

Saudi regime. Between 2003 and 2005, the Saudi government reported that 

it took a number of actions to combat terrorism and terrorism financing 

within the Kingdom, some with U.S. assistance, such as increasing the size, 

training, and professionalism of Saudi security forces. The Saudi and U.S. 

governments also undertook joint designations of several branches of the 

Al Haramain Foundation as financiers of terrorism under UN Security 

Council Resolution 1267.14 (See appendix III for key Saudi agencies 

involved in efforts to combat terrorism and terrorism financing within 

Saudi Arabia.) 

 

13For more information on Saudi Arabia-related terrorism financing issues, see 

Congressional Research Service, Saudi Arabia: Terrorist Financing Issues, June 11, 2008. 

14United Nations (UN) Security Council resolution 1267 (Oct. 15, 1999) led to the 

establishment of a committee that created a list of individuals and entities designated for 

their association with Al Qaeda, Osama bin Laden, and/or the Taliban. 

Page 9 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

Since 2005, several U.S. agencies have conducted training and provided 

technical assistance to improve the capacity of the Saudi government to 

combat terrorism and its financing. These efforts have included enhancing 

the investigative capability of Saudi ministries and assessing the security 

of Saudi oil installations, among others. U.S. agencies involved in these 

efforts include DOD, DOE, DHS, DOJ, State, and Treasury, as well as the 

intelligence community.15 (See appendix IV for U.S. agencies providing 

training and technical assistance to Saudi Arabia to counter terrorism and 

terrorism financing.) 

U.S. Assistance to Saudi 

Arabia to Combat 

Terrorism and Terrorism 

Financing 

Legislative Reporting 

Requirements 

The Congress has enacted several laws that require U.S. agencies to report 

on terrorism and terrorism financing issues, including those related to U.S. 

collaboration with Saudi Arabia. (See table 1 for the selected legislation 

and its requirements.) 

Table 1: Selected Legislation and Associated Reporting Requirements on Efforts to Counter Terrorism and Terrorism 

Financing, Including Efforts Related to Saudi Arabia 

Legislation Reporting requirements Lead agency Agency response 

Foreign Assistance Act 

(FAA) of 1961 Section 489, 

as amended (22 U.S.C. 

Section 2291) 

A report on the extent to which each country or entity 

that received assistance under Chapter 8 of Part I of 

the Foreign Assistance Act in the past two fiscal 

yearsa

 has “met the goals and objectives of the United 

Nations Convention Against Illicit Traffic in Narcotic 

Drugs and Psychotropic Substances” (the “1988 UN 

Drug Convention”) Section 489(a)(1)(A). 

In addition, the Congress also mandated the report to 

identify major money laundering countries (FAA 

section 489(a)(3)(C)) and findings on each country’s 

adoption of laws and regulations to prevent narcoticsrelated money laundering (FAA section 489(a)(7)(C)). 

State The Money Laundering and 

Financial Crimes section of the 

Department of State’s annual 

International Narcotics Control 

Strategy Report (INCSR), 

which includes reporting on 

Saudi Arabia. 

The 2009 INCSR is the 26th 

such report 

 

15In this report, we focus on U.S. agency efforts to collaborate with Saudi Arabia between 

2005 and 2009. GAO previously reported (GAO-05-852) on U.S. agencies’ assistance to Saudi 

Arabia in 2005. 

Page 10 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

Legislation Reporting requirements Lead agency Agency response 

Intelligence Reform and 

Terrorism Prevention Act of 

2004 (P.L. 108-458) Section 

7120(3) 

A description of the strategy of the United States for 

expanding collaboration with the Government of Saudi 

Arabia on subjects of mutual interest and importance, 

including intelligence and security cooperation 

between the United States and Saudi Arabia in the 

fight against extremism 

State Country Reports on Terrorism

Starting in 2004, this annual 

report replaced the previously 

published Patterns of Global 

Terrorism

Implementing the 

Recommendations of the 

9/11 Commission Act of 

2007 (P.L. 110-53) Section 

2043(c) 

A one-time description of the long-term strategy of the 

United States to engage the Government of Saudi 

Arabia on combating terrorism and provide an 

assessment of Saudi Arabia’s progress in this area 

since 2001 

State U.S. Strategy Toward Saudi 

Arabia 

Source: GAO 

a

In fiscal years 2007 and 2008, State reports providing Saudi Arabia approximately $400,000 in 

foreign assistance funding ($300,000 in fiscal year 2007 and $99,000 in fiscal year 2008) through its 

Nonproliferation, Antiterrorism, Demining, and Related Programs account. 

In January 2008, in response to the Implementing Recommendations of the 

9/11 Commission Act of 2007, State submitted to the Congress a report on 

the U.S. strategy to collaborate with and assist Saudi Arabia in areas 

including countering terrorism and terrorism financing.16 The goals and 

objectives contained in the January 2008 document coincide with the 

plans for collaboration with Saudi Arabia contained in State’s Mission 

Strategic Plans (MSP) for Saudi Arabia for fiscal years 2006 to 2009. To 

measure progress toward the goal of building an active antiterrorist 

coalition, the MSPs contain a number of performance targets; however, 

some of the targets relating to countering terrorism financing were 

removed, even though U.S. agencies continue to work on those issues in 

collaboration with the Saudi government. 

U.S. Government 

Strategy Is to Create 

an Active 

Antiterrorism 

Coalition with Saudi 

Arabia, but Some 

Targets to Measure 

Progress toward This 

Goal Have Been 

Removed 

U.S. Government Strategy 

Is to Create an Active 

Antiterrorism Coalition 

with Saudi Arabia 

Following the September 11, 2001, terrorist attacks, the U.S. mission in 

Saudi Arabia reported expanding its ongoing efforts to collaborate with 

the government of Saudi Arabia to combat terrorism. State’s MSPs, 

previously called Mission Performance Plans, for fiscal years 2006 to 2009 

contain goals related to expanding the Saudi government’s ability to 

counter terrorism and preventing financial support to extremists. 

 

16U.S. Department of State, U.S. Strategy Toward Saudi Arabia, Report Pursuant to 

Section 2043(c) of the Implementing Recommendations of the 9/11 Commission Act, 

P.L. 110-53, January 30, 2008, p. 1. 

Page 11 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

According to State documents, the MSP is developed each year by the 

overseas missions to facilitate long-term diplomatic and assistance 

planning and provide a strategic plan to set country-level U.S. foreign 

policy goals, resource requests, and performance targets. State reports 

that its Washington-based bureaus draw on MSPs to gauge the 

effectiveness of policies and programs in the field and formulate requests 

for resources. 

In January 2008, State submitted to the Congress a report on U.S. strategy 

for collaborating with Saudi Arabia on countering terrorism and terrorism 

financing in response to the Implementing Recommendations of the 9/11 

Commission Act of 2007.17 According to this document, the goal of 

strengthening the U.S. government’s counterterrorism partnership with 

Saudi Arabia is to be achieved through bilateral cooperation to enhance 

the Saudi government’s ability to combat terrorists and to prevent 

financial support to extremists.18 The goals and objectives contained in the 

January 2008 document coincide with the plans for collaboration with 

Saudi Arabia contained in MSPs for Saudi Arabia. According to State 

officials, DOD and the Office of the Director of National Intelligence19

approved the 2008 document. Moreover, officials from various agencies 

we met with—including Treasury, DOJ, and DHS—noted they are active 

participants in interagency strategic discussions on collaboration with 

Saudi Arabia regarding countering terrorism and terrorism financing. 

According to Saudi officials, the Saudi government agrees with U.S. goals 

to counter terrorism and terrorism financing in Saudi Arabia. Additionally, 

Saudi officials told us that generally there has been strong collaboration 

between U.S. and Saudi agencies, highlighting areas such as information 

sharing and training of security forces. However, Saudi officials noted 

some concerns related to U.S. implementation of certain efforts to counter 

terrorism financing. For example, Saudi officials expressed concern about 

some designations of individuals and organizations as supporters of 

 

17Pub. L. No. 110–53, Sec. 2043(c). 

18In this report we did not review the other aspects of the strategy, such as broader 

political, social, and economic reforms in Saudi Arabia and U.S. efforts related to the visa 

lookout system. For more information on the processing of visas in Saudi Arabia, see GAO, 

Border Security: Strengthened Visa Process Would Benefit from Improvements in 

Staffing and Information Sharing, GAO-05-859 (Washington, D.C.: Sept. 13, 2005). 

19The Director of National Intelligence serves as the head of the intelligence community 

and acts as the principal advisor to the President, the National Security Council, and the 

Homeland Security Council for intelligence matters related to national security. 

Page 12 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

terrorism, specifically suggesting that these designations may violate the 

right to a fair legal process. Additionally, Saudi officials noted concerns 

regarding past public statements by senior Treasury officials, such as 

those in April 2008, that individuals based in Saudi Arabia are a top source 

of funding for Al Qaeda and other terrorist organizations. However, 

according to Saudi officials, since Treasury placed a deputy attaché in 

Riyadh, Saudi Arabia, in December 2008, there has been a significant 

increase in information sharing and decrease in issues of concern. 

In addition, the Saudi government has developed its own strategy to 

combat terrorism, which Saudi officials characterized as focusing on three 

areas or pillars: “men, money, and mindset.” The “men” pillar of the 

strategy focuses on arresting or killing terrorists. The “money” pillar of the 

strategy focuses on measures to counter terrorism financing, such as 

tightening controls on financial transactions and cash couriers, as well as 

imposing restrictions on Saudi-based charities. Finally, the “mindset” pillar 

of the strategy focuses on preventing extremism by addressing the 

ideology that is used to recruit and indoctrinate potential terrorists. Saudi 

officials stated that the “mindset” pillar is the most challenging aspect of 

its counterterrorism strategy and will be a long-term challenge. 

Nonetheless, Saudi officials told us the Saudi government is committed to 

combating extremist ideology through programs such as public 

information campaigns and terrorist rehabilitation programs. 

The U.S. Mission Has 

Established Targets to 

Measure the Effectiveness 

of Efforts to Combat 

Terrorism and Its 

Financing; Some 

Performance Targets 

Related to Terrorism 

Financing Were Removed 

from the MSP 

The MSP for Saudi Arabia contains goals, performance indicators, and 

performance targets for counterterrorism efforts in Saudi Arabia. While 

the MSP is a State document, officials from DOD, DHS, DOJ, and Treasury 

told us they were aware of relevant portions of the document. According 

to the fiscal year 2009 MSP for Saudi Arabia, the highest priority U.S. goal 

is to strengthen its antiterrorist coalition with Saudi Arabia. Performance 

of this goal is measured by the indicator “Saudi effectiveness on measures 

to combat terrorism and terrorism financing activities.” To build an active 

antiterrorist coalition with the government of Saudi Arabia, the U.S. 

Mission to Saudi Arabia focuses on objectives related to (a) enhancing the 

Saudi government’s ability to combat terrorists, and (b) preventing 

financial support to extremists. To measure progress toward the goal of 

building an active antiterrorist coalition, the MSP contains a number of 

performance targets each fiscal year. (See figure 3 for MSP objectives and 

targets for fiscal years 2006 to 2009.) 

Page 13 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

Figure 3: Objectives and Performance Targets of Mission Strategic Plan for Saudi Arabia, Fiscal Years 2006-2009 

Source: GAO summary of U.S. agency information.

FY 2006 Target FY 2007 Target FY 2008 Target FY 2009 Target

• Provide security-related 

training to Saudi 

government

• Saudi authorities arrest 

“most wanted” terrorist 

suspects

• Strategic Dialogue working 

group improves

cooperation

• Provide security-related 

training to Saudi government

• Saudi authorities continue 

publishing “most wanted” list

• U.S.-Saudi cooperation on 

critical infrastructure 

protection

• No successful terrorist 

strikes in Saudi Arabia

• U.S.-Saudi cooperation 

on critical infrastructure 

protection

• Saudi opinion leaders

condemn terrorism

• No successful terrorist strikes

in Saudi Arabia

• Increased sharing of 

nonintelligence law 

enforcement data and other 

information

• Trials of at least 250 terrorism 

suspects to begin and 50 to 

conclude

• U.S. training for critical 

infrastructure security 

• Saudi and Yemeni government 

cooperation to capture and 

repatriate extremists

• Saudi financial intelligence 

unit (FIU) exchanges

information with regional 

counterparts

• The Saudi government 

cosponsors the designation 

of at least one individual or 

organization under United 

Nations Security Council 

Resolution 1267 related to 

Al Qaeda and the Taliban 

(UN 1267), details seized 

assets, and prosecutes the 

group or individual

• Saudi Charities Commission begins operations

• Cash courier regulations

implemented

• United States provides

training to Saudi FIU

• Saudi government 

implements actions under 

UN 1267, such as providing 

detailed accounting of 

assets seized from 

designees, and takes legal 

action against individuals or 

groups that support 

terrorism

• Saudi Charities Commission 

begins operations

• Cash courier regulations

implemented and enforced

• Additional U.S. training 

to Saudi FIU

• Saudi government 

implements actions

under UN 1267, such 

as providing 

accounting of assets

seized from 

designees, and takes

legal action against 

individuals or groups

that support terrorism

• Saudi Charities

Commission begins

operations

• Saudi FIU joins the Egmont 

Group (the international body 

of financial intelligence units), 

shares data with law 

enforcement, and receives

reports from customs

• Saudi government implements

actions against UN 1267 

designees, such as providing 

an accounting of frozen assets

and obstructing the travel of 

designees, and takes legal 

actions against Saudi entities

supporting terrorism

Build an active 

antiterrorist coalition

Goal Objectives

Objective: Prevent financial support to extremists

Objective: Enhance the Saudi government’s ability to combat terrorists

On an annual basis, the U.S. Mission in Saudi Arabia releases an updated 

MSP, which may contain revised performance targets related to building 

an active antiterrorist coalition with Saudi Arabia. State officials told us 

that MSP performance targets are periodically revised to ensure each 

fiscal year’s targets are most relevant to assessing progress toward U.S.-

Saudi efforts to counter terrorism and terrorism financing. Specifically, 

between fiscal years 2006 and 2009, certain performance targets were 

added, removed, or updated to reflect the change in conditions in Saudi 

Page 14 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

Arabia. For instance, new performance targets were added for fiscal year 

2009 that did not exist in previous years, including enhancing SaudiYemeni cooperation and conducting trials for terror suspects. In addition, 

the fiscal year 2008 target related to the public condemnation of terrorism 

by the Saudi government and religious leaders was omitted in fiscal year 

2009 because, according to State officials, it had been met. 

However, some targets related to preventing financial support to 

extremists were removed from the MSP, even though U.S. agencies 

reported that efforts to address these issues are important and ongoing. 

Specifically, a performance target related to the establishment of a Saudi 

Charities Commission existed in the MSP from fiscal years 2006 to 2008, 

but was removed for fiscal year 2009. According to State officials, the 

performance target related to the Charities Commission was dropped 

because State determined that other strategies to regulate charitable 

organizations in Saudi Arabia might be more effective than a commission. 

Likewise, a target related to implementation of cash courier regulations 

was part of the MSP in fiscal years 2006 and 2007, but was removed in 

fiscal years 2008 and 2009. According to State, the performance target 

related to cash courier regulations was dropped because the Saudi 

government had made progress instituting and enforcing these regulations. 

However, according to officials from DHS—which takes the lead on issues 

such as cash couriers—they were not consulted on the decision to remove 

the target related to cash couriers and stated that this target should be 

reinstated in the MSP. As a result, the MSP lacks targets against which U.S. 

agencies can monitor and assess performance in certain areas of U.S. 

concern related to countering terrorism financing. According to State and 

Treasury officials, even though targets related to these activities were 

removed from MSPs, enforcement of regulations to prevent terrorism 

financing are still important U.S. goals, which U.S. agencies pursue 

through diplomatic or training activities. 

Page 15 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

U.S. agencies and Saudi officials report progress countering terrorism and 

terrorism financing within Saudi Arabia, but noted challenges, particularly 

those related to preventing the flow of alleged financial support to 

extremists outside Saudi Arabia. In April 2009, the U.S. embassy assessed 

progress towards its goal of building an active antiterrorist coalition with 

Saudi Arabia as “on target.”20 With regard to counterterrorism efforts, U.S. 

and Saudi officials report progress enhancing the Saudi government’s 

ability to combat terrorists, and assess that these efforts have disrupted Al 

Qaeda’s terrorist network within Saudi Arabia. While citing progress, U.S. 

and Saudi officials noted Saudi Arabia’s neighbor, Yemen, is emerging as a 

base from which Al Qaeda terrorists can launch attacks against U.S. and 

Saudi interests. With regard to preventing financial support to extremists, 

U.S. and Saudi officials also report progress, citing, among other 

examples, the Saudi government’s implementation of cash courier 

regulations, ban on the transfer of charitable funds outside the Kingdom 

without government approval, and arrest and prosecution of individuals 

providing ideological or financial support to terrorism. Despite these 

gains, U.S. officials remain concerned about the ability of Saudi individuals 

and multilateral charitable organizations, as well as other individuals 

visiting Saudi Arabia, to support21 terrorism and violent extremism outside 

Saudi Arabia. Moreover, both Saudi and U.S. officials cited limited Saudi 

enforcement capacity and terrorist financiers’ use of cash couriers as 

challenges to Saudi efforts to prevent financial support to extremists. 

U.S. Agencies and 

Saudi Officials Report 

Progress in 

Combating Terrorism 

and Its Financing in 

Saudi Arabia, but 

Challenges Persist, 

Particularly in 

Preventing Alleged 

Funding for Terrorism 

and Violent 

Extremism outside of 

Saudi Arabia 

U.S. and Saudi Officials 

Report Progress 

Combating Terrorists in 

Saudi Arabia 

U.S. and Saudi officials report progress enhancing the Saudi government’s 

ability to combat terrorists and assess that Saudi efforts have disrupted Al 

Qaeda’s terrorist network within Saudi Arabia. The U.S. embassy’s MSP 

for fiscal year 2008 lists three performance targets related to enhancing 

the Saudi government’s ability to combat terrorists. These targets 

specifically pertain to (1) prevention of successful terrorist strikes in Saudi 

Arabia, (2) improved U.S.-Saudi cooperation on critical infrastructure 

protection, and (3) public condemnation of terrorist activities by Saudi 

 

20U.S. officials provided us their assessment of progress related to performance targets 

from fiscal years 2006 to 2008. Since activities for fiscal year 2009 were still being 

implemented at the time of this review, U.S. officials provided us an assessment of progress 

through August 2009. 

21For the purposes of this report, we define “support” as financial assistance or 

nonfinancial assistance, which may include individuals, such as those who go abroad as 

foreign fighters, and materials, such as weapons. For a detailed description of “support” 

see 18 U.S.C. 2339A(b). 

Page 16 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

government and religious leaders. U.S. officials report progress on these 

performance targets in fiscal year 2008, as well as the completion of 

related targets in fiscal years 2006 and 2007. While citing progress, U.S. 

and Saudi officials noted Saudi Arabia’s neighbor, Yemen, is emerging as a 

base from which Al Qaeda terrorists can launch attacks, which could 

challenge gains made in combating terrorists in Saudi Arabia. (See figure 4 

for a summary of reported progress related to MSP performance targets.) 

Figure 4: U.S. Agencies’ Assessment of Progress as of August 2009 on Mission Strategic Plan Performance Targets Related 

to Combating Terrorists, Fiscal Years 2006-2008

FY 2006 Target FY 2007 Target FY 2008 Target Status of Activities

Related to Targets

U.S. Agencies’ Assessment

of Overall Progress

Saudi authorities arrest “most 

wanted” terrorist suspects

Strategic Dialogue working group 

improves cooperation

Saudi authorities

continue publishing 

“most wanted” list

• No successful terrorist strikes in Saudi Arabia

reported since 2007

• Saudi government participates in U.S. training 

on case management and infrastructure 

protection

• Saudi government publishes three most 

wanted lists

• In May 2008, U.S. and Saudi governments

sign a cooperation agreement on critical 

infrastructure protection

• U.S. and Saudi governments establish a joint 

organization to implement the cooperative 

agreement

• In fiscal year 2006, Strategic Dialogue 

working group meets

• Saudi leaders, including the King, senior 

government officials, and religious leaders, 

publicly condemn terrorism

• Saudi government adopts a number of 

domestic programs designed to combat 

extremism in Saudi Arabia

U.S. officials report 

progress enhancing the 

Saudi government’s

ability to combat 

terrorists, and assess

these efforts have 

disrupted Al Qaeda’s

terrorist network within 

Saudi Arabia.

Concern remains that 

Saudi Arabia’s neighbor 

Yemen is emerging as a

base from which Al 

Qaeda terrorists can 

launch attacks against 

U.S. and Saudi interests.

Provide security-related 

training to Saudi 

government

Saudi opinion leaders

condemn terrorism

No successful terrorist 

strikes in Saudi Arabia

U.S.-Saudi cooperation 

on critical infrastructure 

protection

U.S.-Saudi 

cooperation on critical 

infrastructure 

protection

Provide security-related 

training to Saudi government

Source: GAO analysis of U.S. agency information.

Officials from State report that there have been no successful terrorist 

strikes in Saudi Arabia since February 2007. Officials attributed this 

outcome, in part, to Saudi law enforcement actions. Experts we 

interviewed also cited decreased popular support for Al Qaeda, due to 

Muslim casualties caused by the organization, as a factor in the declining 

number of attacks. Both U.S. and Saudi officials cited strong intelligence 

and security cooperation between the U.S. and Saudi governments related 

No Successful Terrorist Strikes 

Reported in Saudi Arabia Since 

2007 

Page 17 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

to counterterrorism. Moreover, experts with whom we spoke generally 

agreed that the Saudi government is serious about combating terrorism. 

State officials report that, while there was a major terrorist incident in 

Saudi Arabia in August 2009, there have been no attacks on energy 

infrastructure since 2006 and no successful terrorist strikes in Saudi 

Arabia since February 2007. On August 27, 2009, a suicide bomber 

attempted to assassinate Saudi Arabia’s Assistant Minister of Interior for 

Security Affairs, Prince Mohammed bin Nayef, who is also the head of 

Saudi Arabia’s counterterrorism efforts. While the bomber, a Saudi 

national who was on the Saudi government’s “most wanted” list, was killed 

during the attack, no one else suffered serious injuries. According to the 

Saudi embassy, the attacker was from a region bordering Yemen and had 

offered to coordinate the return of Saudi fugitives in Yemen. Al Qaeda in 

the Arabian Peninsula claimed responsibility for the attack. Officials from 

State and the Saudi embassy told us that, while a major attack, the strike 

was not successful, as the Prince was not seriously harmed.22 Similarly, a 

White House press release described the attack as unsuccessful. DOD 

noted, however, that Saudi authorities did not disrupt this plot. The White 

House press release also stated that the attack underscores the continued 

threat posed by Al Qaeda and the importance of strong counterterrorism 

cooperation between the United States and Saudi Arabia. 

Saudi Arabia has also undertaken law enforcement activities, including 

arresting and prosecuting terror suspects. According to State reporting, 

since May 2003, the Saudi government has killed or captured Al Qaeda’s 

operational Saudi-based senior leadership, as well as most of the 

network’s key operatives and many of the Kingdom’s most wanted 

individuals. Between 2003 and 2008, U.S. and Saudi officials report the 

Saudi government arrested or killed thousands of terrorism suspects, 

including those suspected of planning attacks on Saudi oil fields and other 

vital installations. Further, the Saudi government has published three 

“most wanted” lists, and U.S. and Saudi sources report Saudi Arabia has 

captured or killed a number of suspects on these lists. In 2008, the Saudi 

government announced terrorism trials for approximately 1,000 

individuals indicted on various terrorism-related charges. In July 2009, the 

Saudi government announced that 330 suspects had court trials, of whom 

 

22State told us that that the success of an attack is measured by whether or not it meets its 

objective. In this case, the Prince was not killed, which presumably was the objective of the 

attack. 

Page 18 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

seven were acquitted and the rest received jail terms ranging from a few 

months to 30 years.23 Saudi officials noted that the convictions can be 

appealed in the Saudi supreme court. U.S. and Saudi officials told us, and 

State reports, that such trials could help combat terrorist ideologies. 

Moreover, the U.S. and Saudi governments have implemented joint 

activities to strengthen Saudi law enforcement capabilities, such as Stateled training to strengthen the Saudi government’s antiterrorism 

investigative management and VIP protection capability. Apart from joint 

training courses, U.S. officials told us they have close working-level 

relationships with their Saudi counterparts and noted that Saudi security 

cooperation is significant.24 State, Treasury, FBI, DOD, and DHS officials 

told us that U.S. law enforcement and intelligence agencies have benefited 

and continue to benefit from Saudi information on individuals and 

organizations. The former U.S. ambassador to Saudi Arabia described U.S.-

Saudi counterterrorism cooperation as among the most productive in the 

world. 

U.S. and Saudi officials report progress in cooperation on protecting 

critical infrastructure targets, such as oil installations, in Saudi Arabia. 

Officials cited the signing of a technical cooperation agreement between 

the United States and Saudi Arabia in May 2008, as well as activities to 

implement the agreement, as evidence of deeper cooperation. 

U.S. and Saudi Governments 

Report Extensive Cooperation 

on Critical Infrastructure 

Protection 

U.S. officials told us that the protection of critical Saudi infrastructure, 

particularly energy production facilities, has been a priority since 2006, 

following an unsuccessful terrorist attack at the Abqaiq oil facility,25 one of 

 

23According to a Saudi government press release, the 330 suspects tried in courts included 

41 non-Saudis. Of the 323 people who were convicted, 13 were sentenced to prison terms of 

over 20 years. 

24In November 2005, the U.S. and Saudi governments instituted the Strategic Dialogues, 

including a working group on counterterrorism. According to State, the Strategic Dialogues 

constitute a high-level and institutionalized forum for coordination of U.S.-Saudi interests. 

State officials told us that the Strategic Dialogues have not met since 2006. In place of these 

meetings, U.S. and Saudi officials told us several high-level U.S. officials visited Saudi 

Arabia, such as the Assistant to the President for Homeland Security and Counterterrorism 

and the Under Secretary for Terrorism and Financial Intelligence. Moreover, U.S. officials 

told us that, even though meetings of the Strategic Dialogues have not occurred, 

cooperation and coordination between the U.S. and Saudi governments has expanded 

significantly since 2006, especially in the area of counterterrorism. 

25State documents describe the Abqaiq oil facility as the most important oil processing 

facility in Saudi Arabia. 

Page 19 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

the world’s largest oil processing facilities located in Saudi Arabia. 

According to State reporting, critical infrastructure protection is a vital 

national interest, as a successful terrorist attack that disrupts Saudi oil 

production would have a devastating impact on the U.S. and global 

economies.26

In May 2008, the U.S. Secretary of State and the Saudi Arabian Minister of 

Interior signed a technical cooperation agreement to provide U.S. 

technical assistance to Saudi Arabia in the area of critical infrastructure 

protection. A joint operational entity called the Office of Program 

Management-Ministry of Interior (OPM-MOI) was established to 

implement the agreement, consisting of representatives from State, DOD, 

DOE, and the Saudi Arabian government. The Saudi Arabian government 

agreed to fully fund the agreement’s implementation, including all 

expenses incurred by U.S. agencies for services and contractor costs. 

OPM-MOI is assisting the Saudi government in identifying critical 

infrastructure vulnerabilities; developing security strategies to protect 

critical infrastructure; and recruiting and training a new MOI force, the 

Facilities Security Force, to protect its critical infrastructure. State is the 

lead agency for the implementation of the agreement, DOE is contributing 

expertise in conducting facility assessments and developing security 

strategies for Saudi energy production facilities, and DOD will contribute 

expertise in training and equipping the Facilities Security Force, which is 

intended to have more than 35,000 personnel when fully developed. 

According to U.S. officials, the current focus of OPM-MOI is protecting 

critical infrastructure related to oil production. However, officials told us 

OPM-MOI could expand to cooperate with the Saudi government in a 

number of other areas, including border security, maritime security, and 

cyber security. Other U.S. agencies, such as DHS and the Coast Guard, are 

expected to participate in OPM-MOI as the critical infrastructure mission 

expands. 

Saudi government and religious leaders have publicly condemned 

terrorism and terrorism financing. Several high-ranking Saudi government 

leaders have spoken out against terrorism and extremism. In his remarks 

at the UN’s Culture of Peace conference in November 2008,27 King 

Saudi Leaders Have Publicly 

Condemned Terrorist Activities 

and Implemented Programs to 

Combat Extremism 

 

26According to the DOE, in 2008 Saudi Arabia produced about 9.3 million barrels of oil per 

day, making it the world’s second largest oil producer. 

27The 2-day Culture of Peace conference was sponsored by Saudi Arabia and held at the UN 

headquarters in New York City. 

Page 20 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

Abdullah bin Abdulaziz noted that “terrorism and criminality are the 

enemies of every religion and every culture.” In July 2008, the King made 

similar remarks at the World Conference on Dialogue in Madrid. Many 

other members of the Saudi government, including the Ministers of Islamic 

Affairs, Foreign Affairs, and Interior, have issued statements against 

terrorism and extremism since 2001. 

Moreover, religious leaders, such as the Grand Mufti of Saudi Arabia,28

have issued a number of statements critical of terrorism. In the spring of 

2008, the Grand Mufti issued a statement on the evils of terrorism and 

warned Saudi citizens not to listen to those who use religion to promote 

terrorism. In October 2007, he delivered a sermon cautioning young Saudis 

not to travel abroad to participate in jihad. In the same speech, he urged 

Saudi citizens not to finance terrorism and to be mindful of how their 

charitable contributions are distributed. Later that same year, the Grand 

Mufti stated that terrorists should be subject to severe punishment in 

accordance with Islamic law. According to State, other Saudi Islamic 

scholars and officials also voiced support for the Grand Mufti’s statement. 

Further, in May 2009, the Second Deputy Prime Minister of Saudi Arabia 

organized the first national conference on “intellectual security,” which 

was to address the “intellectual abnormality” that, according to the Saudi 

government, is “the main reason for terrorism.” The conference resulted in 

a communiqué stressing the importance of moderation, tolerance, crosscultural dialogue, nonviolence, and the establishment of national 

strategies for promoting those values. The declaration pointed out the 

moderate nature of Islam and warned against the dangers of embracing 

deviant ideologies. The Deputy Prime Minister also expressed hope that 

the small number of Saudis participating in deviant groups abroad would 

renounce their beliefs and return home, noting, Saudi Arabia “is ready to 

welcome its citizens if they decide to opt for the correct path.” 

In addition to public statements by Saudi government and religious 

figures, the Saudi government has implemented a number of domestic 

activities designed to undermine extremist ideology within the Kingdom. 

These activities include the following: 

Saudi Activities to Combat 

Extremism 

 

28State has reported that while the Grand Mufti is not part of the Saudi government, he is 

the most senior religious scholar in Saudi Arabia and is influential in shaping Saudi public 

opinion. 

Page 21 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

• Initiating a media campaign: According to U.S. and Saudi officials, the 

Saudi government has implemented an extensive media campaign against 

extremist thought. State reports this campaign includes the use of 

advertisements, billboards, text messages and the Internet. (Figure 5 

shows examples of Saudi Arabia’s public outreach campaign.) 

Page 22 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

Figure 5: Saudi Arabia’s National Campaign against Extremism and Terrorism, 

Examples of Public Outreach 

See http://www.gao.gov/media/video/gao-09-883/ for a video of a Saudi 

government-sponsored TV advertisement designed to counter terrorism. 

Source: Royal Embassy of Saudi Arabia.

Page 23 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

• Distributing publications and other materials: Officials from the 

Saudi Ministries of Islamic Affairs and Interior told us Saudi Arabia had 

produced a variety of books and pamphlets designed to combat extremist 

ideology. Saudi officials estimate that approximately 1.8 million books 

have been prepared as part of this effort. (Figure 6 shows a sample of 

Saudi literature to combat extremism provided to GAO by Saudi 

officials.)29 Additionally, according to Saudi officials, the Saudi 

government distributes, via mosques and schools, CDs and cassette tapes 

with lectures and seminars addressing the issues of terrorism and

extremism. 

 

29Although we were provided literature produced by the Saudi government to combat 

extremism, we did not verify the extent of its use and distribution within the Kingdom. 

Page 24 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

Figure 6: Sample of Saudi Literature (with Translated Titles) Designed to Combat Extremist Ideology

Source: Materials provided by the government of Saudi Arabia; translations by GAO.

Seditious (rebellion 

against authority) 

Bombings and 

Assassinations: 

Causes, Impacts, and 

Remedy

Reflections on the 

Riyadh Bombings

The Guidance of 

Quran and Sunnaa

on Maintaining

Security and 

Protecting Lives: The 

Prohibition Against 

Hijacking Airplanes

The Position of Senior 

Ulema (religious

scholars) on Extremism 

and Terrorism

a

The Quran and Sunna (which refers to the customs of Prophet Muhammad) form the basis of Islamic 

jurisprudence. 

Page 25 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

• Monitoring religious leaders: According to State reporting and Saudi 

officials, the Saudi government continues to monitor the preaching and 

writings of religious leaders, and to reeducate those who advocate 

extremist messages. Saudi officials from the Ministry of Islamic Affairs 

told us their monitoring has covered approximately 20,000 of Saudi 

Arabia’s estimated 70,000 mosques, including all of the large mosques that 

hold Friday prayers.30Additionally, Saudi officials told us they have held 

hundreds of seminars and lectures in mosques to help ensure that religious 

leaders preach a moderate message to the public. 

• Monitoring school teachers: According to officials from the Saudi 

Ministry of Islamic Affairs, the Saudi government monitors for school 

teachers who teach extremism. Once identified, such teachers are put 

through reeducation programs. 

• Monitoring Internet sites: According to Ministry of Interior officials, 

Saudi authorities are monitoring Internet chat rooms that could be sources 

of militant recruitment. In September 2008, Saudi authorities reported the 

arrest of three Saudi citizens and two expatriates for promoting militant 

activities on Internet forums, engaging online users in dialogue, spreading 

misleading information, and recruiting youth to travel abroad for 

inappropriate purposes. According to Saudi reports, the Ministry of 

Interior called on all Saudis to be vigilant and urged them not to listen to 

those who promote corruption and sedition. In addition, the Ministry 

published the online usernames utilized by the suspects. 

• Encouraging dialogue: The Saudi government reports that it supports 

the activities of the Sakinah (or Tranquility) Campaign, which is an 

independent nongovernmental organization that engages in dialogue, via 

the Internet, with Internet users who have visited extremist Web sites. 

Additionally, in 2008, the King of Saudi Arabia also initiated a series of 

conferences to promote interfaith dialogues. The first conference was 

hosted by the Muslim World League in Mecca in June 2008 and consisted 

of 500 Muslim scholars from around the world. The second conference 

was held in Madrid, Spain, in July 2008 and included 300 delegates 

representing different faiths, including Islam, Buddhism, Christianity, 

Hinduism, and Judaism. Finally, the King of Saudi Arabia was joined by 

other heads of states at a Special Session of the UN General Assembly on 

interfaith dialogue in November 2008. 

 

30Saudi officials estimated the number of large mosques holding Friday prayers to be 

14,000. 

Page 26 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

The Saudi government operates rehabilitation programs to reeducate 

those arrested for supporting terrorism or extremism, as well as those 

returning from the U.S. detention facilities at Guantanamo Bay, to 

reintegrate them into society. Rehabilitation programs take place both in 

Saudi prisons and in halfway houses outside of prisons, known as 

aftercare centers.31 In March 2009, we visited the aftercare center—called 

the Mohammed bin Nayef Center for Advisory and Care—in Riyadh and 

spoke with staff members as well as participants of the program, including 

those arrested for terrorism and violent extremism in Saudi Arabia and 

those formerly detained at Guantanamo Bay. Staff members told us the 

rehabilitation center seeks to “reeducate” its participants by engaging 

them in religious debates and providing psychological counseling. The 

program generally consists of one-on-one and group sessions between an 

offender and religious scholars, psychiatrists, and psychologists about 

their beliefs. Program officials attempt to persuade the offenders that their 

religious justification for their actions is based upon a corrupted 

understanding of Islam. Psychological counseling includes traditional 

methods as well as activities such as art therapy. Staff members told us the 

program draws heavily on participants’ family and tribal relations. Family 

members can visit and telephone the rehabilitation center, and 

rehabilitation participants are allowed leave to attend family events such 

as weddings and funerals. For instance, when we visited the center, we 

spoke with family members visiting their relatives. Those who complete 

the program, and are deemed eligible for release, are provided social 

support to assist with their reintegration into society, such as counseling, 

job opportunities, and stipends. Moreover, these social services are 

extended to the family and tribal members of released participants, as a 

way to involve participants’ larger social network in their rehabilitation. 

Saudi officials told us that individuals generally participate in the program 

for 6 to 8 months. 

Saudi Rehabilitation Programs 

Saudi officials report such rehabilitation programs, including those in 

prisons and an aftercare center, have treated 4,300 individuals overall. 

Specifically, Saudi officials told us that, as of March 2009, the aftercare 

center had served approximately 250 individuals, with a recidivism rate of 

about 20 percent. Experts with whom we spoke generally praised the 

Saudi rehabilitation program, but offered some caution on the 

 

31The rehabilitation programs in Saudi prisons started in 2004, while the first aftercare 

center started in 2007. Other aftercare centers are under construction. 

Page 27 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

methodology used to measure its results.32 State reports it is monitoring 

these rates closely. Saudi officials told us that former Guantanamo 

detainees account for most of the individuals who have recidivated from 

the aftercare center.33 For example, in January 2009, two former 

participants at the center appeared in an Al Qaeda recruiting video filmed 

in Yemen. One of the individuals in the video has since turned himself in to 

Saudi authorities. Saudi officials acknowledge such cases illustrate the 

difficulties associated with assessing which participants should be 

released from the rehabilitation center, but told us they are working to 

refine their assessment criteria. U.S. and Saudi officials with whom we 

spoke told us that, despite the challenges associated with recidivism, 

Saudi rehabilitation programs have demonstrated some positive results. 

Moreover, U.S. officials told us these activities, among others, demonstrate 

the Saudi government’s commitment to undermining extremist ideology 

within the Kingdom. (See http://www.gao.gov/media/video/gao-09-883/ for 

a video of GAO’s visit to a Saudi government operated rehabilitation 

center.) 

While U.S. and Saudi officials told us that Saudi Arabia had made progress 

in enhancing its ability to combat terrorists, they assessed that political 

instability in Yemen,34 Saudi Arabia’s neighbor, could create challenges to 

counterterrorism efforts. U.S. and Saudi officials expressed concern that 

Yemen, due in part to lack of government control and proximity to Saudi 

Arabia, is emerging as a base from which Al Qaeda terrorists can launch 

attacks against Saudi and U.S. interests in Saudi Arabia. For example, as 

noted previously, in August 2009, Al Qaeda in the Arabian Peninsula—

which is based in Yemen—claimed responsibility for the failed 

assassination attempt against Saudi Arabia’s Assistant Minister of Interior 

for Security Affairs. State has listed Yemen as a terrorist safe haven in its 

Country Reports on Terrorism since 2005. In April 2009, in its Country 

Reports on Terrorism, State reported that, despite some successes against 

Despite Significant Gains in 

Combating Terrorists in Saudi 

Arabia, Instability in Yemen Is a 

Concern 

 

32These experts stated that while initial results after the first 2 years look promising, 

recidivism rates for criminology programs are generally measured for a 5-year period to 

accurately assess the success of a program. 

33The rehabilitation programs have yet to receive the final Saudi detainees from 

Guantanamo. According to Saudi officials, as of July 2009, 11 Saudi men remain in 

Guantanamo. Saudi officials told us these men have been in Guantanamo for nearly 8 years 

and represent the most difficult cases for rehabilitation. 

34Over the past few years, in addition to increased terror attacks by Al Qaeda, the 

government of Yemen has faced a growing insurgency in the north and civil unrest in the 

south. 

Page 28 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

Al Qaeda, the response of the government of Yemen to the terrorist threat 

was intermittent due to its focus on internal security concerns. Moreover, 

State noted that border security between Saudi Arabia and Yemen 

remained a problem. Saudi officials also cited political instability in 

Yemen, as well as the porous border between Yemen and Saudi Arabia, as 

challenges to their counterterrorism efforts. To address this issue, the 

Deputy Foreign Minister of Saudi Arabia told us that the Saudi government 

is providing Yemen assistance in a number of areas, including 

counterterrorism, education, and health. Saudi officials also stated that 

Saudi Arabia is building an electronic fence on the Saudi-Yemen border.35

U.S. and Saudi Officials 

Report Progress in 

Preventing Financial 

Support to Extremists, but 

Concerns Remain about 

Individuals’ and 

Multilateral Charitable 

Organizations’ Ability to 

Support Terrorism and 

Violent Extremism outside 

of Saudi Arabia 

U.S. and Saudi officials report progress in preventing financial support to 

extremists, citing improved Saudi regulation and enforcement capacity. 

Between fiscal years 2006 and 2008, the U.S. embassy’s MSP listed a 

number of performance targets related to preventing financial support to 

extremists, which include (1) the United States providing additional 

training and Saudi banks increasing reporting to the Saudi Financial 

Investigation Unit, (2) the Saudi government providing accounting of 

assets seized from individuals and organizations designated as terrorists 

by the United Nations (UN) 1267 Committee and taking legal action 

against nationals and groups providing financial or ideological support to 

terrorists, (3) the Saudi Charities Commission naming senior staff and 

beginning operations, and (4) the Saudi government implementing and 

enforcing cash courier regulations. U.S. officials report progress on 

several of these performance targets. However, U.S. officials remain 

concerned about the ability of Saudi individuals and multilateral charitable 

organizations, as well as other individuals visiting Saudi Arabia, to support 

terrorism and violent extremism outside of Saudi Arabia. U.S. officials also 

noted that limited Saudi enforcement capacity and terrorist financiers’ use 

of cash couriers pose challenges to Saudi efforts to prevent financial 

support to extremists. (For a summary of reported progress related to 

MSP performance targets from fiscal year 2006 to fiscal year 2008, see 

figure 7.) 

 

35In addition, the embassy’s MSP contains a performance target for fiscal year 2009 related 

to Saudi-Yemeni cooperation on capturing and repatriating extremists. 

Page 29 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

Figure 7: U.S. Agencies’ Assessment of Progress as of August 2009 on Mission Strategic Plan Performance Targets Related 

to Preventing Financial Support to Extremists, Fiscal Years 2006-2008

FY 2006 Target FY 2007 Target FY 2008 Target Status of Activities

Related to Targets

U.S. Agencies’ Assessment

of Overall Progress

• Saudi Charities Commission is not 

operational

• In its place, the Saudi government has

adopted regulations barring charitable 

organizations from sending contributions

overseas absent the approval of the Saudi 

government

• State and Treasury have expressed concerns

that certain charitable organizations in Saudi 

Arabia are not covered by Saudi regulations. 

Saudi government officials contend all 

organizations are covered by their regulations

U.S. officials report 

progress in preventing 

financial support to 

extremists, but concerns

remain about the ability 

of Saudi individuals and 

multilateral charitable 

organizations to provide 

financial support for 

terrorism outside of 

Saudi Arabia.

Limited capacity, 

particularly in key Saudi 

ministries that enforce 

financial regulations, the 

use of cash couriers by 

terrorist financiers, 

circumvention of cash 

declaration laws, and 

pervasive use of cash in 

Saudi society are cited 

as challenges to 

combating the financing 

of terrorism.

Saudi Charities Commission 

begins operations

Saudi financial intelligence unit 

(FIU) exchanges information 

with regional counterparts

• U.S. Treasury and FBI provide training on 

financial investigative skills

• State reports increased reporting by banks

• Saudi FIU joins the international body of 

financial intelligence units

Additional U.S. training 

to Saudi FIU

United States provides

training to Saudi FIU

The Saudi government 

cosponsors the designation of 

at least one individual or 

organization under United 

Nations Security Council 

Resolution 1267 related to Al 

Qaeda and the Taliban (UN 

1267), details seized assets, 

and prosecutes the group or 

individual

• Saudi government arrests a number of 

terrorist financiers

• State reports Saudi government appears

cooperative on efforts to freeze assets of 

designated individuals and entities

• State officials note that the Saudi 

government’s enforcement of the UN 

1267 travel ban provision has not been 

consistent

Saudi government 

implements actions

under UN 1267, such 

as providing 

accounting of assets

seized from 

designees, and takes

legal action against 

individuals or groups

that support terrorism

Saudi government 

implements actions

under UN 1267, such 

as providing detailed 

accounting of assets

seized from designees, 

and takes legal action 

against individuals or 

groups that support 

terrorism

Saudi Charities

Commission begins

operations

Saudi Charities

Commission begins

operations

• Cash courier regulations enacted by the 

Saudi government

• State has reported that the effectiveness

of these regulations remains in question

• DHS noted that they do not have 

information—such as the number of 

seizures—to assess progress on 

implementation of cash courier 

regulations

Cash courier regulations

implemented

Cash courier 

regulations

implemented and 

enforced

Source: GAO analysis of U.S. agency information.

In 2005, the government of Saudi Arabia established the Saudi Financial 

Investigation Unit, which acts as Saudi Arabia’s financial intelligence unit 

(FIU). Located in the Ministry of Interior, the Saudi FIU receives and 

analyzes suspicious transaction reports and other information from a 

variety of sources, such as banking institutions, insurance companies, and 

government departments. 

The United States Provided 

Training to the Saudi Financial 

Investigation Unit 

Page 30 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

Treasury’s Financial Crimes Enforcement Network, which is the FIU for 

the United States, and the FBI have provided training to the Saudi FIU 

since its establishment in 2005. According to Treasury officials, these 

training activities were designed to build the capacity of the Saudi FIU and 

assist it in meeting international standards, with the ultimate goal of 

having the Saudi FIU attain membership in the Egmont Group, an 

international body of financial intelligence units. Saudi officials told us 

that the capacity of the Saudi FIU has increased since 2005. For instance, 

they noted the number of suspicious transaction reports they analyze grew 

from approximately 38 per month in 2006 to 110 per month in 2008,36 while 

the staff of the FIU has grown from approximately 80 individuals in 2006 

to 130 individuals in March 2009. Moreover, since 2005, Saudi officials told 

us the Saudi FIU had conducted information exchanges with FIUs in the 

United States and a number of countries in the region, and said they 

expected these exchanges to increase once the Saudi FIU becomes a 

member of the Egmont Group.37 Similarly, Treasury officials told us Saudi 

Arabia’s membership in the Egmont Group would assist in preventing 

financial support to extremists by facilitating information exchanges 

between the Saudi FIU and its counterparts. In May 2009, the Saudi FIU 

met the requirements for membership and became an official member of 

the Egmont Group.38

According to U.S. officials and State reporting in 2007 and 2008, the Saudi 

government has taken legal action against terrorist financiers, based on its 

laws and regulations related to combating terrorist financing. In 2003, the 

Saudi Arabian government enacted an anti-money laundering law, which 

provided a statutory basis for considering money laundering and terrorism 

financing as criminal offenses. That same year, the Saudi Arabian 

Monetary Agency (SAMA) issued updated anti-money laundering and 

counterterrorist financing guidelines for the Saudi banking and nonbank 

The Saudi Government Has 

Initiated Legal Action against 

Terrorist Financiers, but the 

United States Has Reported the 

Need for Further Action 

 

36After it analyzes reports, the Saudi FIU refers money laundering cases to the Saudi 

Bureau of Investigation and Prosecution and terrorism financing cases to the Mabahith (or 

the General Investigation Directorate), as necessary. Saudi officials estimated that 

approximately 5 percent of the suspicious transaction reports they receive pertain to 

terrorism financing. 

37A core goal of the Egmont Group is to facilitate information sharing between member 

FIUs, and its members are given access to a secure private Web site on which to share 

information. 

38The United States was a sponsor of Saudi Arabia for Egmont membership. 

Page 31 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

financial system.39 The guidelines contain a number of provisions, such as 

requiring that banks (1) have mechanisms to monitor all types of 

“Specially Designated Nationals” as listed by SAMA, (2) strictly adhere to 

SAMA guidance on opening accounts and dealing with charity and 

donation collection, and (3) use software to monitor customers to detect 

unusual transaction patterns. Additionally, SAMA has also issued “know 

your customer” guidelines, requiring banks to freeze accounts of 

customers who do not provide updated account information. In July 2004, 

members of the Financial Action Task Force (FATF) and the Gulf 

Cooperation Council assessed Saudi Arabia’s legal and regulatory 

practices with respect to countering terrorism financing.40 They found 

Saudi Arabia to be compliant or largely compliant with most FATF 

benchmarks—a set of internationally recognized legal and regulatory 

benchmarks on money laundering and terrorism financing.41

Since 2007, U.S. and Saudi officials report that the government of Saudi 

Arabia has arrested and prosecuted a number of individuals suspected of 

financing terrorism. For instance, State reports that the Saudi government 

arrested 56 suspected terrorist financiers in 2008 and prosecuted 20 of 

them. According to Saudi embassy reports, over 40 people were arrested 

in 2007 for providing financial support to terrorists. As noted earlier in this 

report, in July 2009, the Saudi government announced the convictions of 

330 terrorism suspects who were charged with crime, including affiliation 

with terrorist organizations as well as facilitating and financing terrorism. 

U.S. officials we spoke with cited these arrests, as well as those against 

terrorist cells more generally, as having a disruptive effect on financing 

networks. Despite these gains, State notes in its most recent Country 

Report on Terrorism that the United States continues to “urge the 

 

39The Saudi guidelines were issued in accordance with the Financial Action Task Force’s 

(FATF) 40 Recommendations on Money Laundering and 9 Special Recommendations on 

Terrorist Financing. 

40Financial Action Task Force on Money Laundering, Annual Report 2003-2004, Annex C, 

“Kingdom of Saudi Arabia: Executive Summary - FATF Recommendations for Anti-Money 

Laundering and Combating the Financing of Terrorism.” 

41The assessment found that Saudi Arabia was not compliant with the FATF benchmarks in 

three areas, and noted (1) a clear definition of terrorism financing is required to ensure that 

it is an offense if the funds are intended for terrorist use, or derived from a legal source; (2) 

information requests must currently be routed via SAMA, which may cause delays; and (3) 

there is a need to strengthen customer identification measures for nonbank financial 

institutions. In 2009, members of the FATF and the Middle East North African FATF Style 

Regional Body conducted another assessment of Saudi Arabia’s financial system. U.S. 

officials told us the results of this assessment would not be available until 2010. 

Page 32 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

government of Saudi Arabia to pursue and prosecute terrorist financiers 

more vigorously.” 

Moreover, State’s 2009 International Narcotics Control Strategy Report 

(INCSR) cited the Saudi government as “partially compliant” on 

obligations related to UN Security Council resolutions on terrorism 

financing. UN 1267 requires its signatories to impose certain restrictions 

on individual or entities associated with Al Qaeda and the Taliban, such as 

freezing their assets and preventing their entry or transit through 

signatories’ territories (travel ban). In April 2009, State reported that the 

Saudi government had taken action against individuals designated by the 

UN 1267 Committee by freezing their accounts and seizing their assets. 

Moreover, State reports that SAMA provides the names of suspected 

terrorists and terrorist organizations designated by the UN 1267 

Committee to all financial institutions under its supervision. Related to the 

UN 1267 travel ban provision, State officials told us that the Saudi 

government’s enforcement of this provision had not been consistent, 

particularly during hajj.42 According to Saudi officials, the Saudi 

government’s policy is to allow all Muslims to visit the Kingdom during 

hajj to fulfill their religious obligations and to not arrest individuals during 

their pilgrimage. However, Saudi officials noted they would share 

information with the United States about certain individuals, such as those 

designated under UN 1267, visiting the Kingdom for religious obligation. 

State and Treasury have reported that some Saudi charitable organizations 

have been a major source of financing to extremist and terrorist groups. In 

2002, the Saudi government announced its intention to establish a National 

Commission for Relief and Charitable Work Abroad, commonly known as 

the Charities Commission, to oversee all private Saudi charitable activities 

abroad. U.S. officials told us, and Saudi officials confirmed, that the Saudi 

Charities Commission is not operational. Although the Charities 

Commission is not operational, the Saudi government has established 

regulations barring Saudi charitable organizations from sending 

contributions abroad via banks and other formal financial channels 

without first receiving the approval of the Saudi government. Saudi 

officials told us these regulations are preferable to a Charities 

Commission, as they more effectively prevent the flow of funds outside of 

Saudi Arabia. Similarly, some U.S. officials and experts with whom we 

The Saudi Charities 

Commission Is Not Yet 

Operational, but the Saudi 

Government Has Issued New 

Regulations Targeting Saudi 

Charities and Multilateral 

Charitable Organizations 

 

42In 2009, State updated its fiscal year 2009 MSP target related to UN 1267 to include 

specific language regarding Saudi enforcement of UN 1267 travel ban provisions. 

Page 33 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

spoke stated that the current ban might be preferable to a Saudi Charities 

Commission, as a ban may be more effective in preventing financial 

support from reaching extremist groups. Other U.S. officials noted that 

while more effective oversight of charitable organizations is needed, it is 

not necessary that such oversight take the form of a Charities 

Commission. 

Rules related to the banking activities of charitable organization in Saudi 

Arabia were first adopted in 2003, and updated in 2008. However, there is 

some disagreement over whether these rules apply to all Saudi charitable 

organizations. According to U.S. officials, and State reporting, charitable 

organizations in Saudi Arabia include organizations termed “charities”—

which tend to operate within the Kingdom—and organizations dubbed 

“multilateral” charitable organizations—which are based in Saudi Arabia 

but have branches in other parts of the world. Multilateral charitable 

organizations based in Saudi Arabia include the Muslim World League, the 

International Islamic Relief Organization (IIRO), and the World Assembly 

of Muslim Youth. The 2003 rules applied to charitable organizations and 

prohibited them from making cash disbursements and transferring money 

outside of Saudi Arabia.43 U.S. officials have testified that the 2003 

regulations did not apply to multilateral organizations. While State 

reported in the 2006, 2007, and 2008 INCSRs that the government of Saudi 

Arabia stated the 2003 regulations applied to international charities,44 each 

report also contained language recommending the Saudi government 

enhance its oversight of charities with overseas operations. 

Despite the ban on charities transferring money outside of Saudi Arabia 

enacted in 2003, a number of charitable organizations with links to Saudi 

Arabia have been designated by Treasury since 2005 as financing terrorist 

activities. In August 2006, Treasury designated branches of the IIRO in 

Indonesia and the Philippines, as well as a Saudi national employed as the 

Executive Director of the Eastern Province Branch of IIRO, for facilitating 

fundraising for Al Qaeda and affiliated terrorist groups. Further, from 2002 

 

43Additionally, according to State, for over 20 years, the Saudi government has had 

regulations requiring all charities to be licensed, registered, and audited by the Saudi 

Ministry of Social Affairs. 

44In the INCSR, it is not clear to which organizations the term “international charities” 

applies. 

Page 34 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

to 2004,45 the United States designated 13 branches of the Al Haramain 

Islamic Foundation (Al Haramain), including several branches that were 

designated by both the U.S. and Saudi governments.46 In 2004, the Saudi 

government announced that Al Haramain was being dissolved. In June 

2008, Treasury noted that despite Saudi government efforts, which had 

largely prevented Al Haramain from operating in its own name, the 

organization’s leadership had attempted to reconstitute itself and parts of 

Al Haramain continued to operate. Thus, in June 2008, Treasury 

designated all branches of Al Haramain, including its headquarters in 

Saudi Arabia, for having provided support to Al Qaeda as well as other 

terrorists and terrorist organizations. 

After these designations, in rules dated December 2008, the government of 

Saudi Arabia updated its banking regulations to include specific language 

related to multilateral organizations, including Muslim World League, 

IIRO, and World Assembly of Muslim Youth. The rules state that transfers 

from the accounts of these multilateral organizations to any party outside 

of the Kingdom shall not be allowed without approval from SAMA, and 

that any contributions approved for transfer may only be used in ways as 

specified by SAMA. Saudi officials from SAMA and the Ministry of Foreign 

Affairs with whom we spoke told us that no charitable contributions, 

including those from multilateral charitable organizations, can be sent 

abroad through bank accounts without the approval of the Saudi 

government. Moreover, Saudi officials told us that, as of July 2009, the 

Saudi government had not approved any transfer of funds from charities 

and multilateral charitable organizations to support charitable activities 

outside of Saudi Arabia. While the Saudi government has not approved the 

transfer of funds, they have approved overseas transfers of in-kind 

humanitarian assistance, such as medical supplies or blankets, through the 

Saudi Red Crescent Society. State reporting acknowledges the Saudi 

government tightened controls on charitable giving in September 2008. 

Officials from World Assembly of Muslim Youth confirmed that the ban on 

charitable contributions leaving Saudi Arabia through a formal financial 

network applies to their activities, and that contributions to their 

organization have declined as a result. While the Saudi government has 

 

45Between 2002 and 2004, the United States designated branches in Afghanistan, Albania, 

Bangladesh, Bosnia & Herzegovina, Comoros Islands, Ethiopia, Indonesia, Kenya, 

Netherlands, Pakistan, Somalia, Tanzania, and the United States. 

46The UN 1267 Committee has designated some, but not all, branches of Al Haramain 

Foundation. 

Page 35 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

regulations related to the transfer of charitable contributions through the 

formal financial system, World Assembly of Muslim Youth officials stated 

they have moved money out of Saudi Arabia by providing cash to 

individuals or contractors to implement charitable projects outside the 

Kingdom.47 State and Treasury officials noted that, despite the tightened 

regulations on the formal financial system, they are still concerned about 

the ability of multilateral charitable organizations to move money out of 

the country, and in the 2009 INSCR, State reports that multilateral 

organizations operate “largely outside of the strict Saudi restrictions 

covering domestic charities.” 

According to U.S. officials and State reporting, a proposal for the Charities 

Commission is still under review by Saudi officials. However, the most 

recent MSP for Saudi Arabia no longer contains a performance target 

related to the operation of a Saudi Charities Commission. U.S. officials 

told us that, even in the absence of this target, the regulation of charitable 

organizations is still a priority that U.S. agencies pursue through 

diplomatic and information-sharing activities with the Saudi government. 

 

47Officials from World Assembly of Muslim Youth stated they would prefer a regulatory 

system that would allow them to more easily transfer money to their affiliates abroad, 

instead of a complete ban on the transfer of charitable contributions outside of Saudi 

Arabia via the formal financial system. The officials noted that having to pay cash couriers 

and local contractors results in less funds being available for projects. 

Page 36 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

In late 2005, the Saudi government enacted stricter customs declaration 

laws that regulate the cross-border movement of cash, jewels, and 

precious metals. The regulations state that money and gold in excess of 

60,000 Saudi riyals (equivalent to $16,000 U.S. dollars) must be declared 

upon entry and exit from Saudi Arabia using official customs forms.48

Saudi Arabia Has Issued Cash 

Courier Regulations, but 

Concerns Remain about 

Implementation of These 

Regulations 

That same year, representatives from DHS’s Immigration and Customs 

Enforcement (ICE) conducted training for 46 Saudi officials on topics 

related to bulk cash smuggling. ICE officials told us the goal of this 

training was to introduce Saudi officials to interdiction and investigative 

techniques designed to support enforcement of the Saudi customs 

regulations. 

In 2007, State reported concerns related to the enforcement of Saudi 

Arabia’s customs declaration laws. For example, Saudi customs had not 

issued the necessary declaration forms. State officials with whom we 

spoke told us that the Saudi government had improved its enforcement of 

the laws, including distributing declaration forms and posting signs, which 

we observed during our visit to the Kingdom (see figure 8). Additionally, 

State has reported that the Saudi government’s new cash courier 

regulations have resulted in the investigations of several individuals. 

 

48By comparison, each individual arriving into the United States is required to declare 

monetary instruments, such as cash, traveler’s checks, or money orders, valued at $10,000 

or more. 

Page 37 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

Figure 8: Official Saudi Customs Declaration Form 

Source: Royal Embassy of Saudi Arabia.

According to ICE officials, although they have tried to persuade the Saudi 

government to conduct operational training related to preventing bulk 

cash smuggling, the Saudi government did not express interest in 

undertaking such an exercise until 2008. ICE officials noted that, in 

addition to classroom training, it considers operational training necessary 

to ensure proper enforcement of customs declaration laws designed to 

prevent bulk cash smuggling. Moreover, ICE officials said that they do not 

have information—such as the number of seizures and prosecutions—that 

would allow them to assess progress with regard to the Saudi 

Page 38 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

government’s efforts to prevent bulk cash smuggling. In its 2009 INCSR, 

State reported that the Saudi government has adopted stricter regulations; 

however, information collected by Saudi customs on cash declarations 

and smuggling is not shared with other governments, and the 

implementation and effectiveness of the customs regulations remain in 

question. 

Despite concerns about the Saudi government’s enforcement of customs 

declaration laws that include cash courier regulations, the MSP 

performance target related to cash couriers was removed from the MSP 

after fiscal year 2007. U.S. officials told us that, despite the omission of the 

target from the MSP, Saudi implementation and enforcement of cash 

courier regulations are important U.S. objectives that U.S. agencies pursue 

through training and diplomatic activities with the Saudi government. 

Further, in the 2008 and 2009 INCSRs, State reported that, in addition to 

bulk cash, some instances of terrorist financing in Saudi Arabia have 

allegedly involved informal mechanisms, such as hawala.49 U.S. and Saudi 

officials told us, and State reports, that hawala and money services 

businesses apart from banks and licensed money changers are illegal in 

Saudi Arabia. In 2005, State reported that SAMA consolidated the eight 

largest money changers into a single bank. Further, State notes that Saudi 

banks have created fund transfer systems that have attracted customers 

accustomed to using hawala. According to State, this creates an advantage 

for Saudi authorities in combating terrorism financing, as senders and 

recipients of fund transfers through this formal financial sector are 

required to clearly identify themselves. 

Despite reporting progress in Saudi Arabia’s efforts to combat terrorism 

financing, U.S. officials expressed concern regarding the ability of Saudi 

individuals and multilateral charitable organizations, as well as other 

individuals visiting Saudi Arabia, to support terrorism and violent 

extremism outside Saudi Arabia. Officials stressed this funding allegedly 

comes from individuals or multilateral charitable organizations, not from 

the Saudi government, and that the government of Saudi Arabia is 

pursuing terrorism financiers and cooperating with the United States to 

counter terrorism financing. Further, experts we spoke with agreed that 

Despite Progress, U.S. Officials 

Remain Concerned about the 

Ability of Saudi Individuals and 

Multilateral Charitable 

Organizations to Support 

Terrorism and Violent 

Extremism Outside of Saudi 

Arabia 

 

49Hawalas are informal banking systems that allow the transfer of funds, both domestically 

and internationally, without the use of the formal financial institutions. 

Page 39 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

there is no indication that the Saudi government is providing funding for 

terrorism. 

Officials from State, Treasury, and DHS stated that alleged support from 

some Saudi individuals and multilateral charitable organizations for 

terrorism and violent extremism outside of Saudi Arabia remains a cause 

for concern. According to the 2009 INCSR, Saudi individuals and Saudibased charitable organizations continue to be a significant source of 

financing for terrorism and extremism outside of Saudi Arabia. For 

example, Treasury officials have noted that Saudi-based individuals are a 

top source of funding for Al Qaeda and associated terror groups, such as 

the Taliban.50 Moreover, there have been concerns that during hajj—when 

an estimated 2 to 3 million Muslims visit Saudi Arabia—non-Saudi 

individuals associated with extremists groups could exchange funds to 

support terrorism and violent extremism outside of Saudi Arabia. Saudi 

government officials acknowledged that Saudi individuals could 

potentially fund terrorism, but, according to these officials, such 

individuals do so in violation of Saudi laws and regulations. Related to 

charitable contributions, Saudi officials told us that no funds have been 

approved for overseas transfer. Saudi officials also told us that if a Saudiaffiliated multilateral charitable organization raises funds abroad, it is the 

host country government’s responsibility to ensure such funds are used 

appropriately, and stated that they have directed their embassies abroad to 

cooperate with host country governments in this effort. 

U.S. and Saudi officials cited challenges associated with efforts to prevent 

financial support to extremists, including limited Saudi enforcement 

capacity and the use of cash couriers by terrorist financiers. First, U.S. and 

Saudi officials noted enforcement capacity presents a challenge to U.S.-

Saudi efforts to prevent financial support to extremists. While noting 

progress, U.S. and Saudi officials told us that key Saudi enforcement 

agencies, particularly those agencies that enforce financial regulations, 

could benefit from increased training and technical assistance to build 

their capacity. For instance, U.S. and Saudi officials stated that, while the 

Saudi FIU has expanded its capacity since its creation in 2005, more 

training in financial analysis could be beneficial to the organization. 

 

50Treasury officials did not cite an estimated amount of funding from Saudi-based 

individuals to Al Qaeda and associated terror groups. 

Page 40 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

Second, U.S. and Saudi officials told us that preventing financial support 

to extremists is made more challenging by terrorist financiers’ use of cash 

couriers. According to U.S. and Saudi officials, some individuals and 

multilateral charitable organizations have allegedly increased their use of 

more informal financial transaction methods, such as couriering cash 

across borders, in response to Saudi Arabia’s adoption of regulations 

making transactions in the formal financial sector more challenging. 

Though Saudi Arabia has implemented cash courier regulations, Saudi 

officials noted that motivated individuals can circumvent such regulations 

by moving amounts of cash that are below legal declaration limits. U.S. 

officials concurred, noting circumvention of regulations as an inherent 

challenge in regulating the use of cash couriers in any country. U.S. and 

Saudi officials also cited the prevalent use of cash for transactions as a 

challenge, particularly in Saudi Arabia. According to these officials, 

because large numbers of people in Saudi Arabia and the Gulf region use 

cash, an individual traveling with or declaring large amounts of cash may 

not raise suspicion. Moreover, challenges associated with preventing the 

circumvention of cash courier regulations increase during hajj, which, 

despite efforts by the Saudi government, presents logistical enforcement 

challenges because of the large number of people involved. Dealing with 

the challenges inherently associated with the use of cash, according to 

Saudi officials, requires using intelligence to target specific individuals 

who may be using cash to fund terrorism or violent extremism and 

educating the public not to give cash to individuals they do not know, even 

for allegedly worthy causes. 

According to State, goals and performance targets in country-specific 

Mission Strategic Plans (MSP) are used to assess effectiveness of U.S. 

policies and programs in the field and to formulate requests for resources. 

According to U.S. officials, since 2005, several targets to assess progress of 

the U.S. government’s counterterrorism and antiterrorism financing 

collaboration with the Kingdom of Saudi Arabia have been met. However, 

some performance targets, specifically those related to combating 

financing of terrorism, were removed from the MSP for Saudi Arabia even 

though U.S. agencies remain concerned about the ability of Saudi 

individuals and multilateral charitable organizations to fund terrorist 

organizations in other countries. U.S. agencies stated that, despite the 

omission of these targets, they continue to engage with the government of 

Saudi Arabia on efforts to prevent financial support to extremists. Given 

that State uses MSP targets to assess progress in countering terrorism and 

terrorism financing in Saudi Arabia, it is important that the U.S. mission 

include targets related to key areas of concern to more effectively 

Conclusion 

Page 41 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

prioritize U.S. efforts and to formulate resource requests for these 

activities. 

We recommend that the Secretary of State direct the U.S. mission in the 

Kingdom of Saudi Arabia to reinstate, in consultation with relevant U.S. 

agencies, performance measures related to preventing the flow of alleged 

financial support, through mechanisms such as cash couriers, to terrorists 

and extremists outside Saudi Arabia. 

State and DOD provided written comments on a draft of this report, which 

are reproduced in appendices V and VI, respectively. State concurred with 

our recommendation and committed to instructing the U.S. Embassy, 

Riyadh, in consultation with key interagency partners, to ensure that the 

Mission Strategic Plan reflect the continued importance of cooperation to 

combat terrorism financing, including by reinstating performance 

indicators related to Saudi enforcement of cash courier regulations. DOD 

also concurred with the report. In addition, we received technical 

comments from DOD, DOE, NSC, State, Treasury, and the intelligence 

community. Additionally, consistent with our protocols, we provided a 

copy of the draft report to Saudi officials, who described the report as a 

fair and detailed review of U.S. and Saudi efforts and also offered 

technical comments. We incorporated technical comments as appropriate. 

Recommendation for 

Executive Action 

Agencies Comments, 

Third-Party Views, 

and Our Evaluation 

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 5 days from the 

report date. At that time, we will send copies to the Departments of State, 

Treasury, Defense, Energy, Homeland Security, Justice, the intelligence 

community, and the National Security Council. In addition, the report will 

be available at no charge on the GAO Web site at http://www.gao.gov. 

Page 42 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
 

If you or your staff have any questions about this report, please contact me 

at (202) 512-5257, or merrittz@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made key contributions to this report are 

Zina D. Merritt, Acting D

listed in appendix VII. 

irector 

International Affairs and Trade 

Page 43 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
Appendix I: Objectives, Scope and 

Methodology 

Page 44 GAO-09-883 

Appendix I: Objectives, Scope and 

Methodology 

In this report, we were asked to report on (1) the U.S. government strategy 

to collaborate with and assist the Kingdom of Saudi Arabia to counter 

terrorism and terrorism financing, and (2) U.S. government agencies’ 

assessment of and the Saudi government’s views on progress toward the 

goals of the U.S. strategy to collaborate with and assist the Kingdom of 

Saudi Arabia. 

Our work focused on the efforts of the intelligence agencies; the 

Departments of Defense (DOD), Energy (DOE), Homeland Security (DHS), 

Justice (DOJ), State (State), and the Treasury (Treasury); and the National 

Security Council (NSC) to collaborate with Saudi Arabia to combat 

terrorism and terrorism financing since 2005. Within these agencies and 

executive offices, we met with officials from several relevant components 

that are monitoring or working with the Saudi government on efforts to 

combat terrorism and its financing, including DHS’s Immigration and 

Customs Enforcement (ICE); DOJ’s Federal Bureau of Investigation (FBI); 

State’s bureaus of Coordinator of Counterterrorism; Economic, Energy, 

and Business Affairs; International Narcotics and Law Enforcement 

Affairs; and Near Eastern Affairs; and Treasury’s Office of Terrorism and 

Financial Intelligence, Financial Crimes Enforcement Network, and the 

Internal Revenue Service. We focused on these agencies and components 

as a result of previous work undertaken by GAO regarding efforts to 

address violent extremism, our review of information since GAO’s 

previous work indicating which agencies were involved in efforts to 

collaborate with Saudi Arabia, and discussions with U.S. agency officials 

regarding the agencies with which they collaborate. 

To examine the U.S. government strategy to collaborate with and assist 

the Kingdom of Saudi Arabia to counter terrorism and terrorism financing, 

we reviewed relevant U.S. strategic documents, including the U.S. 

Strategy Toward Saudi Arabia, Report Pursuant to Section 2043(c) of 

the Implementing the Recommendations of the 9/11 Commission Act, 

and Mission Strategic Plans (MSP) for Saudi Arabia (previously called 

Mission Performance Plans) for fiscal years 2005 to 2011. While we did not 

assess these documents for key elements of a strategy as identified by 

GAO, we used the performance targets stated in these documents as 

criteria against which we assessed progress. In addition to documents 

from U.S. agencies, we obtained documents detailing the Saudi 

government’s approach to combating terrorism and terrorism financing 

from Saudi officials, and reviewed public information available on the 

embassy Web site. We discussed the U.S. government strategy to 

collaborate with and assist Saudi Arabia with officials from DOD, DHS, 

DOJ, State, and Treasury, as well as representatives from the Saudi 

 U.S.-Saudi Counterterrorism Efforts 
Appendix I: Objectives, Scope and 

Methodology 

embassy, including the Saudi Ambassador to the United States. 

Furthermore, while in Riyadh, Saudi Arabia, we discussed the U.S. strategy 

to collaborate with Saudi Arabia with officials from the U.S. embassy, 

including the then ambassador, as well as representatives from the Saudi 

government, including representatives from the Ministries of Foreign 

Affairs, Interior, and Islamic Affairs. We met with Saudi officials from 

these ministries as they are involved in efforts to combat terrorism and 

extremism. 

To report U.S. government agencies’ assessment of progress toward the 

goals of the U.S. strategy to collaborate with and assist the Kingdom of 

Saudi Arabia, we reviewed relevant U.S. planning and evaluation 

documents, including MSPs for Saudi Arabia, Country Reports on 

Terrorism, and International Narcotics Control Strategy Report: Volume 

II, Money Laundering and Financial Crimes, among others. Additionally, 

we developed and administered a data collection instrument to agencies 

providing training and technical assistance to the Saudi government—

including State, Treasury, DOJ, DHS, DOD, and DOE—to obtain 

information on programs and activities, including goals, description, 

indicators, assessments, and associated funding. We corroborated 

information reported to us in the data collection instrument with 

information obtained during interviews with agency officials and reported 

in agency evaluation documents. Further, we obtained and examined 

documentation from Saudi officials regarding their domestic efforts to 

counter terrorism and terrorism financing, including Rules Governing the 

Opening of Bank Accounts and General Operational Guidelines in Saudi 

Arabia, Third Update, December 2008, and reviewed public information 

available on the embassy Web site. Although we report on Saudi efforts to 

combat extremism, we did not independently verify all of these activities. 

In Washington, D.C., we discussed progress on U.S.-Saudi 

counterterrorism efforts with U.S. officials from DOD, DOE, DHS, DOJ, 

State, Treasury, and the intelligence community; as well as with Saudi 

officials from the Royal Embassy of Saudi Arabia. We also interviewed 

subject matter experts from a variety of academic institutions and 

nongovernmental organizations to obtain their assessments of progress. 

We selected experts who met at least one of the following criteria: (1) 

produced research focusing on Saudi Arabia; (2) traveled to Saudi Arabia; 

and, (3) were recognized as experts in the professional community, as 

determined by the recommendation of other experts. State concurred with 

our list of experts. Additionally, we traveled to Riyadh and Jeddah, Saudi 

Arabia, where we visited the Prince Mohammed bin Nayef Center for 

Advisory and Care—a counseling program designed to reeducate violent 

extremists—in Riyadh, and met with U.S. officials from DOD, DHS, DOJ, 

Page 45 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
Appendix I: Objectives, Scope and 

Methodology 

State, and Treasury; Saudi officials from the Saudi Arabian Monetary 

Agency and the Ministries of Foreign Affairs, Interior, and Islamic Affairs; 

and representatives from World Assembly of Muslim Youth. The 

information on foreign laws in this report is not a product of our original 

analysis, but is based on interviews and secondary sources. 

We conducted this performance audit from July 2008 through September 

2009 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. 

Page 46 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
Appendix II: Time Line of Key Events in U.S. 

and Saudi Relations, 1750-2004 

Summary Date Description 

Alliance between Muhammad bin Saud and a 

conservative Muslim leader 

Mid-18th century Muhammad bin Saud, founder of the precursor to the modern 

Saudi state, strikes an alliance with the conservative Muslim 

leader, Muhammad bin Abdul Wahhab. This marks the start of 

the close association between Saudi political and religious 

establishment. 

Saudi power and influence expands 1902 to 1926 Abdul Aziz Al Saud expands Saudi power to other regions of the 

Arabian Peninsula, including Riyadh and the holy Muslim city of 

Mecca. 

Modern Kingdom of Saudi Arabia established 1932 The modern Kingdom of Saudi Arabia is formally established 

under the reign of King Abdul Aziz Al Saud with a system of 

government based on Islamic law. 

U.S.-Saudi diplomatic relations established 1933 United States and Saudi Arabia establish diplomatic relations. 

Saudi Arabia starts large scale oil production 1940s Saudi Arabia starts large scale oil production after World War II. 

Saudi King meets with President Roosevelt 1945 The meeting between King Abdul Aziz and President Franklin D. 

Roosevelt to discuss oil and security is considered the start of 

more robust U.S.-Saudi relations. 

State of Israel established 1948 In 1948, Israel is established with support from the United 

States and overwhelming Arab opposition. 

Saudi Arabia allies with the United States in 

fighting communism 

1950s U.S. and Saudi governments pursue some common national 

security objectives, including combating the global spread of 

communism. U.S. administrations consider the Saudi monarchy 

as an ally against nationalist and socialist governments in the 

Middle East. 

First U.S. military training mission organized 

under the terms of the U.S. and Saudi mutual 

defense assistance agreement 

1953 United States provides military training assistance to Saudi 

Arabia under the terms of the Defense Assistance Act of 1949 

and the Mutual Security Act of 1951. 

First multilateral charitable organization founded 

in Saudi Arabia 

1960s The Muslim World League, one of several multilateral charitable 

organizations, is established with headquarters in Saudi Arabia 

to promote Islam and extend economic aid to Muslim nations. 

Oil production creates great wealth in Saudi 

Arabia 

1970s Oil production in the 1970s makes Saudi Arabian per capita 

income comparable to that of other developed countries. As the 

price of oil rises, Saudi Arabia’s wealth and political influence 

increase. 

Iran is established as an Islamic state 

Soviets invade Afghanistan 

Extremists attack Grand Mosque in Mecca 

1979 The Islamic Republic of Iran is established after the ouster of the 

Shah, signaling the rise of political Islam as a challenge to 

existing regimes in the region. 

The Soviet army invades Afghanistan in December, prompting 

opposition from some Arab governments as well as from the 

United States and its allies. 

Religious extremists seize the Grand Mosque of Mecca; the 

Saudi government regains control and executes the 

perpetrators. 

Appendix II: Time Line of Key Events in U.S. 

and Saudi Relations, 1750-2004 

Page 47 GAO-09-883 U.S.-Saudi Counterterrorism Efforts 
Appendix II: Time Line of Key Events in U.S. 

and Saudi Relations, 1750-2004 

Summary Date Description 

Saudi Arabia and United States aid the 

mujahideen against the Soviets in Afghanistan 

1980s Volunteers from some Muslim countries, including Saudi Arabia, 

join the Afghan mujahideen (the name given to Afghan 

resistance fighters) in their fight against the Soviets. The United 

States and Saudi Arabia play a leading role in supporting the 

mujahideen. 

United States establishes military installations in 

Saudi Arabia 

1991 The United States establishes military installations in Saudi 

Arabia during the U.S.-led and Saudi-supported ouster of the 

Iraqi army from Kuwait. The bases draw intense opposition from 

Al Qaeda, which was founded 3 years earlier. 

Bombing of the World Trade Center kills 6 1993 Terrorists, some with links to Al Qaeda, use a car bomb to 

attack the World Trade Center in New York City killing 6 people 

and injuring 1,042. 

Saudi government strips Osama bin Laden of 

citizenship 

Islamists arrested in Saudi Arabia 

1994 Citing his support of extremist movements, Saudi Arabia strips 

Osama bin Laden of Saudi citizenship. 

Saudi authorities arrest hundreds of Islamists who have been 

openly critical of the Saudi government. 

Terrorist attack in Saudi Arabia kills 5 Americans 1995 Saudi terrorists use a truck bomb to attack the Riyadh 

headquarters of the U.S.-operated training center of the Saudi 

National Guard resulting in the death of 5 Americans, among 

others. 

Bombings in Saudi Arabia kill 19 Americans 1996 Terrorist bombings at U.S. military complex in Khobar, eastern 

Saudi Arabia, kill 19 Americans and wound many others. The 

attack is conducted by Saudi Hizaballah. 

Saudi Arabia recognizes the Taliban regime in 

Afghanistan 

1997 The Taliban rise to power in Afghanistan in 1996, imposing a 

strict interpretation of Islamic law on Afghan society. In 1997, 

Saudi Arabia becomes one of three countries to recognize the 

Taliban regime. 

UN Security Council adopts Resolution 1267 1999 The United Nations Security Council adopts Resolution 1267 

imposing financial and other sanctions applying to individuals 

and entities associated with Al Qaeda, Osama bin Laden, and/or 

the Taliban. 

Start of the Palestinian uprising strains U.S.-

Saudi relations 

Attack on USS Cole 

2000 Dissatisfaction in Saudi Arabia and many parts of the Arab world 

with U.S. policies related to the second Palestinian intifada (or 

uprising). Frustrated by a lack of U.S. response to IsraeliPalestinian violence, in a letter to President Bush in 2001, Saudi 

Crown Prince Abdullah warns of a serious rift between the two 

governments. 

Al Qaeda attack on the USS Cole harbored in Yemen kills 17 

American soldiers. 

Page 48 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
Appendix II: Time Line of Key Events in U.S. 

and Saudi Relations, 1750-2004 

Summary Date Description 

Al Qaeda attacks United States 

Saudi Arabia condemns September 11th attacks 

on the United States 

U.S. and allied forces attack the Taliban and Al 

Qaeda in Afghanistan 

2001 On September 11th, the World Trade Center in New York and 

the Pentagon in Washington, D.C. are the targets of terrorist 

attacks, and a hijacked plane crashes in Pennsylvania. The 

attacks are carried out by 19 Al Qaeda hijackers, including 15 

Saudi nationals. 

Saudi Arabia condemns the attack and withdraws its official 

recognition of the Taliban government in Afghanistan, which is 

an ally of Al Qaeda. 

U.S. forces, along with those of several allies and Afghanistan’s 

Northern Alliance, topple the Taliban regime and remove the 

safe haven for Al Qaeda in Afghanistan. Some Al Qaeda 

survivors return to their countries of origin, including Saudi 

Arabia. 

United States begins military operations in Iraq

Major terrorist incidents in Saudi Arabia 

2003 The United States and its coalition of allies begin military 

operations in Iraq in March. Saudi Arabia publicly opposes the 

U.S.-led invasion of Iraq, but reportedly allows the U.S.-led 

forces the use of military facilities in the Kingdom in support of 

operations in Iraq. However, virtually all U.S. troops are 

withdrawn from the Kingdom by August. 

Several terrorist incidents in Saudi Arabia, including attacks in 

May and November on residential compounds, kill dozens of 

people. 

Iraqi insurgency attracts foreign fighters, 

including Saudis 

2003 to present Iraqi insurgency attracts foreign fighters, including Saudi 

nationals. 

Escalation in terrorist attacks in Saudi Arabia 

and Saudi government retaliation 

2004 A series of terrorist attacks throughout Saudi Arabia results in 

dozens of victims. The targets include Saudi Arabia’s oil 

infrastructure and the U.S. Consulate in Jeddah. Saudi security 

forces intensify their antiterrorist campaign, with casualties on 

both sides, including Abdulaziz al-Mughrin, the head of Al 

Qaeda in Saudi Arabia. 

Source: GAO 

Page 49 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
Appendix III: Saudi Ministries and Agencies 

that Have Functions Related to Countering Appendix III: Saudi Ministries and Agencies Terrorism and Terrorism Financing 

that Have Functions Related to Countering 

Terrorism and Terrorism Financing 

Saudi ministries and agencies Description 

Ministry of Interior Primary ministry responsible for efforts to combat terrorism and terrorism 

financing. It has issued “most wanted” list of terrorists and its security forces 

have killed or arrested terrorist suspects. The ministry also includes 

investigative units and oversees the Saudi rehabilitation program for 

terrorism suspects. The ministry oversees public security, coast guards, civil 

defense, fire stations, border police, and special security and investigative 

functions, including criminal investigation. 

Saudi Arabian Financial Investigation Unit This unit, which is within in the Ministry of Interior, was created in 2005 and 

tasked with handling money laundering and terror finance cases. All banks 

are required to file suspicious transaction reports with this unit. It collects and 

analyzes these reports and other available information and makes referrals 

to relevant Saudi agencies, including the Mabahith for further investigation 

and prosecution. 

Mabahith Also referred to as the General Investigation Directorate, it investigates 

cases related to terrorism, among other activities. 

Saudi Arabian Monetary Agency Serves as the central bank of the Kingdom of Saudi Arabia. It plays a central 

role in overseeing all anti-money laundering and combating financing of 

terrorism programs and supervises all banking, securities, and insurance 

activities in the country. 

Ministry of Foreign Affairs Oversees political, cultural, and financial international relations; monitors 

diplomatic relations. Signs bilateral agreements, including those related to 

counterterrorism, and coordinates efforts with other governments. 

Ministry of Finance Oversees government finance, including budgeting and expenditure of all 

ministries and agencies; controls national economic growth, zakat, income 

tax, and customs. 

Ministry of Islamic Affairs, Endowments, Call and 

Guidance 

Oversees all Islamic affairs, including maintenance of mosques and 

monitoring of clerics. The ministry is reported to have dismissed a large 

number of extremist clerics and sent them to be reeducated. 

Ministry of Education Oversees all schools, including physical infrastructure and curriculum. One 

of its priorities is to increase awareness and religious tolerance among 

teachers. 

Source: GAO summary of Saudi government information. 

Page 50 GAO-09-883 U.S.-Saudi Counterterrorism Efforts 
Appendix IV: U.S. Agencies Providing Training 

and Technical Assistance to Saudi Arabia, Appendix IV: U.S. Agencies Providing 2005-2008 

Training and Technical Assistance to Saudi 

Arabia, 2005-2008 

U.S. agency Associated activities 

Department of Defense (DOD) • Along with State and DOE, assists the Saudi government with the protection of critical 

infrastructure assets, such as oil installations, through the Office of Program 

Management-Ministry of Interior (OPM-MOI)—a U.S.-Saudi joint organization. 

Department of Energy (DOE) • Along with DOD and State, assists the Saudi government with the protection of critical 

infrastructure assets, such as oil installations, through OPM-MOI. DOE has provided 

training to Saudi officials on conducting facilities assessments, as well as performed joint 

assessments of key facilities. 

Department of Homeland Security • Provided training to Saudi Customs officials on interdiction and investigation related to 

bulk cash smuggling. 

Department of Justice • Provided training to Saudi officials, through the Federal Bureau of Investigation, on 

financial investigation techniques. 

Department of State (State) • Leads the U.S. Mission in Saudi Arabia. 

• Provided training to Saudi government officials related to building investigative capability 

and consulted on oil installation security. 

• Along with DOD and DOE, assists the Saudi government with the protection of critical 

infrastructure assets, such as oil installations, through OPM-MOI. 

Department of the Treasury • Through the Financial Crimes Enforcement Network, provided training to, and conducted 

assessments of, the Saudi Arabian Financial Investigation Unit. 

• Through Internal Revenue Service-Criminal Investigations, provided training to Saudi 

officials on financial investigation techniques. 

Intelligence community • Engages in information sharing with Saudi ministries. 

Source: GAO analysis of U.S. agency information. 

Page 51 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
Appendix V: Comments from the Department 

of State 

Page 52 GAO-09-883 

Appendix V: Comments from the Department 

of State 

U.S.-Saudi Counterterrorism Efforts
Appendix V: Comments from the Department 

of State 

Page 53 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
Appendix VI: Comments from the Department Appendix VI: Comments from the of Defense 

Department of Defense 

Page 54 GAO-09-883 U.S.-Saudi Counterterrorism Efforts 
Appendix VII: GAO Contact and Staff Appendix VII: GAO Contact and Staff Acknowledgments 

Acknowledgments 

Zina D. Merritt, (202) 512-5257 or merrittz@gao.gov

In addition to the person named above, Jason Bair (Assistant Director), 

Ashley Alley, Alexandra Bloom, Joe Carney, Tom Costa, Martin de Alteriis, 

Mark Dowling, Jonathan Fremont, Etana Finkler, Phillip Farah, Joel 

Grossman, Julia Jebo, Charles M. Johnson, Jr., Bruce Kutnick, Elizabeth 

Repko, Mona Sehgal, and James Strus made key contributions to this 

report. Elizabeth Curda, Davi D’Agostino, Muriel Forster, Barbara Keller, 

Eileen Larence, Armetha Liles, Sarah McGrath, and Theresa Perkins also 

provided technical assistance. 

GAO Contact 

Staff 

Acknowledgments 

Page 55 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
Related GAO Products Related GAO Products 

Combating Terrorism: Actions Needed to Enhance Implementation of 

Trans-Sahara Counterterrorism Partnership. GAO-08-860. Washington, 

D.C.: July 31, 2008. 

Combating Terrorism: The United States Lacks Comprehensive Plan to 

Destroy the Terrorist Threat and Close the Safe Haven in Pakistan’s 

Federally Administered Tribal Areas. GAO-08-622. Washington, D.C.: 

April 17, 2008. 

Combating Terrorism: State Department’s Antiterrorism Program Needs 

Improved Guidance and More Systematic Assessments of Outcomes.

GAO-08-336. Washington, D.C.: February 29, 2008. 

Combating Terrorism: Law Enforcement Agencies Lack Directives to 

Assist Foreign Nations to Identify, Disrupt, and Prosecute Terrorists.

GAO-07-697. Washington, D.C.: May 25, 2007. 

Terrorist Financing: Agencies Can Improve Efforts to Deliver CounterTerrorism-Financing Training and Technical Assistance Abroad. 

GAO-06-632T. Washington, D.C.: April 6, 2006. 

Terrorist Financing: Better Strategic Planning Needed to Coordinate U.S 

Efforts to Deliver Counter-Terrorism Financing Training and Technical 

Assistance Abroad. GAO-06-19. Washington, D.C.: October 24, 2005. 

International Affairs: Information on U.S. Agencies’ Efforts to Address 

Islamic Extremism. GAO-05-852. Washington, D.C.: September 16, 2005. 

Border Security: Strengthened Visa Process Would Benefit from 

Improvements in Staffing and Information Sharing. GAO-05-859. 

Washington, D.C.: September 13, 2005. 

Border Security: Actions Needed to Strengthen Management of 

Department of Homeland Security’s Visa Security Program. GAO-05-801. 

Washington, D.C.: July 29, 2005. 

Terrorist Financing: U.S. Agencies Should Systematically Assess 

Terrorists’ Use of Alternative Financing Mechanisms. GAO-04-163. 

Washington, D.C.: November 14, 2003. 

Combating Terrorism: Interagency Framework and Agency Programs to 

Address the Overseas Threat. GAO-03-165. Washington, D.C.: May 23, 

2003. 

(320592) Page 56 GAO-09-883 U.S.-Saudi Counterterrorism Efforts
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