Terrorism and Financial Intelligence

Program Summary by Budget Activity

Dollars in Thousands

FY 2019 FY 2020 FY 2021 FY 2020 to FY 2021

Budget Activity Operating Plan Enacted Request $ Change % Change

Terrorism and Financial Intelligence $159,000 $169,712 $172,751 $3,039 1.79%

Subtotal, TFI $159,000 $169,712 $172,751 $3,039 1.79%

Offsetting Collections - Reimbursable $8,000 $8,000 $8,000 $0 0.00%

Total Program Operating Level $167,000 $177,712 $180,751 $3,039 1.71%

Direct FTE 440 526 575 49 9.32%

Reimbursable FTE 40 41 41 0 0.00%

Total Full-time Equivalents (FTE) 480 567 616 49 8.64%

Summary

The Department of the Treasury’s (Treasury) strategic plan guides program and budget decisions 

for the Office of Terrorism and Financial Intelligence (TFI). The FY 2021 Budget Request 

supports two of Treasury’s FY 2018-2022 Strategic Goals: Enhance National Security and 

Achieve Operational Excellence.

TFI requests $172.751 million, which is a $3.039 million increase from the FY 2020 Enacted 

level. TFI requests these additional resources to continue to invest in its people as well as

infrastructure, systems, and automated tools, thereby ensuring that TFI remains agile, innovative, 

and strategic in responding to the most pressing U.S. national security concerns. The budget 

prioritizes funding for Treasury’s targeted financial tools that protect the U.S. and international 

financial system from abuse, as well as countering the financial networks that support terrorists, 

weapons proliferators, organized transnational crime, rogue regimes, and other threats. 

TFI’s economic authorities continue to play an increasingly central role in countering some of 

the nation’s most critical security threats. This Administration and Congress rely upon TFI to 

deploy non-kinetic tools at a rapid pace to proactively implement U.S. policy towards North 

Korea, Iran, Russia, Islamic State of Iraq and Syria (ISIS) and other terrorist organizations, 

Venezuela, human rights abusers and corrupt actors, narcotics traffickers, and other malign and 

destabilizing actors. As reliance upon TFI’s authorities has grown, the corresponding growth in 

personnel across TFI and increased demand placed upon secure systems requires additional 

investment in mission support areas. TFI’s infrastructure investments have been developed with 

careful consideration of the personnel increase request with the intent of developing and 

maintaining a collaboration network that facilitates our operational and policy goals.
Budget Highlights

Dollars in Thousands

FTE Amount

FY 2020 Enacted 526 $169,712 

Changes to Base: 

Maintaining Current Levels (MCLs): - $ 3,983 

Pay Annualization (2020 3.1% average pay raise) - $757 

Pay Raise (1.0% average pay raise) - $738 

FERS Contribution Increase - $800 

Non-Pay - $1,688 

Non-Recurring Costs - ($2,539)

Efficiency Savings - ($2,716)

Other Adjustments: 30 $0 

FTE Adjustment 30 $0 

Subtotal Changes to Base 30 ($1,272)

FY 2021 Current Services 556 $168,440 

Program Changes: 

Program Increases 19 $4,311 

TFI-Wide Centralized Data Platform Infrastructure Support - $602 

Western Hemisphere/Human Rights Sanctions 3 $657 

Cyber Analysts and Data Scientists 9 $1,583 

Virtual Currency Investigators 4 $812 

Foreign Asset Control Staffing 3 $657 

FY 2021 President's Budget Request 575 $172,751

Budget Adjustments

Maintaining Current Levels (MCLs)....................................................... +$3,983,000 / +0 FTE

Pay Annualization (3.1%) +$757,000 / +0 FTE

Funds are requested for annualization of the January 2020 3.1% average pay raise. 

Pay Raise (1.0% in 2021) +$738,000 / +0 FTE

Funds are requested for a 1.0% average pay raise in January 2021. 

FERS Contribution Increase +$800,000 / +0 FTE

Funds are requested for the Federal Employee Retirement System (FERS) contribution rates 

effective FY 2021.

Non-Pay +$1,688,000 / +0 FTE

Funds are requested for non-labor expenses such as travel, contracts, rent, supplies, and 

equipment.

Non-Recurring Costs................................................................................... -$2,539,000 / -0 FTE

Non-Recur of IT Infrastructure Investments -$2,539,000 / -0 FTE 

One-time costs of the FY 2020 IT Infrastructure Investment initiative will non-recur.
Efficiency Savings........................................................................................ -$2,716,000 / -0 FTE

TFI Contractual Support -$2,716,000 / +0 FTE

TFI will achieve cost savings and efficiencies in contract services through improved oversight of 

all TFI contracts, consolidating contracts where appropriate, and partnering with other agencies 

and Treasury Departmental Offices (DO) components to leverage common technology or 

administrative support needs.

Other Adjustments................................................................................................. +$0 / +30 FTE

FTE Adjustment +$0 / +30 FTE 

The FY 2021 Budget reflects a +30 FTE technical adjustment from the FY 2020 Enacted Budget. 

This technical adjustment reflects increased efforts at TFI to hire and on-board new staff as 

provided for in prior year budget requests. 

Program Increases .................................................................................. +$4,311,000 / +19 FTE

TFI-Wide Centralized Data Platform Infrastructure Support +$602,000 / +0 FTE 

To best utilize the volumes of data currently available to TFI staff and positively leverage 

technology to expand the efficiency of TFI’s limited personnel resources, TFI is establishing a 

data analytics program and staff, an overarching governing body (in close coordination with 

CIO), and an operational enterprise tool capable of fusing TFI’s disparate data streams for TFIN 

desktop analysis by TFI staff. 

Western Hemisphere/Human Rights Sanctions +$657,000 / +3 FTE

Administration and Congressional actions during the past 18 months in the Western Hemisphere 

require significant sanctions implementation efforts by the Licensing, Policy, and Regulatory 

Affairs teams, including: designing sanctions implementation architecture proposals for Treasury 

and interagency leadership, implementing new regulatory frameworks through general licenses 

(over 30 issued in the Venezuela program alone), publishing regulations, and public guidance 

such as frequently asked questions, and processing an onslaught of new licensing requests to 

authorize activity that may be otherwise prohibited but is in U.S. foreign policy interests.

Cyber Analysts and Data Scientists +$1,583,000 / +9 FTE

The Office of Intelligence Analysis (OIA) requests five cyber intelligence research specialists 

and one visual analyst to meet the increased demand from Treasury senior policymakers and 

Domestic Finance/Office of Cybersecurity and Critical Infrastructure Protection for intelligence 

support and analysis to counter the intensification of cyber-enabled threats to the U.S. financial 

services sector (FSS) and US national security interests more broadly. The analysts would focus 

on support to improve the sharing of cyber threat intelligence to the FSS, provide the Office of 

Foreign Assets Control (OFAC) with intelligence support on targeting financial networks of 

malicious cyber actors, and provide tactical intelligence support to TFI cryptocurrency

initiatives. OIA also requests three data scientists to analyze large tranches of data and to build 

assessments from that analysis. Data scientists are skilled in statistical analysis and trained 

specially to perform this type of work, which is critical to using Treasury's own data to answer 

analytic questions and inform policymakers.

Virtual Currency Investigators +$812,000 / +4 FTE

Among the new and emerging threats to the use of sanctions as a tool for national security is the 

rapid development of virtual currencies as a mechanism to move value across borders while
skirting the formal financial system that OFAC relies on as the implementing mechanism for its

authorities. Presently, OFAC has a single investigator focused on the illicit use of virtual 

currency, and this investigator is often pulled away from purely investigative duties in order to 

share virtual currency expertise across TFI, since this area is of high concern but also an 

uncommon area of technical competency. Meanwhile, investigators across most sanctions 

programs are reporting increasing exposure to the use of virtual currencies by the targets of their

investigations. Additional virtual currency investigators will allow investigations involving 

cryptocurrency across all of OFAC’s sanctions programs to be able to exploit this investigative

arena.

Foreign Asset Control Staffing +$657,000 / +3 FTE

The requested Senior Enforcement Officers will provide essential investigative and legal 

knowledge to OFAC’s enforcement process, deliberative memoranda, and final agency charging

documents. These personnel will be responsible for working closely with Enforcement’s 

investigators to coordinate the final phase of public enforcement actions through the OFAC Front 

Office (Director and Deputy Director) and handle all negotiations, meetings, and interactions 

with subject persons thereafter. These personnel will handle such matters for all U.S. economic 

and trade sanctions programs, and will reduce the workload and burden placed on other offices 

(e.g., the Office of Chief Counsel, OFAC).

Legislative Proposals 

The Office of Terrorism and Financial Intelligence has no legislative proposals.

Performance Highlights 

FY 2017 FY 2018 FY 2019 FY 2020 FY 2021

Performance Measure Actual Actual Actual Target Target

New or Modifications to Existing 

Sanctions Programs 5 5 7 I DISC

Number of Designation Actions 867 1431 1120 I DISC

Analytic Intelligence Support 385 523 637 I DISC

Review and Support of Foreign 

AML/CFT Laws and Regulations 49 64 81 I DISC

DISC: Discontinued; I: Indicator

Description of Performance

New or Modifications to Existing Sanctions Programs: This indicator measures new actions or 

expansion of existing sanction programs, and the data is collected by OFAC. The measure 

reflects an increase in workload requirements as any new country programs or expansion in 

scope of existing programs are by and large in addition to current workload and not in lieu of 

already existing work, and therefore, cumulative. Conversely, ongoing program requirements 

are much less frequently removed. The creation or modification of sanctions programs requires 

a significant upfront dedication of policy, program, legal, and regulatory resources to ensure 

proper coordination and documentation of the changes. This measure is being discontinued 

because it has been split into two indicators for FY 2021. One indicator is to monitor the number 

of sanctions programs modified by EO or Congressional mandate, and the second is to monitor 

the number of new sanctions programs modified by EO or Congressional mandate.
Number of Designation Actions: This indicator measures number of actions taken to impose 

sanctions, and is collected by OFAC. It is important to note that for “Program-Specific 

Designations” may not always represent a true reflection of TFI’s extensive efforts across 

programs or toward a particular program. From FY 2017 to FY 2018, TFI activity increased 

across a number of high priority programs. However, the FY 2018 numbers do not reflect the 

approximately 700 Iran sanctions that were implemented on November 5, 2018, in conjunction 

with the full snapback of sanctions following the President’s withdrawal of the United States 

from the JCPOA. Though these sanctions technically occurred in FY 2019, the preparation for 

the tranche was exceedingly complex and required several lines of effort over the last several 

months of FY 2018. 

Analytical Intelligence Support: TFI includes both formal analytical intelligence briefings as 

well as final analytical intelligence products that were published. The significant increase from 

FY 2017 to FY 2018 represents increased demand as well as a higher prioritization on 

production. In FY 2021 this indicator will be replaced with an expanded indicator that includes

the vast array of OIA products, including number of IIRs published and the number of finished 

intelligence pieces published.

Review of Foreign AML/CFT Law and Regulations: This measure tracks/includes participation 

in Financial Action Task Force (FATF) mutual evaluations (ME), which are peer evaluations of 

countries’ levels of effectiveness and implementation of the FATF anti-money laundering and 

countering the financing of terrorism (AML/CFT) Standards. The data is collected from the 

Office of Terrorist Financing and Financial Crimes (TFFC). Participation in MEs usually 

requires several extended on-site visits in country, extensive analysis of a country’s AML/CFT 

system, and follow-up meetings to provide in-depth analyses and ratings. Additionally, the 

metric includes reviews and comments on reports produced by the nine FATF-style Regional 

Bodies; and, work assessing and reviewing countries as part of the International Cooperation 

Review Group, which oversees the FATF process that identifies and reviews jurisdictions with 

strategic AML/CFT deficiencies that may pose a risk to the international financial system and 

closely monitors their progress. Finally, this metric includes strategic support to certain high 

priority bilateral partners in an effort to enhance their AML/CFT laws, regulations, and 

structures. This effort may include, but is not limited to, bi-lateral and multi-lateral meetings, 

foreign travel, and reviewing draft legislation.

New Measures: TFI has also proposed creation of a number of new indicators and measures for 

FY 2021 which will be reflected in the FY 2022 Budget. Among these are regulatory documents 

published in the Federal Register within four months of publication of an Executive order or 

Congressional mandate during the fiscal year; the number of roundtables with private sector on 

Money Laundering/Terrorist Finance threats, vulnerabilities, and risk; the number of 

overseas/domestic engagements with foreign officials by TFFC officials; the timeliness of 

response to de-confliction requests received from law enforcement; the number of security 

clearances processed by OIA’s Office of Security Programs (OSP); and the percent of customer 

satisfaction with OIA products. Please refer to Section C of the TFI Congressional Justification 

for further explanation on new and discontinued measures.