Department of the Treasury 

Office of Terrorism and 

Financial Intelligence 

Congressional Budget 

Justification and Annual 

Performance Report and Plan 

FY 2022 

 
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Table of Contents

Section I – Budget Request........................................................................................................... 3

A – Mission Statement ................................................................................................................ 3

B – Summary of the Request ...................................................................................................... 3

1.1 – Appropriations Detail Table .............................................................................................. 3

1.2 – Budget Adjustments ........................................................................................................... 4

C – Budget Increases and Decreases Description ....................................................................... 4

1.3 – Object Classification (Schedule O) Obligations ................................................................ 7

D – Appropriations Language and Explanation of Changes ...................................................... 8

E – Legislative Proposals ............................................................................................................ 8

Section II – Annual Performance Plan and Report ................................................................... 8

A – Strategic Alignment ............................................................................................................. 8

B – Budget and Performance/Workforce Indicators by Budget Activity ................................... 9

2.1.1 – Terrorism and Financial Intelligence Resources and Measures ..................................... 9

Terrorism and Financial Intelligence Budget and Performance ............................................... 10

C– Evidence-Building Activity ................................................................................................. 12

Section III – Additional Information ........................................................................................ 12

A – Summary of Capital Investments ....................................................................................... 12
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Section I – Budget Request 

A – Mission Statement 

Enhance national security by applying Treasury’s unique policy, enforcement, intelligence, and 

regulatory tools to identify, disrupt and disable terrorists, criminals, and other national security 

threats to the United States and to protect the U.S. and international financial systems from abuse 

by illicit actors. 

B – Summary of the Request 

TFI requests $185.192 million, which is a $10.192 million increase from the FY 2021 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 FY 2022 

budget request also includes funding that represents TFI’s portion of a larger Treasury 

Departmental Offices (DO) project to modernize critical equipment and software that supports 

the DO workforce’s fundamental information technology needs, and replace servers that have 

now reached the end of their useful life. 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 

develop strategies that employ all targeted financial measures, including sanctions, to proactively 

implement U.S. national security and foreign policy goals towards China, Iran, Russia, 

Venezuela, Burma, Islamic State of Iraq and Syria (ISIS) and other terrorist organizations, 

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

actors. This request also includes targeted tools that protect the U.S. and international financial 

system from abuse by illicit actors, to include unexpected challenges such as COVID-19 related 

illicit finance concerns. 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. 

1.1 – Appropriations Detail Table 

Dollars in Thousands 

 FY 2020 FY 2021 FY 2022 FY 2021 to FY 2022 

Appropriated Resources Operating Plan Operating Plan Request % Change 

New Appropriated Resources FTE AMOUNT FTE AMOUNT FTE AMOUNT FTE AMOUNT 

Terrorism and Financial Intelligence 477 $169,712 551 $175,000 575 $185,192 4.4% 5.8% 

Subtotal New Appropriated Resources 477 $169,712 551 $175,000 575 $185,192 4.4% 5.8% 

Other Resources 

Reimbursable 39 $8,543 35 $10,500 41 $10,500 17.1% 0.0% 

Subtotal Other Resources 39 $8,543 35 $10,500 41 $10,500 17.1% 0.0% 

Total Budgetary Resources 516 178,255 586 $185,500 616 $195,692 5.1% 5.5% 

 Note: FTE = Full-time Equivalent employment
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1.2 – Budget Adjustments 

Dollars in Thousands 

 FTE Amount 

FY 2021 Operating Plan 551 $175,000 

Changes to Base: 

Maintaining Current Levels (MCLs): 0 $4,817 

Pay Annualization (1.0% average pay raise) 0 $234 

Pay Raise (2.7% average pay raise) 0 $2,119 

FERS Contribution Increase 0 $836 

Non-Pay 0 $1,628 

Other Adjustments: 8 $0 

Contracts 0 ($1,330) 

FTE Adjustment 8 $1,330 

Subtotal Changes to Base 8 $4,817 

FY 2022 Current Services 559 $179,817 

Program Changes: 

Program Adjustments 16 $0 

Non-recur 0 ($2,750) 

FTE Adjustment 16 $2,750 

Program Increases: 0 $5,375 

Replacement of End of Life Servers 0 $1,659 

IT Modernization 0 $3,716 

FY 2022 President's Budget Request 575 $185,192 

C – Budget Increases and Decreases Description 

Maintaining Current Levels (MCLs) ...................................................... +$4,817,000 / +0 FTE 

Pay Annualization (1.0%) +$234,000 / +0 FTE 

Funds are requested for annualization of the January 2021 1.0% average pay raise. 

Pay Raise (2.7% in 2022) +$2,119,000 / +0 FTE 

Funds are requested for a 2.7% average pay raise in January 2022. 

FERS Contribution Increase +$836,000 / +0 FTE 

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

effective FY 2022. 

Non-Pay +$1,628,000 / +0 FTE 

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

equipment. 

Other Adjustments ................................................................................................... +$0/ +8 FTE 

Contracts -$1,330,000 / -0 FTE 

As a result of hiring delays due to the pandemic, funds initially intended to support FTE 

increases were applied to finance one-time contract requirements in FY 2021. These funds are 

no longer needed to support contracts in FY 2022. 

 
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FTE Adjustment +$1,330,000 / +8 FTE 

The FY 2022 Budget reflects a +8 FTE technical adjustment from the FY 2021 Enacted Budget. 

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

Program Adjustments .......................................................................................... +$0 / +16 FTE 

Non-recur Costs -$2,750,000 / +0 FTE 

These funds are no longer needed to support renovation requirements in FY 2022 and can 

support expanded staffing. 

FTE Adjustment +$2,750,000 / +16 FTE 

The FY 2022 Budget reflects a +16 FTE technical adjustment from the FY 2021 Enacted Budget. 

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

funds no longer required for use towards renovations that program anticipates will be completed 

in FY 2022. 

Program Increases ..................................................................................... +$5,375,000 / +0 FTE 

Replacement of End of Life Servers +$1,659,000 / +0 FTE 

Funds are requested for TFI’s portion of a larger DO project to replace servers that have now 

reached the end of their useful life. 

April 2021 marks one year that DO’s workforce has been in a remote work environment due to 

the coronavirus pandemic. The challenges, weaknesses, and vulnerabilities of DO’s current 

infrastructure have been magnified in a way that may not have been apparent previously. 

Separately, the SolarWinds incident, which impacted the Treasury Department and other federal 

departments and agencies on a much broader level, has exacerbated an already tenuous situation. 

This is particularly acute with respect to Treasury’s server infrastructure. Over the past several 

months, several servers have reached their end of life, and over 120 additional servers will reach 

end of life by FY 2022. If these servers are allowed to reach end of life, key IT infrastructure 

responsible for housing the data of vital programs used by every TFI employee (e.g., email and 

virtual desktops) as well as data for critical national security programs will be put at risk of 

failure or breach. 

DO has been able to negotiate extensions for some of these service contracts over the past few 

months, but this is at best a stopgap remedy. To present the most cost-effective, long-term 

solution, DO conducted several comprehensive studies to review its existing server infrastructure 

and application base. These assessments analyzed DO applications and workloads to determine 

their cloud suitability. Factors considered include: 

1) Suitability for migration to a cloud environment (i.e. whether the workload is elastic or if its 

migration presents any security concerns); 

2) Readiness to move to the cloud (i.e. understanding whether any remediation is required prior 

to migration); and 

3) Level of complexity (i.e. how critical the business processes supported are). 

 
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IT Modernization +$3,716,000 / +0 FTE 

Funds are requested for TFI’s portion of a larger DO project to modernize critical equipment and 

software. Treasury leadership, over the past few years, made the conscious decision to focus 

investments and resources on DO’s policy mission. This request’s key investments include: 

1) End user equipment refreshes and enhancements to support a sustained telework 

posture. Many end user computing devices have reached the end of their useful life and 

require lifecycle replacement. Without a meaningful refresh, end user devices will fail, 

which will have an impact on staff productivity and ultimately impact Treasury’s ability to 

deliver on its mission. This refresh also encompasses equipment that would improve 

telework productivity for TFI staff. DO recently conducted a survey of IT needs and 

satisfaction. The single largest requirement set by users was for additional equipment to 

support their productivity in a remote environment.

2) Redesign of Treasury’s intranet to improve user experience, site navigation, search 

capabilities and information architecture. Improvements should simplify actions, accelerate 

processing, and increase intranet performance collectively by greater than 20 percent. 

3) Modernization of legacy applications/enhancement of existing applications. DO has a need 

to retire legacy applications built on aged technologies to reduce cybersecurity risk, 

standardize low-code platform adoption, and realize operational efficiencies through 

common systems. DO also has identified technology gaps and business process automation 

opportunities which will be prioritized to shift staff focus from low to high value work. This 

initiative will reduce the administrative burden on our IT development staff through 

automation and common tool sets. DO plans to leverage this funding to secure a dedicated 

agile development sprint team comprised of seven resources to continually improve the DO 

application portfolio. The remainder will be used to procure low-code software as a service 

(SaaS) licensing on which legacy applications will continue to be re-platformed. DO will 

prioritize legacy application modernization while integrating enhancements across mission 

support technologies (OSP Tracker, Nuvolo, Impress, etc.). 

4) Migration to managed remote access and remote desktop. DO’s current remote access and 

virtual desktop infrastructure were designed a decade ago and intended to support traveling 

staff as well as a small number of telecommuters for episodic telework and days where a 

large telework load would be supported for a day or two (such as “inclement weather 

events”). While hardware has been occasionally refreshed over the years, the underlying 

architecture has not changed over the past decade. This comes amid increased usage of 

telework flexibilities over this same period, which necessitate a new posture. DO intends to 

migrate to a new managed remote access platform which leverages a similar solution to the 

one IRS has used for its 80,000 plus users during the pandemic. This should help DO to 

leverage IRS’s implementation lessons as well as reduce the Department’s overall attack 

surface area for cyber threats. Both the new managed remote access and virtual desktop 

infrastructure will provide DO with added resiliency, support greater swings in demand, and 

scalability which does not exist in DO’s current posture.
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1.3 – Object Classification (Schedule O) Obligations 

Dollars in Thousands 

 FY 2020 FY 2021 FY 2022 

Object Classification Actual Estimated Estimated 

Obligations Obligations Obligations 

11.1 - Full-time permanent 63,253 74,309 80,485 

11.3 - Other than full-time permanent 431 551 568 

11.5 - Other personnel compensation 2,002 2,332 2,405 

11.9 - Personnel Compensation (Total) 65,686 77,192 83,458 

12.0 - Personnel benefits 21,544 25,125 27,128 

Total Personnel and Compensation Benefits $87,230 $102,317 $110,586 

21.0 - Travel and transportation of persons 1,397 1,367 1,394 

22.0 - Transportation of things 95 94 96 

23.2 - Rental payments to others 222 4 4 

23.3 - Communications, utilities, and miscellaneous charges 48 47 48 

24.0 - Printing and reproduction 4 0 0 

25.1 - Advisory and assistance services 15,837 20,590 19,289 

25.2 - Other services from non-Federal sources 1,089 1,892 1,914 

25.3 - Other goods and services from Federal sources 47,024 42,423 40,103 

25.4 - Operation and maintenance of facilities 27 0 0 

25.7 - Operation and maintenance of equipment 6,693 6,353 10,118 

26.0 - Supplies and materials 3,320 3,209 3,237 

31.0 – Equipment 5,043 2,009 3,682 

32.0 - Land and structures 8,598 5,194 5,221 

Total Non-Personnel $89,397 $83,182 $85,106 

Total Obligations $176,627 $185,500 $195,692 

 

Full-time Equivalents (FTE) 516 586 616 

Amounts reflect obligations of annually appropriated resources, carryover balances, reimbursables, and transfers. 
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D – Appropriations Language and Explanation of Changes 

Appropriations Language Explanation of Changes 

DEPARTMENT OF THE TREASURY 

OFFICE OF TERRORISM AND FINANCIAL 

INTELLIGENCE 

Federal Funds 

SALARIES AND EXPENSES 

For the necessary expenses of the Office of Terrorism and 

Financial Intelligence to safeguard the financial system against 

illicit use and to combat rogue nations, terrorist facilitators, 

weapons of mass destruction proliferators, human rights abusers, 

money launderers, drug kingpins, and other national security 

threats, [$175,000,000] $185,192,000, of which not less than 

$3,000,000 shall be available for addressing human rights 

violations and corruption, including activities authorized by the 

Global Magnitsky Human Rights Accountability Act (22 U.S.C. 

2656 note): Provided, That of the amounts appropriated under 

this heading, up to $10,000,000 shall remain available until 

September 30, [2022] 2023. (Department of the Treasury 

Appropriations Act, 2021.)

 

 

E – Legislative Proposals 

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

Section II – Annual Performance Plan and Report 

A – Strategic Alignment 

In accordance with the Government Performance and Results Act Modernization Act 

(GPRAMA) of 2010, the Department of the Treasury is currently developing the FY 2022 – 

2026 Departmental Strategic Plan. The Strategic Plan is scheduled for publication in 2022. The 

Annual Performance Plan will be updated in the FY 2023 President’s Budget to reflect new 

departmental strategic goals and objectives 
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B – Budget and Performance/Workforce Indicators by Budget Activity 

2.1.1 – Terrorism and Financial Intelligence Resources and Measures 

Dollars in Thousands 

 FY 2016 FY 2017 FY 2018 FY 2019 FY 2020 FY 2021 FY 2022 

 Resource Level Actual Actual Actual Actual Actual Operating 

Plan Request 

Appropriated Resources $117,000 $123,000 $141,778 $159,000 $169,712 $175,000 $185,192 

Reimbursable $6,329 $6,491 $8,626 $7,756 $8,543 $10,500 $10,500 

Budget Activity Total $123,329 $129,491 $150,404 $166,756 $178,255 $185,500 $195,692 

Full-time Equivalents (FTE) 414 428 444 480 516 586 616 

The FY 2016 - FY 2020 appropriated resources represents the approved operating plan. The FY 2016 - FY 2020 columns represent realized 

resources for full-time equivalents, reimbursables, and user fees. 

Performance Measure 

FY 2016 FY 2017 FY 2018 FY 2019 FY 2020 FY 2020 FY 2021 FY 2022 

Actual Actual Actual Actual Actual Target Target Target 

Number of new or modified 

sanctions programs modified by 

EO or Congressional mandate 

during the fiscal year

N/A N/A N/A N/A 7 I I I 

Regulatory documents published 

in the Federal Register within 

four months of publication of an 

Executive order or Congressional 

mandate during the fiscal year

N/A N/A N/A N/A 67% 75% 75% 75% 

Designations and identifications 

released on time to the public 

without errors 

N/A N/A N/A N/A 97% 90% 90% 90% 

Conduct outreach events for the 

other US government agencies, 

the public, the business sector, 

and foreign government per 

calendar year

N/A N/A N/A N/A 0 40 60 60 

Participation in FATF 

international mutual evaluations 

and follow up reports 

N/A N/A N/A N/A 32 I I I 

Number of roundtables with 

private sector on AML/CFT 

threats, vulnerabilities, and risk 

N/A N/A N/A N/A 13 I I I 

# of overseas/domestic 

engagements with foreign 

officials by TFFC officials 

N/A N/A N/A N/A > 690 I I I 

Respond to de-confliction 

requests received from law 

enforcement

N/A N/A N/A N/A 7 days 7 days 7 days 7 days 

# of security clearances processed N/A N/A N/A N/A 1131 B B B 

Number of analytic products 

published (includes number of 

IIRs published, number of 

finished intelligence pieces 

published) 

N/A N/A N/A N/A 446 

IIRs/297 FI I I I 

Percent customer satisfaction 

with OIA products N/A N/A N/A N/A 

Customer 

Satisfaction 

Surveys not 

conducted in 

FY 2020 due 

to the 

COVID-19 

pandemic. 

74% 74% 74% 

Key: I – Indicator; B - Baseline 

Note: All performance measures are new beginning in FY 2020, so no results were reported for FYs 2016 - 2019. 
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Terrorism and Financial Intelligence Budget and Performance 

($185,192,000 from direct appropriations, $10,500,000 from reimbursable resources) 

TFI has strategically applied Treasury’s powerful tools and authorities against bad actors, 

including rogue regimes, terrorist financiers, human rights abusers, proliferators of weapons of 

mass destruction, drug kingpins, and others. Since the beginning of FY 2020, Treasury has 

established four new and six modified sanctions programs. This included the use of tools and 

authorities to deter Iran’s nuclear and ballistic missile program, hindering Iran’s support of 

global terrorism, and offsetting efforts to destabilize the Middle East, Burma, Hong Kong, 

Venezuela, and others. 

On Iran, Treasury targeted terrorist financing and money laundering activity and imposed a 

series of sanctions designed to disrupt Iran’s nuclear program and its ability to acquire and sell 

conventional arms. Treasury imposed sanctions on the Iranian ambassador to Iraq responsible 

for coordinating the activity of Iran’s Islamic Revolutionary Guard Corps Quds Force (IRGCQF) throughout Iraq. Additionally, Treasury imposed sanctions on a huge network on 150 

targets in addition to metals and petrochemical companies. Through the Terrorist Financing 

Targeting Center’s (TFTC) partnership with seven Gulf nations, joint sanctions against the 

Islamic State of Iraq and Syria (ISIS), Hizballah, and Iran’s IRGC were successfully taken. 

Additionally, Treasury applied its tools and authorities against Venezuela’s Maduro regime to 

deny the regime revenue and sanctioned members of the regime for human rights violations and 

corruption. Additionally, Treasury used sanctions to place pressure on North Korea, including 

designations focused on North Korea’s continued supply of unlawful labor to overseas markets, 

which is used to generate income in contravention of United Nations sanctions. Treasury 

countered Russian illicit financing by working with foreign partners and through strategic use of 

sanctions authorities. TFI also formed an election security team in response to foreign 

interference and influence threats to the American electoral system and designated four Russialinked individuals for attempting to influence the U.S. electoral process. 

In addition to administering global programs targeting sanctionable activity, Treasury issued two 

actions under Section 311 of the USA PATRIOT Act and issued eight special collection requests 

on major illicit financing issues. On China, TFI realigned analytic resources to anticipate and 

analyze more thoroughly the security threats China poses and took action to impose costs on 

China for human rights abuses in Xinjiang and for undermining Hong Kong’s autonomy. On 

Burma, Treasury implemented a new sanctions regime in response to the Burmese military’s 

coup against the democratically elected civilian government of Burma. In coordination with the 

issuance of a new Executive Order (E.O.), Treasury designated, pursuant to that E.O. 

approximately 10 individuals and three entities connected to the military apparatus responsible 

for the coup. These actions were taken quickly and at the direction of the White House, in 

response to violence and suppression of peaceful protests over the weekend of February 21, 

2021. 

To strengthen Treasury’s ability to target and combat risks, TFI built a tailored financial 

intelligence data platform that aggregates and overlays TFI data holdings. This platform hosts 

foreign government information, open source corporate registry information, and Financial 
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Action Task Force (FATF) publications, among other resources, to help TFI personnel make 

more effective national security decisions. 

The Office of Terrorist Financing and Financial Crimes-led Illicit Finance Fusion Cell (IFFC), an 

interagency body established in 2018 to use advanced data analytics and public records in 

support of Treasury’s national security priorities, partnered closely with the TFI Chief Data 

Officer to acquire and ingest over 300 million corporate records into the TFI data platform. The 

IFFC’s methodology prioritizes detecting anomalous patterns in publicly available data (PAI) 

that are both indicative of illicit activity and uncover new information previously unknown to the 

interagency community. The IFFC expanded in 2020 beyond its original focus on Iran to 

produce analysis of corporate networks conducting illicit activity, including corruption, bribery, 

and other financial crimes, in support of rogue actors in China, Russia, Lebanon, Syria, Bahrain, 

Venezuela, Malta, and Turkey. The IFFC’s unique methodology detected previously unreported 

illicit or suspicious activity, enhanced foreign engagement, and informed targeting efforts. 

The introduction of new government programs in response to COVID-19 and the economic 

distress caused by the pandemic resulted in an uptick in fraud and illicit activities. Treasury 

worked with the federal banking community to coordinate an interagency response and publish 

advisories for financial institutions (Advisories). 

In FY 2020, Treasury further expanded its role in cybersecurity through the creation of the Cyber 

Analysis Office, which worked with the governmental partners and major financial institutions to 

gather intelligence aimed at disrupting global cyber theft operations. OIA’s Cyber Analysis 

Office also augmented analytic resources to detect and analyze emerging trends in state and nonstate use of virtual currencies to undermine U.S. national security. In September 2020, TFI 

worked with the Department of Justice and Department of Homeland Security to sanction two 

Russian nationals for their involvement in a sophisticated phishing campaign that resulted in 

losses of at least $16.8 million in 2017 and 2018. 

Terrorism and Financial Intelligence Offices Supporting the AML/CFT Mission

The NDAA legislation codified practices that will enable Treasury to address key threats, 

including traditional methods of money laundering and emerging issues related to financial 

technology and virtual currency. The law also creates an expansive whistleblower rewards 

system that is expected to increase BSA enforcement. 

TFI also leveraged its partnerships to strengthen the international regulatory framework for 

AML/CFT. In FY 2020, Treasury strengthened its programs that were established during the 

U.S. presidency the FATF, the intergovernmental body that sets global AML/CFT standards. 

TFI led efforts focused on virtual currencies and the combating of terrorist financing and the 

financing of weapons of mass destruction, to strengthen the U.S. and international financial 

systems. Under Treasury’s leadership, the FATF revised its standards to also apply to virtual 

assets and virtual asset service providers. The revision included commitments from 205 

countries to comply with the FATF standards and to effectively regulate and supervise virtual 

asset service providers for anti-money laundering and counter the financing of terrorism. In 

addition, the FATF assisted countries in combating terrorist financing, which included training 
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prosecutors and judges from around the world on how to conduct terrorist financing 

investigations and prosecute terrorist financers. 

The FATF adopted new standards on proliferation financing and advanced work on COVID-19 

AML/CFT risks and trade-based money laundering. The enhancements on these standards 

ensures that jurisdictions around the world will equip their financial institutions and other 

covered entities with targeted information on proliferation financing risk that can be used to 

detect shell companies and other individuals or entities acting on behalf of designated persons. 

Treasury also augmented resources to detect and analyze emerging trends in state and non-state 

use of virtual currencies to undermine U.S. national security and led the G7 in producing an 

annex on ransomware in the Ministerial statement on digital payments. 

C– Evidence-Building Activity 

TFI is an organization of 900+ people in five independent but complementary offices that work 

together using tools and authorities, including sanctions, to achieve U.S. national security and 

foreign policy goals. This is done through strategies that employ our policy, law enforcement, 

intelligence, and regulatory tools to identify, disrupt, and dismantle threats, such as rogue 

regimes, terrorist organizations, human rights abusers, drug traffickers, money launders, 

proliferators of weapons of mass destruction, and more. Our comprehensive data analytics, 

regulatory reporting, foreign government information, and record keeping rules inform our 

approach to policy implementation, diplomatic engagement, sanctions, designation targets, and 

more. Similar sources of analytics and data are also used to ensure that the domestic and 

international financial systems are protected from abuse by illicit actors. 

Section III – Additional Information 

A – Summary of Capital Investments 

A summary of capital investment resources, including major information technology and nontechnology investments can be found at: 

https://www.treasury.gov/about/budget-performance/Pages/summary-of-capitalinvestments.aspx.