Department of the Treasury

Office of Terrorism and 

Financial Intelligence

Congressional Budget 

Justification and Annual 

Performance Report and Plan

FY 2021
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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 Table................................................................................................. 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................................................................... 9

A – Strategic Alignment ............................................................................................................. 9

B – Budget and Performance by Budget Activity ...................................................................... 9

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

Terrorism and Financial Intelligence Budget and Performance ............................................... 11

C – Changes in Performance Measures.................................................................................... 16

D – Evidence-Building Activity ............................................................................................... 19

Section III – Additional Information ........................................................................................ 19

A – Summary of Capital Investments....................................................................................... 19
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Section I – Budget Request

A – Mission Statement

Strengthen national security by using targeted financial measures to combat threats and protect 

the integrity of the financial system.

B – Summary of the Request 

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.

1.1 – Appropriations Detail Table

Note: FTE = Full-time Equivalent employment

Dollars in Thousands

Appropriated Resources

New Appropriated Resources FTE AMO UNT FTE AMO UNT FTE AMO UNT FTE AMO UNT

Terrorism and Financial Intelligence 440 $159,000 526 $169,712 575 $172,751 9.3% 1.8%

Subtotal New Appropriated Resources 440 $159,000 526 $169,712 575 $172,751 9.3% 1.8%

O ther Resources

Reimbursable 40 $8,000 41 $8,000 41 $8,000 0.0% 0.0%

Subtotal O ther Resources 40 $8,000 41 $8,000 41 $8,000 0.0% 0.0%

Total Budgetary Resources 480 $167,000 567 $177,712 616 $180,751 8.6% 1.7%

% Change

FY 2019 FY 2020 FY 2021 FY 2020 to FY 2021

O perating Plan Enacted Request
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1.2 – Budget Adjustments Table

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

C – Budget Increases and Decreases Description

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.
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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 

Treasury Foreign Intelligence Network (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 and 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 cyberenabled 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) 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.
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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).
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1.3 – Object Classification (Schedule O) Obligations

 Amounts reflect obligations of annually appropriated resources, carryover balances, reimbursables, and transfers.

Dollars in Thousands

FY 2019 FY 2020 FY 2021

O bject Classification

Actual

O bligations

Estimated

O bligations

Estimated

O bligations

11.1 - Full-time permanent 57,132 69,145 76,035

11.3 - Other than full-time permanent 601 556 556

11.5 - Other personnel compensation 1,381 1,078 1,078

11.9 - Personnel Compensation (Total) 59,114 70,779 77,669

12.0 - Personnel benefits 18,307 22,637 24,084

Total Personnel and Compensation Benefits $77,421 $93,416 $101,753

21.0 - Travel and transportation of persons 2,434 3,969 3,665

22.0 - Transportation of things 98 0 2

23.2 - Rental payments to others 177 0 4

23.3 - Communications, utilities, and miscellaneous charges 15 67 712

24.0 - Printing and reproduction 19 0 0

25.1 - Advisory and assistance services 21,505 25,717 21,514

25.2 - Other services from non-Federal sources 1,718 533 2,121

25.3 - Other goods and services from Federal sources 44,695 47,680 45,900

25.4 - Operation and maintenance of facilities 9 0 0

25.7 - Operation and maintenance of equipment 328 399 538

25.8 - Subsistence and support of persons 5 0 0

26.0 - Supplies and materials 2,672 2,321 2,197

31.0 - Equipment 5,965 3,540 1,989

32.0 - Land and structures 4,322 70 356

Total Non-Personnel $83,962 $84,296 $78,998

Total O bligations $161,383 $177,712 $180,751

0

Full-time Equivalents (FTE) 480 567 616
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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, [$169,712,000] $172,751,000, 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, 

[2021] 2022. (Department of the Treasury Appropriations 

Act, 2020.)

E – Legislative Proposals

The Office of Terrorism and Financial Intelligence has no legislative proposals.
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Section II – Annual Performance Plan and Report

A – Strategic Alignment

TFI programs support the following Department of the Treasury’s Strategic Plan for FY 2018-

2022. Strategic objectives for Strategic Goal 3, to enhance national security: 

• Objective 3.1 – Strategic Threat Disruption: Identify, dismantle, and disrupt priority threats 

to the U.S. and international financial system. 

• Objective 3.2 – AML/CFT Framework: Identify and reduce vulnerabilities in the U.S. and 

international financial system to prevent abuse by illicit actors. 

• Objective 3.3 – Economic Strength and National Security: Advance American prosperity and 

security through growth, investment, trade, and expanding the American industrial base 

while protecting national security. 

TFI programs support the following strategic objectives for Strategic Goal 5, to achieve 

operational excellence: 

• Objective 5.1 – Workforce Management: Foster a culture of innovation to hire, engage, 

develop, and optimize a diverse workforce with the competencies necessary to accomplish 

our mission.

• Objective 5.2 – Treasury Infrastructure: Better enable mission delivery by improving the 

reliability, security, and resiliency of Treasury’s infrastructure.

B – Budget and Performance by Budget Activity

2.1.1 – Terrorism and Financial Intelligence Resources and Measures

Dollars in Thousands

FY 2015 FY 2016 FY 2017 FY 2018 FY 2019 FY 2020 FY 2021

 Resource Level Actual Actual Actual Actual Actual Enacted Request

Appropriated Resources $112,500 $117,000 $123,000 $141,778 $159,000 $169,712 $172,751 

Other Resources $6,966 $6,329 $6,491 $8,626 $7,756 $8,000 $8,000 

Budget Activity Total $119,466 $123,329 $129,491 $150,404 $166,756 $177,712 $180,751 

Full-time Equivalents (FTE) 385 414 428 444 480 567 616 

*Note: FY 2015 - FY 2019 Other Resources dollars are actuals. FY 2015 - FY 2019 FTE are actuals.

FY 2015 FY 2016 FY 2017 FY 2018 FY 2019 FY 2020 FY 2021

Measure Actual Actual Actual Actual Actual Target Target

New or Modifications to Existing 

Sanctions Programs

N/A N/A 5 5 7 I DISC

Number of Designation Actions N/A N/A 867 1431 1120 I DISC

Analytic Intelligence Support N/A N/A 385 523 637 I DISC

Review and Support of Foreign 

AML/CFT Laws and Regulations 

N/A N/A 49 64 81 I DISC

N/A: Not available; DISC: Discontinued; I: Indicator 

New measures are being introduced in FY 2020. Refer to Section C for justification. 
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Description of TFI’s Performance:

As described more fully above, TFI has strategically and tactically deployed all available 

economic tools and authorities to disrupt and counter key national security challenges. TFI 

focuses its resources on those actions that are most likely to create the greatest impact towards a 

stated program objective. Therefore, the number of actions taken cannot serve as a single 

determination of effectiveness, complexity, or level of resources required to complete the action. 

For instance, as TFI takes action against larger entities or individuals that are integrated into and 

impact global supply chains, the level of resources and complexity of planning for the action 

increases substantially. For each action, resources are required to monitor collateral impacts, 

issue required licenses, engage with the public to answer questions, participate in bilateral and 

multilateral exchanges to ensure international support for actions, meet reporting requirements in 

a timely manner, monitor for potential evasion, and execute all required regulatory changes, 

among other things. Workload indicators tracked in FY 2019 were the following: 

• 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. 

• 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 antimoney 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 
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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.

TFI proposes to create 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 deconfliction 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. See Section C for changes in performance measures and indicators.

Terrorism and Financial Intelligence Budget and Performance

($172,751,000 from direct appropriations, $8,000,000 from reimbursable resources):

TFI serves a distinct role in enhancing national security by deploying Treasury’s tools and 

authorities to protect the U.S. and international system from abuse and by combating rogue 

regimes, terrorist facilitators, weapons proliferators, money launderers, drug kingpins, human 

rights abusers, cyber criminals and other illicit finance and national security threats. TFI does 

this by strategically applying the policy, law enforcement, intelligence, and regulatory tools, and 

authorities of its components in a calibrated manner to achieve maximum impact. In FY 2019, 

TFI successfully applied its diverse targeted financial measures, including financial sanctions 

and regulatory tools that address major national security challenges. These challenges include 

North Korea, Iran, Russia, Syria, Venezuela, ISIS, al-Qai’da, Hizballah, human rights violators 

and others. In an effort to identify, disrupt, and dismantle these threats, TFI was able to deny 

revenue sources to these illicit actors and organizations.

North Korea

In the past year, TFI has supported the Administration’s goal to achieve the final, fully verified 

denuclearization of North Korea by maintaining pressure on North Korea’s finances and 

economy, thereby stemming the flow of illicit revenue to its weapons program which continues 

to pose a threat to global security. TFI deploys a variety of financial tools and authorities to curb 

the North Korean threat, including sanctions; measures for anti-money laundering and countering 

the financing of terrorism (AML/CFT); regulatory actions under Section 311 of the United and 

Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct 

Terrorism Act of 2001 (USA PATRIOT Act); foreign engagement; and private sector 

partnerships; among other actions. 

In 2019, TFI targeted illicit actors serving as gateways for North Korea to access the 

international financial system. This includes targeted DPRK illicit efforts aimed at schemes used 
TFI - 12

to evade U.S. and UN sanctions, launder funds, and finance the regime’s weapons of mass 

destruction and ballistic missile programs. 

Overall, in FY 2019, TFI has sanctioned more than 20 individuals, entities, and vessels related to

North Korea. This economic pressure campaign has created the conditions to bring the U.S. and

North Korea to the negotiating table to finally achieve fully verifiable denuclearization with the

hope of bringing peace to the Korean peninsula. 

Iran

Treasury continues to play a leading role in the implementation of the Administration's Iran 

policy. Treasury's actions have disrupted the Iranian regime's ability to fund its broad range of 

malign activities, including supporting its proxies Hizballah and Hamas. Following the 

Administration’s decision to fully re-imposed the nuclear-related sanctions that had been lifted or 

waived under the Joint Comprehensive Plan of Action (JCPOA), in November 2018, Treasury 

took the largest single-day action by sanctioning over 700 individuals, entities, aircraft, and 

vessels. Treasury followed that up through a variety of targeted financial measures that disrupt 

funding sources such as oil, its primary source of funds, as well as other areas such as banking, 

petrochemicals, shipping, and metals. Treasury re-imposed U.S. sanctions on the Iranian regime

and has continued to apply pressure to reduce Iran’s capacity to continue its support for

terrorism, human rights abuses, ballistic missile proliferation, destabilizing activities, and support

of militant groups. Sanctions have included designations of the then-Governor of the Central

Bank of Iran for conspiring with the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF)

to conceal the movement of millions of dollars to enrich and support Hizballah; individuals and

entities supporting Mahan Air, an airline previously designated for its support to terrorism, and a

currency exchange network that was funneling millions of dollars to the IRGC-QF.

Of note, in September 2019, Treasury designated the Central Bank of Iran, National 

Development Fund, and Etemad Tejarate Pars Co. under its counterterrorism authority for its 

support of Hizballah and IRGC-Qods Force. In addition, as of the end of FY 2019, TFI has

issued sanctions on 450 individuals and entities for a range of activities related to terrorism,

proliferation, and human rights abuses, and to thwart Iran’s exploitation of the global financial

system. In addition to sanctions, TFI continues to deploy other tools to achieve maximum

pressure on Iran to hold Iran accountable for its destabilizing activities. For example, TFI

recently issued advisories to financial institutions detailing Iran’s efforts to deceive legitimate

businesses, including through the use of front and shell companies, to fund its malign activities. 

Likewise, Treasury officials have traveled the world, meeting with officials in dozens of

countries to warn them of Iran’s illicit activities and garner their support for our pressure

campaign.

Russia

TFI has also undertaken a comprehensive and strategic financial pressure campaign to counter

the scale and sophistication of Russia’s malign activities. TFI has strategically deployed tools to

maximize financial pressure on the Kremlin while minimizing unintended consequences within

the international financial system. These efforts have included a robust sanctions program,

enforcement actions, foreign engagement, and private sector partnerships to deter their illicit

activity. During FY 2019, the Administration sanctioned 58new individuals or entities,
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including 18 designated under Ukraine/Russia-related sanctions under the Countering America's

Adversaries Through Sanctions Act. TFI sanctioned powerful Russian oligarchs and many of the

companies they own or control. 

Counter-Terrorism

TFI’s financial tools are also making an impact in the fight to combat terrorism, to include ISIS,

al-Qai’da, Hizballah, Hamas, the Taliban and others. The Office of Terrorist Financing and 

Financial Crimes (TFTC), introduced in FY 2017, was created to disrupt the financing of terror

through the sharing of intelligence and coordinated actions between the U.S. and six Gulf

country partners—Saudi Arabia, Bahrain, Qatar, Kuwait, Oman, and the United Arab Emirates—

as well as through capacity building. In FY 2019, TFTC conducted two rounds of multilateral

designations. These designations were put into place to expose and disrupt Taliban actors and

their Iranian sponsors that seek to undermine the security of the Afghan Government and to

additionally disrupt an Iranian-backed terrorist group by designating the senior leadership of

Lebanese Hizballah. Additionally, TFI led discussions and training sessions with Gulf partners

on regional terrorist financing issues.

 

Beyond coordinated sanction actions, TFI continued targeting Hizballah and its supporters,

including leadership, operatives, facilitators, financiers, investors, and key global procurement

networks. In FY 2019, TFI conducted 33 Hizballah-related sanction designations, and saw more

designations in calendar year 2019 by the Departments of State and the Treasury than in any

single prior year. 

Venezuela

The U.S. along with other international partners have applied unprecedented financial pressure

on the Maduro regime in Venezuela in light of the actions and policies of the Government of

Venezuela, including serious abuses of human rights and fundamental freedoms; the deepening

humanitarian crisis in Venezuela; establishment of an illegitimate Constituent Assembly;

rampant public corruption; and ongoing repression and persecution of, and violence toward, the

political opposition. Specifically, Treasury has designated over 200 individuals and entities

pursuant to its sanctions authorities, including state-owned oil company, PDVSA, and former

President Maduro and members of his inner circle, cutting them off from the U.S. financial

system. TFI will continue to impose financial constraints on those responsible for Venezuela’s

severe decline and the illicit financial networks used to mask their wealth.

Human Rights

TFI has also applied our tools and authorities to combat corruption and human rights abuses

through the Global Magnitsky Human Rights Accountability Act. In FY 2019 under this

program, TFI has sanctioned approximately 30 individuals and entities for serious human rights

abuse and/or corruption. Consistent with the growing human rights-related workload and

Congress’s focus on these areas, TFI will continue to take action against human rights and

corruption related targets around the globe, including implementing sanctions under Global

Magnitsky and other authorities, and will continue to assess the impact of these activities on

TFI’s mission.
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Financial Action Task Force (FATF)

TFI has also focused on improving systemic enhancements to the global financial system,

including Treasury's assumption of the presidency of the Financial Action Task Force (FATF),

the AML/CFT standard setting body, from July 2018 through June 2019. TFI set three priorities

during its term:

• Clarifying how the FATF standards on regulation and supervision apply to virtual currency

service providers to mitigate the use of virtual currencies by illicit actors;

• Maintaining the FATF's emphasis on combating terrorist financing; and

• Enhancing FATF's work on preventing the financing of the proliferation of weapons of mass

destruction.

During FY 2019, Treasury participated in FATF peer review processes of ten countries. These

comprehensive AML/CFT assessments evaluate countries against the FATF standards for both

technical compliance and effective implementation. FATF also clarified how its standards apply

to virtual asset service providers, which include virtual currency exchangers and administrators.

TFI led the FATF to adopt new standards that require countries around the world to regulate and

supervise virtual currency providers for AML/CFT. TFI also led U.S. efforts to issue guidance

on how countries can effectively regulate and supervise virtual currency providers. Additionally,

TFI, through the Office of Terrorist Financing and Financial Crimes (TFFC), worked with the

United Nations to incorporate into international law the FATF standard that countries prohibit

any funds to terrorists and/or terrorist organizations even without any link to a specific terrorist

act.

In FY 2019, TFI led FATF to foster improved information-sharing between governments and

between financial institutions to put both in a better position to detect, deter, and disrupt illicit

finance, one effort among many that will continue into FY 2020 and beyond.

Under the U.S. Presidency of the FATF, two key U.S. allies became full members of the FATF. 

In addition, due in part to TFI leadership, the FATF under the U.S. Presidency agreed to impose

countermeasures on Iran for the first time in three years. 

Throughout FY 2020 and FY 2021, TFI will focus heavily on strategically deploying its tools

and authorities for maximum impact against national security and foreign policy challenges, as

well as addressing risks to and vulnerabilities within the U.S. and international financial system. 

TFI will continue to focus on applying targeted financial measures against North Korea, Iran,

Russia, and Venezuela, in addition to identifying, disrupting, and dismantling terrorist

organizations, drug kingpins, transnational criminal organizations, and other threats to the U.S.

and our international partners.

Terrorism and Financial Intelligence Offices Supporting the AML/CFT Mission

This budget request supports three of the four components within TFI that exercise AML/CFT 

authorities and responsibilities. The fourth component, Financial Crimes Enforcement Network, 

reports directly to the Under Secretary for TFI but is budgeted separately as a bureau within the 

Treasury.
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Office of Terrorist Financing and Financial Crimes (TFFC)

TFFC is responsible for formulating and coordinating comprehensive strategies to target national 

security and foreign policy threats and safeguard the U.S. and international financial systems 

from abuse. In performing its mission, TFFC works across TFI, as well as interagency and law 

enforcement, to ensure that Treasury’s tools are strategically applied and calibrated for 

maximum impact against global threats such as North Korea, Iran, Venezuela, Russia, ISIS and 

Hizballah, among others. TFFC also leads the development of AML/CFT regulatory and 

outreach initiatives and collaborates with Federal law enforcement on financial crime 

methodology analysis. Domestically, TFFC performs a critical role in working with key 

stakeholders to increase the security of our financial systems, leading public-private sector 

dialogues, financial experts meetings, and other strategic initiatives to identify and address 

potential vulnerabilities. TFFC also serves as the primary interlocutor with international partners 

whether on a bilateral basis or in multi-lateral fora to enhance information sharing, advance 

systemic reforms, synchronize targeted actions, and increase pressure on other countries to 

address specific illicit finance concerns in line with U.S. national security priorities. TFFC 

serves as the head of the U.S. Delegation to the Financial Action Task Force, the international 

body that sets standards and promotes effective implementation of AML/CFT legal, regulatory

and operational measures that protect the integrity of the international financial system. The 

United States held the FATF Presidency from June 2018-June 2019, and TFFC’s Assistant 

Secretary served in that role. Throughout this time period, he and his staff spent months 

determining FATF priorities, working with member countries, and organizing the week long 

FATF plenary, which took place in Orlando, FL in June 2019. TFFC is also leading Treasury’s 

efforts to operationalize the Terrorist Financing Targeting Center.

Office of Intelligence and Analysis (OIA)

As one of 17 members of the U.S. Intelligence Community (IC), OIA is responsible for 

informing Treasury decisions with timely, relevant, and accurate intelligence and analysis of 

financial networks and illicit actors. It supports this mission by: producing all-source 

intelligence analysis that identifies threats to and vulnerabilities within the international financial 

system; driving and delivering intelligence that meets the needs of Treasury decision makers; 

and providing the security infrastructure to protect Treasury’s physical and information security 

apparatus. OIA’s efforts inform and support the Department’s ability to address illicit finance 

and national security threats, including Iran, North Korea, Russia, ISIS, al-Qaida, and illicit 

cyber actors. OIA works with the Office of the Director of National Intelligence and other IC 

agencies to help ensure the Department’s intelligence needs are met. OIA’s security office 

ensures that all necessary Treasury personnel are properly trained to safeguard information 

systems and infrastructure. OIA’s security office also maintains counterintelligence and insider 

threat programs designed to deter, detect, and mitigate foreign intelligence and insider threats to 

Treasury. 

Office of Foreign Assets Control (OFAC)

OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and 

national security goals against over 40 targeted foreign countries and regimes, terrorists, 

international narcotics traffickers, those engaged in activities related to the proliferation of 

weapons of mass destruction, and other threats to the national security, foreign policy, or 

economy of the United States. OFAC acts under Presidential national emergency powers, as 
TFI - 16

well as authority granted by specific legislation, to impose controls on transactions and freeze 

assets under U.S. jurisdiction. Many of the sanctions are based on United Nations and other 

international mandates, are multilateral in scope, and involve close cooperation with allied 

governments. OFAC vigorously enforces the sanctions programs it administers, and conducts 

civil enforcement investigations against U.S. and non-U.S. individuals and entities who threaten 

the integrity of its sanctions programs. OFAC’s enforcement actions and activities – including 

civil monetary penalties, non-public disruptive intervention, and public outreach – illuminate 

evasion schemes and enlist the private sector in its sanctions efforts. Additionally, OFAC 

administers a licensing program through which it reviews and then authorizes or denies requests 

to conduct certain transactions or activities that would otherwise be prohibited. OFAC is 

continually evaluating and adjusting its sanctions programs to ensure that it is prohibiting illicit 

activity, while allowing activity that is consistent with or advances U.S. national security and 

foreign policy.

C – Changes in Performance Measures

In 2019 new measures and indicators were determined by a working group between Treasury and 

TFI to effectively measure the growing workload of TFI and better align with enhanced reporting 

across Treasury bureaus and offices. These will be reflected in the FY 2022 Budget tables. 

Performance Measure 

or Indicator

Proposed Change and Justification Indicator/ Measure

1. Number of new 

sanctions 

programs 

modified by EO or 

Congressional 

mandate during 

the fiscal year 

This indicator measures new actions or 

expansion of existing sanction programs. 

The creation of sanctions programs 

requires a significant upfront dedication 

of policy, legal, and regulatory resources 

to ensure proper coordination and 

documentation of the changes. Previously 

TFI reported New or Modificaitons to 

Existing Sanctions programs but the 

indicator has been spilt and refined to 

better capture TFI workload. The data is 

collected by OFAC.

Indicator

2. Number of 

sanctions 

programs 

modified by EO or 

Congressional 

mandate during 

the fiscal year 

This indicator measures actions or 

expansion of existing sanction programs. 

The modification of sanctions programs 

requires a significant upfront dedication 

of policy, legal, and regulatory resources 

to ensure proper coordination and 

documentation of the changes. Previously 

TFI reported New or Modifications to 

Indicator
TFI - 17

Existing Sanctions programs but the 

indicator has been spilt and refined to 

better capture TFI workload. The data is 

collected by OFAC.

3. Regulatory 

documents 

published in the 

Federal Register 

within four 

months of 

publication of an 

Executive order or 

Congressional 

mandate during 

the fiscal year 

(Target 75%)

This measure ensures that OFAC 

publishes regulatory documents related to 

sanctions in a timely manner. The 

preparation for regulatory documents can 

be complex and include several lines of 

effort across OFAC. The data is collected 

by OFAC. 

Performance Measure

4. Designations and 

identifications 

released on time to 

the public without 

errors 

(Target 90%)

This performance measure captures the 

number of actions taken to impose 

sanctions without errors. The preparation 

for each action is exceedingly complex 

and requires several lines of effort. In 

2020 Congressional Justification (CJ)

TFI reported the indicator number of 

designation actions but now is 

performance measure with a target.

Designations released on time and 

without errors strengthens effectiveness 

of US sanction programs. The data is 

collected from OFAC.

Performance Measure

5. Conduct outreach 

events for the 

other US 

government 

agencies, the 

public, the 

business sector, 

and foreign 

government per 

calendar year 

(Target 60 events)

For TFI to be successful in their mission 

involvement and buy-in with the private 

sector and government officials is 

necessary. This performance measure 

tracks the amount of outreach events 

conducted by TFI. 

Performance Measure
TFI - 18

6. Participation in 

FATF 

international 

mutual evaluations

and follow up 

reports)

FATF Mutual Evaluations are peer 

evaluations of countries’ levels of 

effectiveness and implementation of the 

FATF AML/CFT Standards. 

Additionally, the metric includes reviews 

and comments on reports produced by 

the nine FSRBs; and, work assessing and 

reviewing countries as part of the ICRG. 

Participation on mutual evaluations 

usually requires several extended on-site 

visits in country, extensive analysis of a 

country’s AML/CFT system. Previously 

TFI reported Review and Support of 

Foreign AML/CFT laws and regulations 

in the CJ. The modified indicator 

includes FATF ME and follow-up reports

which better represents TFI workload.

The data is collected from TFFC.

Indicator

7. Number of 

roundtables with 

private sector on 

ML/TF threats, 

vulnerabilities, 

and risk

This indicator measures the number of 

roundtables with the private sector TFFC 

conducts. Roundtables contribute to the 

success of TFI mission since private 

sector buy-in support compliance. The 

data is collected by TFFC. 

Indicator

8. # of 

overseas/domestic 

engagements with 

foreign officials 

by TFFC officials 

TFFC is tasked with the majority of the 

outreach and engagement with private 

sector and foreign officials. This 

indicator tracks the number of 

engagement with foreign officials. The 

data is collected by TFFC. 

Indicator

9. Respond to deconfliction 

requests received 

from law 

enforcement 

(target: TBD)

OFAC is tasked with providing a timely 

response to law enforcement agencies 

regarding conflicts in law enforcement 

information.The data is collected by 

OFAC. 

Performance Measure
TFI - 19

10. Number of 

security clearances 

processed 

This indicator reports the number of 

security clearances processed by OIA’s 

Office of Security Programs (OSP). The 

data is collected by OIA. 

Indicator

11. Number of 

analytic products 

published 

(includes Number 

of IIRs published, 

Number of 

finished 

intelligence pieces 

published) 

This indicator includes both formal 

analytical intelligence briefings and final 

analytical intelligence products that were 

published. In the 2020 CJ for TFI, OIA 

reported Analytical Intelligence Support 

published but the indicator has been 

modified to include the vast array of OIA 

products. The data is collected from 

OIA.

Indicator

12. Percent Customer 

Satisfaction with 

OIA products 

(performance 

measure)

OIA products are rated by customers 

using a survey. The rating help OIA 

improve the quality of products and 

customer support. The information is 

collected from OIA.

Performance measure

D – Evidence-Building Activity

TFI is an organization of 800+ people in five independent, but complimentary offices that work 

together using its tools and authorities, including sanctions, to enhance national security. This is 

done by applying policy analysis, law enforcement information, intelligence analysis, and 

regulatory tools in understanding and addressing threats such as rogue regimes, terrorist 

organizations, human rights abusers, drug traffickers, money launders, proliferators of weapons 

of mass destruction (WMDs) and more. Analytics and other information—regulatory reporting, 

foreign government information, and record keeping rules— inform our approach to policy 

implementation, diplomatic engagement, and sanctions and 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:

http://www.treasury.gov/about/budget-performance/Pages/summary-of-capital-investments.aspx

This website also contains a digital copy of this document.