Department of the Treasury

Office of Terrorism and 

Financial Intelligence

Congressional Budget 

Justification and Annual 

Performance Report and Plan

FY 2020
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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 – Operating Levels................................................................................................................ 8

D – Appropriations Language and Explanation of Changes ...................................................... 9

E – Legislative Proposals............................................................................................................ 9

Section II – Annual Performance Plan and Report................................................................. 10

A – Strategic Alignment ........................................................................................................... 10

B – Budget and Performance by Budget Activity .................................................................... 10

2.1.1 – Terrorism and Financial Intelligence Resources and Measures ................................... 10

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

C – Changes in Performance Measures.................................................................................... 18

Section III – Additional Information ........................................................................................ 18

A – Summary of Capital Investments....................................................................................... 18
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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 2020 Budget Request 

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

Achieve Operational Excellence.

TFI requests $166.712 million, which is a $24.934 million increase from the FY 2019 

Annualized Continuing Resolution. 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, 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

Dollars in Thousands

Terrorism and Financial Intelligence

Appropriated Resources

New Appropriated Resources FTE AMOUNT FTE AMOUNT FTE AMOUNT FTE AMOUNT FTE AMOUNT

Terrorism and Financial Intelligence 495 $141,778 495 $141,778 545 166,712 50 $24,934 10.10% 17.59%

Subtotal New Appropriated Resources 495 $141,778 495 $141,778 545 $166,712 50 $24,934 10.10% 17.59%

Other Resources

 Transfer-out to Departmental Offices S&E 0 ($31,452) 0 ($31,452) 0 0 0 $31,452 NA 11.58%

 Payments to Treasury Franchise Fund 0 $0 0 $0 0 ($35,094) 0 ($35,094) NA NA

 Reimbursables 36 $8,626 36 $8,626 36 $8,626 0 $0 0.00% 0.00%

Subtotal Other Resources 36 ($22,826) 36 ($22,826) 36 ($26,468) 0 $0 0.00% 15.96%

Total Budgetary Resources 531 $118,952 531 $118,952 581 $140,244 50 $21,292 9.42% 17.90%

FY 2018 FY 2019 FY 2019 to FY 2020

Enacted Annualized CR Request Change % Change

FY 2020

⃰FY 2018 shows actual FTE usage. This column reflects levels appropriated in P.L. 115-141 Consolidated Appropriations Act,

2018. For further details on the execution of these resources see the FY 2020 Appendix chapter for the Department of the 

Treasury.
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1.2 – Budget Adjustments

Terrorism and Financial Intelligence FTE Amount

FY 2019 Annualized CR 495 $141,778

Changes to Base:

Maintaining Current Levels (MCLs) 0 $1,553

Non-Pay 0 $1,553

Efficiency Savings 0 ($3,830)

Subtotal Changes to Base 0 ($2,277)

Total FY 2020 Base 495 $139,501

Program Changes:

Program Increases: 50 27,211

Operations and Maintenance (O&M) of Prior-year 

Enterprise-w ide Cybersecurity investments 0 $2,277

Terrorist Financing Targeting Center 10 $6,211

Terrorist Finance and Financial Crimes 2 $530

TFI National Security Programs 27 $6,634

Committee on Foreign Investment in the United States 3 $859

IT Infrastructure Investments 8 $10,700

Total FY 2020 Request 545 $166,712

Dollars in Thousands

C – Budget Increases and Decreases Description

Maintaining Current Levels (MCLs) ......................................................+$1,553,000 / +0 FTE

Non-Pay +$1,553,000 / +0 FTE 

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

equipment.

Efficiency Savings.........................................................................................-$3,830,000 / -0 FTE

TFI Contractual Support -$3,830,000 / +0 FTE 

TFI will achieve cost savings and efficiencies in contract services through more efficient 

oversight of all TFI contracts, consolidating contracts where appropriate, and partnering with 

other agencies and DO components to leverage common technology or administrative support 

needs.

Program Increases .................................................................................+$27,211,000 / +50 FTE

O&M of Prior-Year Enterprise-wide Cybersecurity Investments +$2,277,000 / +0 FTE 

This request includes funding to support O&M for prior-year Cybersecurity Enhancement 

Account investments. O&M will be funded by Treasury Bureaus through Treasury Franchise 

Fund billing. This increase represents the TFI portion of the $17.5 million O&M total.
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Terrorist Financing Targeting Center +$6,211,000 / +10 FTE

On May 21, 2017, the United States and the six Gulf Cooperation Council countries signed an 

historic agreement announcing a joint commitment to establish the Terrorist Financing Targeting 

Center (TFTC). The TFTC’s efforts support the Administration’s priorities to fight terrorism in 

new and innovative ways through a multilateral initiative that will dramatically increase the 

ability to curb terrorist financing. The TFTC has already resulted in greater regional cooperation 

as evidenced by the sharing of intelligence, the capacity building, and the joint designations by 

the seven participating members of TFTC that targeted terrorist leaders, financiers, and 

facilitators. The TFTC will continue to disrupt the finances and operations of terrorist 

organizations by identifying, tracking, and sharing information regarding terrorist financial 

networks; coordinating joint disruptive actions, like sanctions; and offering support to countries 

in the region that need assistance building capacity to counter terrorist finance threats.

Terrorist Finance and Financial Crimes +$530,000 / +2 FTE

TFI requests two FTEs to develop and build global capacity to combat illicit financing in the 

international arena. These FTEs will be responsible for establishing strategies and employing 

targeted financial measures to disrupt and dismantle the financial networks that support 

terrorism, proliferation of weapons of mass destruction, and organized crime. 

TFI National Security Programs +$6,634,000 / +27 FTE 

Treasury requests additional staffing to support its ever-increasing role in the Administration's 

efforts to apply economic pressure in pursuit of national security and foreign policy goals. This 

has included the use of unilateral designations and other economic authorities, as well as 

working with other countries to increase multilateral economic pressure and continuous 

interaction with the financial and private sector through advisories and engagement to cut off 

malign actors’ access to the international financial system. As the number of sanctions programs 

continues to grow, there is a crucial need for increasing intelligence, policy, and targeting staff to 

identify and take impactful actions against the individuals, entities, and their networks 

responsible for this dangerous and malign behavior. Many of these actors have complex 

business structures that are well-integrated into the global markets, which requires additional 

analysis and post-designation support to ensure that the actions have maximum impact on malign 

activity while minimizing the collateral damage to U.S. businesses and our allies.

This requested staffing increase will address personnel needs, including Virtual Currency, Cyber, 

Iran, Russia, Human Rights/Corruption, and Counterterrorism Programs. These are high priority 

areas for the Administration and Treasury and constitute the majority of taskings and 

requirements levied upon TFI and its component offices. Below are some highlights of TFI’s 

activities.

• The use of virtual currency is expanding rapidly with instances of its use having been 

identified in many key sanctions programs, including Russia, Iran, and Venezuela. This 

request will help support additional intelligence, targeting, and policy expertise to ensure that 

TFI and Treasury remain well positioned to stay ahead of emerging financial threats in this 

space. 

• TFI will increase intelligence, policy, and targeting personnel to support the Administration’s 

priority in countering Iran’s malign behavior and Russia’s destabilizing activities. This 
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includes Treasury’s ongoing efforts to implement the Countering America’s Adversaries 

Through Sanctions Act (CAATSA) targeting and reporting requirements. The 

Administration remains committed to countering the threat posed by Iran by using Treasury’s 

economic authorities to deny the regime and the Islamic Revolutionary Guard funding for 

malign activities, including its support for terrorism and regional destabilization in Yemen 

and Syria. Treasury’s Russia-related sanctions program remains a top priority as well, with 

strategic, complex actions that target key actors across the full range of Russian malign 

activity, to include malign cyber activities, interference in democratic elections, aggressive 

behavior in Ukraine, and purported illegal annexation of Crimea as well as its continued 

support for the Assad regime. 

• The December 2017 Executive Order implementing the Global Magnitsky Act highlights 

Treasury’s critical role in identifying and financially isolating those who destabilize countries 

and regions by pilfering the wealth and resources of their nation or commit human rights 

abuse and atrocities. TFI’s use of these authorities has already impacted individuals across 

the globe and changed the way regimes are operating, directly advancing objectives outlined 

in the National Security Strategy. These funds will support TFI in supporting policy, 

intelligence, and targeting efforts in this program. 

• TFI monitors and takes action against numerous terrorist entities across the globe, an effort 

that has become increasingly complex as terrorist groups continue to splinter and fracture 

into more independently operated organizations. This request will assist in supporting TFI’s 

efforts in maintaining persistent pressure to disrupt the financing of these terrorist 

organizations.

Committee on Foreign Investment in the United States +859,000 / +3 FTE

CFIUS is an inter-agency committee authorized to review transactions that could result in control 

of a U.S. business by a foreign person, in order to determine the effect of such transactions on 

the national security of the United States. Additional TFI resources are required to meet the 

increase in the CFIUS caseload. 

IT Infrastructure Investments +$10,700,000 / +8 FTE 

Treasury Financial Intelligence Network (TFIN) +$4,498,000 / +2 FTE

• IT Infrastructure upgrade. Increases bandwidth on existing infrastructure in support of the 

TFI expansion and build a more robust capability for the TFI collaborative data discovery 

initiative. Currently, TFI’s virtual desktop infrastructure is not sufficient to support the new 

demands of data analytics. Without more processing power, TFIN users will continue to lack 

the ability to query certain databases or effectively utilize analytic tools, undermining OIA’s 

ability to support TFI efforts to identify, disrupt, and dismantle threats to the United States 

and international financial system.

• TFIN Network Defense. Enhances the ability to monitor the classified Network against 

cyber threats by incorporating more comprehensive and integrated risk and threat 

management. Without enhanced network defense capabilities, Treasury’s classified network 

may potentially be vulnerable to cyber threats like network intrusions, malicious actors, or 

other vulnerable exploits. Cyber defense services are critical components to detect, monitor, 

and analyze TFIN network elements to keep our organization’s data center healthy and 

functional.
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• Multi-factor Authentication (MFA). Creates a layered defense and make it more difficult 

for an unauthorized person to access a target such as a physical location, computing device, 

network, or database. Failure to effectively use current MFA technologies on TFIN would 

result in vulnerable computing devices, networks, or databases

• Cross Domain - One Way Transfer (OWT). Implements the OWT system that provides 

secure transfer of data between the unclassified domain to that of a higher security level 

using proven technology that automatically scans files for viruses. Manually transferring 

data is cumbersome, time consuming, and often impacts data confidentiality, integrity, and 

availability. OWT systems reduce the amount of time currently required to transfer data 

from lower to higher classification systems.

User Activity Monitoring (UAM) on Unclassified Bureau Networks +$3,047,000 / +4 FTE

Rapid technological advances are allowing a broad range of foreign intelligence entities (FIEs) to 

field increasingly sophisticated capabilities and aggressively target the government, including 

Treasury. FIEs are proactive and use creative approaches—including malicious insiders 

threats—to advance their interests and gain advantage over the United States. To mitigate these 

threats, the Office of Counterintelligence (OCI) must drive innovative counterintelligence (CI) 

and insider threat solutions to include implanting more effective monitoring solutions. This 

request includes funding for UAM licenses, hardware, software, and professional services, as 

well as additional insider threat analysts and CI investigators. Treasury Order 105-20 (Revised) 

will give the OCI the authority to monitor all cleared users on unclassified networks. As 75 

percent of Treasury's cleared population is employed by the bureaus, and the exfiltration of 

sensitive information is most likely to occur on an unclassified network, this is a critical need. 

This deployment will cover over 100,000 endpoints and collect activity data on approximately 

5,000 employees. The additional analysts and investigators will support this expanded effort, as 

well as the launch of Treasury’s Insider Threat Reporting Guidelines, which will be disseminated 

Department-wide and require all Treasury employees and insider threat stakeholders to report CI 

and insider threat indicators; OCI anticipates a significant increase in CI and insider threat 

reporting due to its publication. The overall increased workload will greatly exceed levels 

manageable with current Insider Threat Program staffing. 

OFAC-wide IT Infrastructure +3,117,000 / +2 FTE

• Enhancement to the OFAC Administrative System for Investigations and Sanctions 

(OASIS) to aid with TAR Processing. Further automates the Terrorist Assets Report (TAR) 

to Congress by enabling the electronic upload of data from financial institutions directly into 

Office of Foreign Assets Control’s (OFAC) collection system instead of having the data 

manually transmitted to OFAC and being entered into the system by employees. While an 

important measurement of the blocked assets of State Sponsors of Terrorism as well as 

terrorist groups, OFAC’s preparation of the annual TAR remains a labor-intensive, mostly 

manual process. This enhancement will allow OFAC to replicate automation gains already 

implemented on some programs across additional sanctions programs.

• Secure Online Communications Tool. Completes secure bi-directional, data/ecommunication transfers with the public in order to allow financial institutions to file 

information required by OFAC regulations (such as blocking reports) in a secure and 

expeditious manner. This initiative will transform the public’s ability to submit and track 

respective OFAC transactions, including maintaining an online account with OFAC, and 
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improve communication with the general public. The solutions to date have either been costprohibitive or inefficient, requiring a visit to the public institution seeking to establish a 

connection. OFAC has identified a government-approved, secure, sustainable, and efficient 

bi-directional solution to solve this need, and OFAC is in the process (via prototype) of 

implementing the solution for the Banking Institution High Volume Blocking report filers. 

This request would take the prototype to a production system and will be greeted as a 

significant step forward. 

• OFAC Classified Network e-workflow and Case Management. Enhances the hardware and 

software necessary to enable case management functionality on Treasury’s classified 

networks that mirrors OFAC’s unclassified OASIS case management system. These 

enhancements will allow for the installation of the software necessary to support case 

management, TFI collaboration, and other analytical efforts on Treasury’s high and mid-side 

networks. 

• TFIN Enhancement Information Analysis Project. Complements the larger TFI-wide data 

discovery and analysis initiative by providing mature data analytics functionality on TFIN for 

disparate OFAC (and TFI) investigative data sets. With this investment, TFI would be able 

to perform maintenance on existing designees, with the expectation of a 150 percent increase 

in ISIS terrorism targets by introducing the ability to identify direct and indirect relationships 

in a way not possible without this technology and a 50 percent increase in targeting across 

other counter terrorism groups. 

1.3 – Operating Levels

Dollars in Thousands

Terrorism and Financial Intelligence FY 2018 FY 2019 FY 2020

Object Classification Enacted Annualized CR Request

11.1 - Full-time permanent 54,884 54,884 60,763

11.3 - Other than full-time permanent 243 243 556

11.5 - Other personnel compensation 971 971 1,078

11.9 - Personnel Compensation (Total) 56,098 56,098 62,397

12.0 - Personnel benefits 17,394 17,394 19,924

Total Personnel and Compensation Benefits $73,492 $73,492 $82,321

21.0 - Travel and transportation of persons 2,797 2,797 2,116

22.0 - Transportation of things 20 20 824

23.1 - Rental payments to GSA 73 73 491

23.2 - Rental payments to others 14 14 256

24.0 - Printing and reproduction 100 100 122

25.1 - Advisory and assistance services 8,125 8,125 16,546

25.2 - Other services from non-Federal sources 7,989 7,989 9,620

25.3 - Other goods and services from Federal sources 41,768 41,768 46,672

25.7 - Operation and maintenance of equipment 360 360 404

26.0 - Supplies and materials 2,000 2,000 2,302

31.0 - Equipment 1,400 1,400 3,258

32.0 - Land and structures 3,640 3,640 1,780

Total Non-Personnel $68,286 $68,286 $84,391

New Budgetary Resources $141,778 $141,778 $166,712

 ⃰FY 2018 shows actual FTE usage. This column reflects levels appropriated in P.L. 115-141 Consolidated Appropriations Act, 2018. 

 For further details on the execution of these resources see the FY 2020 Appendix chapter for the Department of the Treasury.
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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, $166,712,000: Provided, That of the amounts 

appropriated under this heading, $10,000,000 shall remain 

available until September 30, 2021.

Note.—A full-year 2019 appropriation for this account was not 

enacted at the time the budget was prepared; therefore, the budget 

assumes this account is operating under the Continuing 

Appropriations Act, 2019 (Division C of P.L. 115–245, as 

amended). The amounts included for 2019 reflect the annualized 

level provided by the continuing resolution.

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 g y – Terrorism and Financial Intelligence Resources and Measures

Dollars in Thousands

 Resource Level FY 2014 FY 2015 FY 2016 FY 2017 FY 2018 FY 2019 FY 2020

Actual Actual Actual Actual Actual Annualized CR Request

Appropriated Resources $101,305 $112,160 $112,754 $121,580 $109,038 $141,778 $166,712

Other Resource $31,293 $6,966 $6,329 $6,491 $8,626 $8,626 $8,626

Budget Activity Total $132,598 $119,126 $119,083 $128,071 $117,664 $150,404 $175,338

FTE 376 385 414 428 444 531 581

Performance Measure FY 2014 FY 2015 FY 2016 FY 2017 FY 2018 FY 2018 FY 2019 FY 2020

Actual Actual Actual Actual Actual Target Target Target

Impact of TFI Programs and 

Activities

8.5 8.8 8.7 8.5 DISC DISC DISC DISC

New or Modifications to 

Existing Sanctions Programs

N/A N/A N/A 5 6 I I I

Number of Designation 

Actions

N/A N/A N/A 867 725* I I I

Analytic Intelligence Support N/A N/A N/A 385 704 I I I

Review and Support of 

Foreign AML/CFT Laws and 

Regulations

N/A N/A N/A 49 64 I I I

Key: I - Indicator 

*This number does not include the more than 700 individuals, entities, aircraft and vessels sanctioned on November 5, 2018, as part of the reimposition of the U.S. nuclear-related sanctions that were lifted or waived in connection with the JCPOA Although technically completed in FY 

2019, the vast majority of the work was completed in FY 2018. 
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Terrorism and Financial Intelligence Budget and Performance

($166,712,000 from direct appropriations, $8,626,000 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 2018, 

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.

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 November 2017, FinCEN issued its final ruling pursuant to Section 311 of the USA 

PATRIOT Act against the China-based Bank of Dandong for serving as a gateway for North 

Korea to access the international financial system. Along with that action, FinCEN issued an

advisory to financial institutions across the globe with specific red flags of illicit North Korean 

schemes being used to evade U.S. and UN sanctions, launder funds, and finance the regime’s 

weapons of mass destruction and ballistic missile programs. Additionally, in February 2018, the 

OFAC issued an advisory, joined by the U.S. Department of State and the U.S. Coast Guard, to 

alert persons globally to deceptive shipping practices used by North Korea to evade sanctions. 

Overall, in FY 2018, TFI has sanctioned more than 200 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

With respect to Iran, following the President’s announcement in May 2018 to cease participation

in the Joint Comprehensive Plan of Action (JCPOA), Treasury re-imposed U.S. sanctions on the

Iranian regime. These measures, imposed in two phases, are designed to greatly reduce Iran’s

capacity to continue its support for terrorism, human rights abuses, ballistic missile proliferation,

destabilizing activities, and support of militant groups. In addition, as of the end of FY 2018,

TFI has issued 18 rounds of sanctions on 146 individuals and entities for a range of activities

related to terrorism, proliferation, and human rights abuses, and to thwart Iran’s exploitation of
TFI - 12

the global financial system. Additionally, on November 5, OFAC issued an additional 700

designations, the preparation of which all took place in FY 2018. 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. 

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, FinCEN recently

issued an advisory 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 in recent months, 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. As of the end of FY 2018, the Administration sanctioned 215 individuals or entities,

including 136 designated under Ukraine/Russia-related sanctions under the CAATSA. TFI

sanctioned powerful Russian oligarchs and many of the companies they own or control. 

Additionally, to protect the international banking system, FinCEN named Latvia-based ABLV

Bank as a primary money laundering concern under Section 311 of the USA PATRIOT Act. This

closed a key access point being exploited by illicit Russian actors to access the international

banking system.

Counter-Terrorism

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

Islamic State of Iraq and Syria (ISIS), al-Qa’ida, Hizballah, Hamas, the Taliban and others. The

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 2018, TFTC conducted two rounds of multilateral designations, to

include the senior leadership of Hizballah’s Shura Council and leaders, financiers, and

facilitators of the ISIS in Syria and Yemen and al-Qa’ida in the Arabian Peninsula. Additionally,

TFI led discussions with Gulf partners on regional terrorist financing issues, and FinCEN led a

training session with the Financial Intelligence Units of TFTC member countries.

 

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

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

networks. In FY 2018, TFI conducted 26 Hizballah-related sanction designations, and saw more

designations in calendar year 2018 by the Departments of State and Treasury than in any single

year. Furthermore, in September 2018, TFI sanctioned a company with ties to the Assad regime
TFI - 13

in Syria that facilitated the trading of fuel between Assad’s government and ISIS. The

designations disrupted this specific illicit supply chain and eliminated access to the international

financial system.

Human Rights

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

on the Maduro regime in Venezuela in light of the recent 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. In FY 2018, TFI implemented sanctions against several senior

government officials and former officials, along with others in Maduro’s inner circle, and issued

a FinCEN advisory to financial institutions to assist them in blocking suspected Venezuelan

public corruption funds moving through 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. 

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

through the Global Magnitsky Human Rights Accountability Act. Under this program, by the end

of FY 2018, TFI has sanctioned more than 80 individuals and entities, including a corrupt

financier of mining and oil deals in the Democratic Republic of the Congo and individual

officers and units of the Burmese military for their involvement in ethnic cleansing and extreme

violence against the Rohingya Muslim population and other ethnic and religious minorities. 

Moreover, FinCEN issued an advisory to U.S. financial institutions to highlight the connection

between corrupt senior foreign political figures and their enablement of human rights abuses. In

Nicaragua, Treasury again used these tools and authorities to combat an increasingly

deteriorating corruption and human rights crisis. OFAC designated four officials pursuant to the

Global Magnitsky authority in response to their significant involvement in corruption schemes or

human rights abuse. OFAC also issued an advisory alerting financial institutions that the

growing instability in Nicaragua may lead to the proceeds of crime and corruption from senior

political figures entering the United States. 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. 

FATF

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

including Treasury’s July 2018 assumption of the presidency of the Financial Action Task Force

(FATF), the AML/CFT standard setting body. TFI has set three priorities during this 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. 
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During FY 2018, Treasury participated in FATF peer review processes of seven countries:

Iceland, Bahrain, Saudi Arabia, Myanmar, Indonesia, Latvia and United Kingdom. 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 worked with the FATF to produce extensive guidance on counter proliferation financing. 

This guidance aims to help both public and private sector stakeholders understand and

implement the obligations of the United Nations Security Council resolutions, as well as how to

prevent sanctions evasion.

In FY 2019, TFI is working with the 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. 

In support of our priorities to protect the financial system from abuse by illicit actors, Treasury

launched the FinCEN Exchange to provide financial institutions with additional information

about priority issues on a more regular basis. This will allow these financial institutions to focus

on specific illicit finance and national security threats. As part of this program, TFI convenes

regular briefings with law enforcement and financial institutions to exchange information on

priority illicit finance threats, including targeted information and broader typologies. This

program enables financial institutions to better identify risks and focus on high priority issues

and allows FinCEN and law enforcement to receive critical information to help them disrupt

money laundering and other financial crimes. 

In addition, TFI resolved three civil enforcement actions against financial institutions that violate

the Bank Secrecy Act, which resulted in the assessment of civil money penalties against two

depository institutions and one casino.

Throughout FY 2019 and FY 2020, 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 

(FinCEN), reports directly to the Under Secretary for TFI but is budgeted separately as a bureau 

within the Treasury.
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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. 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. 

OFAC

The Office of Foreign Assets Control (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 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 
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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.

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 every action, additional 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, timely meet 

reporting requirements, monitor for potential evasion, and execute all required regulatory 

changes, among other things. 

Impact of TFI Programs and Activities: To gauge its performance, TFI previously used a 

composite measure consisting of three program office focus areas related to its mission and 

strategic goals, including customer outreach, increasing production and dissemination of 

intelligence products, and implementing IT modernization projects. TFI discontinued this 

measure in FY 2018 but proposes four new measures with targets for FY 2019 and FY 2020.

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 program 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 “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 
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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.

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

in FATF mutual evaluations (ME), which are peer evaluations of countries’ levels of 

effectiveness and implementation of the FATF AML/CFT Standards. The data is collected from 

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, bilateral and 

multilateral meetings, foreign travel, and reviewing draft legislation.
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C – Changes in Performance Measures 

Performance Measure or Indicator Proposed Change and Justification

1. Impact of TFI Programs and Activities

(discontinue)

We propose to stop reporting this metric in the CJ/BIB 

because this data required considerable effort to collect 

and was not indicative of TFI’s overall performance.

2. New or Modifications to Existing 

Sanctions Programs (new measure)

This indicator measures new actions or expansion of 

existing sanction programs. The creation or 

modification of sanctions programs requires a 

significant upfront dedication of policy, legal, and 

regulatory resources to ensure proper coordination and 

documentation of the changes. The data is collected by 

OFAC.

3. Number of Designation Actions (new 

measure)

This indicator measures number of actions taken to 

impose sanctions. The preparation for each action is 

exceedingly complex and requires several lines of 

effort. The data is collected from OFAC.

4. Analytic Intelligence Support (new 

measure)

This indicator includes both formal analytical 

intelligence briefings and final analytical intelligence 

products that were published. The data is collected 

from OIA.

5. Review and Support of Foreign 

AML/CFT Laws and Regulations 

(new measure)

This indicator includes participation in FATF ME, 

which 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. The data is collected from TFFC. 

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.