Countering Violent Extremism in the United States
Released: 2014-02-19T00:00:00

Summary:
In August 2011, the Obama Administration announced its counter-radicalization strategy. It is devised to address the forces that influence some people living in the United States to acquire and hold radical or extremist beliefs that may eventually compel them to commit terrorism. This is the first such strategy for the federal government, which calls this effort "combating violent extremism" (CVE). Since the Al Qaeda attacks of September 11, 2001, the U.S. government has prosecuted hundreds of individuals on terrorism charges. Unlike the necessarily secretive law enforcement and intelligence efforts driving these investigations, the CVE strategy includes sizeable government activity within the open marketplace of ideas, where private citizens are free to weigh competing ideologies and engage in constitutionally protected speech and expression. Some of the key challenges in the implementation of the CVE strategy likely spring from the interplay between the marketplace of ideas and the secretive realm encompassing law enforcement investigations and terrorist plotting.
The strategy addresses the radicalization of all types of potential terrorists in the United States but focuses on those inspired by Al Qaeda. To further elaborate this strategy, in December 2011 the Administration released its "Strategic Implementation Plan for Empowering Local Partners to Prevent Violent Extremism in the United States" (SIP). The SIP is a large-scale planning document with three major objectives and numerous future activities and efforts. The SIP's three objectives involve (1) enhancing federal community engagement efforts related to CVE, (2) developing greater government and law enforcement expertise for preventing violent extremism, and (3) countering violent extremist propaganda.
This report provides examples of Administration CVE activity and examines some of the risks and challenges evident in the SIP's three objectives. The report also diagrams and briefly discusses the "future activities and efforts" outlined in the SIP for each of these three objectives. A number of areas may call for oversight from Congress. These include the following:
Picking Partners and Establishing "Rules of the Road"
Much of the federal government's CVE effort centers on engagement with Muslim American community groups. This may not be as easy as simply reaching out to local organizations. Who speaks for diverse Muslim communities in America? What criteria will the Administration employ in its selection efforts, and how open will the process be? Once approved as partners, what "rules of the road" will govern continued cooperation? Ad hoc and opaque decision making might render the whole CVE outreach process arbitrary to some community participants. Congress may opt to consider whether there is a need to require the Administration to release public guidelines in this area.
Intervention with At-Risk Individuals
There appears to be little federally driven guidance to community groups on how to intervene with people vulnerable to radicalization. Congress may desire to require the Administration to examine the utility and feasibility of developing a CVE intervention model—possibly akin to gang intervention models—for the United States.
Identifying Programs to Assist Grassroots CVE Efforts
Working with communities entails informing them of possible resources they can use. A publicly available, comprehensive list of grant programs that can be harnessed for CVE activities does not exist. Congress may be interested in asking the Administration to formalize a roster or designate a clearinghouse available to local entities to identify such programs. By possibly pursuing this, Congress may help to ensure that local constituents have better information about and more direct access to federal CVE programs. On the other hand, such a list could be perceived as an additional layer of bureaucracy between constituents and grant programs.
Countering Extremist Ideas: Choosing Good vs. Bad
The task of countering extremist ideas highlighted in the CVE strategy and SIP raises a number of questions. Do the strategy and the SIP place the federal government in the business of determining which ideologies are dangerous and which are safe—essentially determining which beliefs are good and which are bad? In order to conduct effective oversight, Congress may choose to ask the Administration to define exactly what it means when referring to "violent extremist narratives."
The Lack of a Lead Agency
There is no single agency managing all of the individual activities and efforts of the plan. At the national level, some may argue that it would be of value to have a single federal agency in charge of the government's CVE efforts. From their perspective, without a lead agency it may be difficult to monitor the levels of federal funding devoted to CVE efforts and how many personnel are devoted to CVE in the federal government. For how many of these employees is counter-radicalization a full-time job? Are there mechanisms to track federal CVE expenditure? Which federal body is responsible for this? Congress may wish to pursue with the Administration the feasibility or value of designating a lead agency, or the possibility of naming a lead via legislation. However, it is unclear what types of authority—especially in the budgetary realm—such a lead may be able to wield over well-established agencies playing central roles in the CVE strategy.
Transparency
Without a high degree of transparency, an engagement strategy driven by federal agencies charged with intelligence gathering and law enforcement responsibilities may run the risk of being perceived as an effort to co-opt communities into the security process—providing tips, leads, sources, and informants. Some may maintain that this threatens to "securitize" a relationship intended as outreach within the marketplace of ideas. As such, critics may argue that it might not be particularly effective to have the same federal agencies responsible for classified counterterrorism investigations grounded in secrecy also be the main players in the CVE strategy. However, the Department of Homeland Security, the Department of Justice, and the Federal Bureau of Investigation have responsibilities for much of the CVE program. Because of this reality, Congress may opt to consider whether there is a need for greater transparency from the Administration in its CVE efforts.

subsections: section_title: Introduction: Counterterrorism Context
paragraphs: In August 2011, the Obama Administration released its domestic counter-radicalization strategy. The Administration dubbed this effort "countering violent extremism" (CVE). Implementation of the CVE strategy revolves around impeding the radicalization of violent jihadists in the United States. As this may suggest, for this report, a couple of concepts are key. Namely, "radicalization" describes the process of acquiring and holding radical or extremist beliefs; and "terrorism" describes violent or illegal action taken on the basis of these radical or extremist beliefs. 
This report examines the implementation of the Administration's counter-radicalization strategy and provides possible policy considerations for Congress relating to this relatively new area of coordinated federal activity. Implementation of the CVE strategy involves many elements within the executive branch and brushes against a number of key issues involving constitutionally protected activity versus effective counterterrorism policing efforts. 
Government-related efforts to stave off terrorist activity in the United States exist within two broad contexts. First, the operational aspects of violent terrorist plots largely involve clandestine illegal activity. Since the terrorist attacks of September 11, 2001 (9/11), hundreds of individuals have been implicated in more than 70 homegrown violent jihadist plots or attacks. In this secretive realm, law enforcement pursues terrorists in a real-world version of hide-and-seek. Domestic law enforcement strategies devised in the decade since 9/11 to prevent terrorism largely focus their efforts in this area. Federal law enforcement activity in this arena is geared toward rooting out terrorists and stopping them from successfully executing their plots. 
The second context is the open marketplace of ideas. Here, private citizens are free to weigh competing ideologies and engage in constitutionally protected speech and expression. In this arena, a relative few ordinary law-abiding persons move from the mainstream and adopt radical ideologies that embrace terrorism. As they radicalize, they do not necessarily commit crimes . Much like the policing that occurs in the secretive realm, the federal government's CVE strategy is a preventative approach to terrorism, but it is not wholly focused on policing . Rather, federal activity in this arena is geared toward helping local communities and individuals boost their resilience to terrorist radicalization efforts. 
The divergent nature of these two contexts may imply clear distinction between the marketplace of ideas and the secretive operational realm. In reality, they are far from distinct. What happens operationally has significant impacts in the marketplace of ideas ( Figure 1 ). This interrelationship is highlighted by any number of issues. For example,
the success of terrorist plots in the secretive realm may spur radicalization and generate public fear in the marketplace of ideas; conversely, successful investigations in the secretive realm may discourage radicalizing individuals within the marketplace of ideas from eventually embracing violent acts of terrorism as an ultimate goal; effective policing within the secretive realm may depend on a trusting community acting supportively in the marketplace of ideas; perceived policing excesses in the secretive realm may impede community engagement with law enforcement; and high levels of radicalization occurring in the marketplace of ideas may expand the potential pool of terrorist recruits, while an effective government strategy to counter radicalization may staunch terrorist recruitment. 
In fact, some of the key challenges involved in implementing a national strategy to deal with terrorist radicalization spring from the interplay between the marketplace of ideas and the secretive realm. 
subsections: section_title: From Radicalization to Terrorism
paragraphs: A key way to fight the threat of homegrown terrorists is to develop an understanding of how radicalization works and formulate ways to prevent radicalization from morphing into terrorist plotting. In 2007, the New York City Police Department's (NYPD's) Intelligence Division released a study of domestic jihadist radicalization that has been widely circulated within the law enforcement community. 
The NYPD study describes a general four-step process of radicalization leading to terrorist plotting. First, individuals exist in a pre-radicalization phase in which they lead lives unaware of or uninterested in either violent jihad or fundamentalist Salafi Islam. Next, they go through self-identification in which some sort of crisis or trigger (job loss, social alienation, death of a family member, international conflict) urges them to explore Salafism. Third, individuals undergo indoctrination or adoption of jihadist ideals combined with Salafi views. The study indicates that, typically, a "spiritual sanctioner" or charismatic figure plays a central role in the indoctrination process. Finally, radicalizing individuals go through "jihadization," where they identify themselves as violent jihadists, and are drawn into the planning of a terrorist attack. At this point, according to the NYPD, they can be considered violent extremists (terrorists). The Federal Bureau of Investigation's (FBI's) own four-stage model of radicalization closely follows that of the NYPD. 
This model and the process it describes—though useful—should, however, be read with caution, according to some observers. The radicalization process is best depicted in broad brush strokes. Brian Michael Jenkins has suggested that
There is no easily identifiable terrorist-prone personality, no single path to radicalization and terrorism. Many people may share the same views, and only a handful of the radicals will go further to become terrorists. The transition from radical to terrorist is often a matter of happenstance. It depends on whom one meets and probably on when that meeting occurs in the arc of one's life.
Some experts have warned against viewing the radicalization process as a "conveyer belt," somehow starting with grievances and inevitably ending in violence. The NYPD report itself acknowledges that individuals who begin this process do not necessarily pass through all the stages nor do they necessarily follow all the steps in order, and not all individuals or groups who begin this progression become terrorists. Studies by the Department of Homeland Security's (DHS's) Office of Intelligence and Analysis indicate that the radicalization dynamic varies across ideological and ethno-religious spectrums, different geographic regions, and socioeconomic conditions. Moreover, there are many diverse "pathways" to radicalization and individuals and groups can radicalize or "de-radicalize" because of a variety of factors. 
In a more fundamental conceptualization, radicalization expert Peter Neumann has noted that three core elements exist in the radicalization process. These are grievance, ideology/narrative, and mobilization. Grievances can stem from narrow issues unique to an individual's personal life or arise from broader perceptions of the surrounding world. A radicalizing individual seizes upon extremist ideologies or narratives to help explain his or her grievance. Mobilization consists of an individual acting on his or her grievances based on precepts culled from a particular ideology or narrative. These actions can involve criminality. 
section_title: Countering Radicalization in the United States
paragraphs: Because so much of the radicalization process occurs within the marketplace of ideas, counter-radicalization efforts involve activity in the same realm. American counter-radicalization approaches favor government engagement with communities affected by terrorism. Scholars who have studied the circumstances that are associated with voluntary cooperation by Muslim-Americans in anti-terror policing efforts have identified strong evidence that when authorities are viewed as more legitimate, their rules and decisions are more likely to be accepted. Community engagement is—in part—an effort to make law enforcement authority more accepted within localities. 
subsections: section_title: Administration Strategy and Current Activities
paragraphs: The Administration's CVE strategy revolves around countering the radicalization of all types of potential terrorists. As such, the radicalization of violent jihadists falls under its purview and is the key focus. The initial August 2011 strategy was supported by the Administration's release in December 2011 of its "Strategic Implementation Plan for Empowering Local Partners to Prevent Violent Extremism in the United States" (SIP). The SIP is a large-scale planning document with three major objectives and numerous future activities and efforts. There is no single lead agency for any of the three objectives. Likewise, there is no single agency managing all of the individual future activities and efforts of the plan. The SIP's three objectives or "core areas of activity" are "(1) enhancing engagement with and support to local communities that may be targeted by violent extremists; (2) building government and law enforcement expertise for preventing violent extremism; and (3) countering violent extremist propaganda while promoting our [U.S.] ideals."
The following sections provide examples of Administration CVE activity and discussion of the risks and challenges evident in the SIP's three core areas of activity. The "future activities and efforts" outlined for each of the three core areas of activity in the SIP are also diagramed and briefly discussed below. 
subsections: section_title: Community Engagement
paragraphs: The concept of building trust through engagement and partnership is rooted in the community policing model developed by law enforcement professionals in the 1990s, and community policing is mentioned in the Administration's CVE strategy. Following the 9/11 attacks, law enforcement agencies came to realize the prevention of terrorist attacks would require the cooperation and assistance of American Muslim, Arab, and Sikh communities. "Embedded within these communities," notes Professor Deborah Ramirez, "are the linguistic skills, information, and cultural insights necessary to assist law enforcement in its efforts to identify suspicious behavior. In order to have access to these critical tools and information, law enforcement recognized the need to build bridges required for effective communication with these groups." At the same time, Muslim, Arab, and Sikh Americans recognized the need to define themselves as distinctly American communities who, like all Americans, desire to help prevent another terrorist attack.
A study by the Homeland Security Institute found that "[c]ommunity policing has been applied with notable success in places such as New York City, Chicago, Boston, and San Diego, and has been widely adopted (at least in name) throughout the United States." A Homeland Security Advisory Council (HSAC) working group chaired by Maryland Governor Martin O'Malley commented on Community-Oriented Policing, stating that
Effective public-private partnerships, designed to enable civic engagement, problem-solving, and violent crime mitigation provide the foundation for efforts to prevent, protect against and respond to violent criminal activity—including that which may be motivated by ideological objectives.
The Administration's CVE strategy depends on federal agencies cooperating with local groups to expand engagement efforts and to foster preventative programming "to build resilience against violent extremist radicalization." In fact, it highlights a "community-based approach" for the federal government, and much of the activity it describes will take place in the "marketplace of ideas" described in Figure 1 . To this end, the federal government most effectively acts as a "facilitator, convener, and source of information." Since November 2010, a national task force led by DOJ and DHS has helped coordinate CVE-related community engagement from the national perspective. It works with U.S. Attorneys, DHS's Office for Civil Rights and Civil Liberties (CRCL), the Department of State, and DOJ, among others. 
subsections: section_title: Role of U.S. Attorneys
paragraphs: Under the Administration's CVE strategy, U.S. Attorneys play a key role in community engagement within their jurisdictions. U.S. Attorneys are "the nation's principal litigators under the direction of the Attorney General." Attorney General Eric Holder has pushed the U.S. Attorneys to enhance their outreach efforts to Muslim, Sikh, and Arab American communities. Within their districts across the country, U.S. Attorneys have met with Muslim communities regarding specific situations and trends. In December 2010, DOJ began a pilot program involving U.S. Attorneys in community outreach efforts. This program did not specifically focus on CVE efforts but has included radicalization-related outreach. For example, in September 2011, the U.S. Attorney for the District of Oregon and Attorney General Holder met with Arab and Muslim community representatives in Portland, OR. 
Comparable outreach has been pursued by other U.S. Attorneys. The District of Minnesota has established the Young Somali-American Advisory Council. This responded to al-Shabaab's recruitment of young men within the greater Minneapolis-St. Paul, MN, Somali community. The council includes more than a dozen people between the ages of 18 and 30. Among the outreach activities tied to the council, the U.S. Attorney's office instructed council members on civics issues. In a similar vein, the U.S. Attorney for the Southern District of Florida and Assistant Attorney General Thomas E. Perez met with Muslim and Arab leaders in Miami in February 2011. Likewise, in November 2010, an alleged jihadist terrorist plotter was arrested for purportedly attempting to bomb a Christmas tree lighting ceremony in Portland, OR. In the plot's wake, the state's U.S. Attorney repeatedly met with local Muslim leaders. 
section_title: Other Federal Activities
paragraphs: Aside from the special role given to U.S. Attorneys, other elements of DOJ and additional U.S. government agencies engage and partner with Muslim American communities. Some of these efforts by DHS, DOJ, and FBI are detailed below. 
section_title: Department of Homeland Security
paragraphs: DHS has stated that public outreach to local communities plays a major role in the department's mission.  Engagement activities are centered in the Office for Civil Rights and Civil Liberties (CRCL), which began its outreach in 2003. Its work involves counterterrorism and CVE-related matters, but its overall mission is broader. The office is also responsible for
advising DHS leadership, personnel, and partners about civil rights and civil liberties issues; communicating with individuals and communities whose civil rights and civil liberties may be affected by DHS activities, informing them about policies and avenues of redress, and promoting appropriate attention within DHS to their experiences and concerns; and investigating and resolving civil rights and civil liberties complaints filed by the public.
CRCL has a Community Engagement Section. Recent domestic CVE-related outreach events have been coordinated by CRCL and its Community Engagement Section.
section_title: Department of Justice
paragraphs: In addition to the CVE role played by U.S. Attorneys, DOJ's engagement activities largely appear to come from the Civil Rights Division and the Community Relations Service. According to its website, since the terrorist attacks of September 11, 2001 (9/11), the Civil Rights Division of DOJ has prioritized prosecution of bias crimes and discrimination against Muslims, Sikhs, and persons of Arab and South-Asian descent, as well as individuals perceived to be members of these groups. These types of incidents are commonly referred to as "backlash." The division has also educated people in these communities about their rights and available government services. Senior Civil Rights Division officials have met with Muslim, Sikh, Arab, and South Asian community leaders regarding backlash discrimination issues. Like the Civil Rights Division, DOJ's Community Relations Service is involved in outreach. Since 9/11, the service has held meetings around the country to address backlash-related issues. 
section_title: Federal Bureau of Investigation
paragraphs: The FBI has publicly suggested that since 9/11, it has been formulating an "extensive program" to bolster its relationship with Arab, Muslim, Sikh, and South Asian communities in the United States. In March 2010, the Chief of the Community Relations Unit of the FBI's Office of Public Affairs testified to Congress that the primary purpose of the agency's outreach program was "to enhance public trust and confidence in the FBI." This involves fostering a positive image of law enforcement among U.S. organizations that have condemned terrorism and violent radicalization. The FBI relies on programs at the field office level to foster interaction with a wide variety of local groups. Also, some FBI field offices have formally interacted with local Muslim communities regarding specific cases. At the national level, FBI headquarters representatives have engaged in liaison with Arab and Muslim American advocacy groups and have regular issue-focused conference calls with community leaders. The FBI is also a member of the Incident Coordination Communications Team managed by DHS CRCL. 
section_title: Risks and Challenges
paragraphs: Although there is considerable support among public officials for community engagement, some experts warn of significant challenges in the development of programs that foster substantive relationships rather than token discussions or community relations events. A study of policing in Arab American communities sponsored by the National Institute of Justice, for example, highlighted four key obstacles hindering outreach between U.S. Arabs (Christian and Muslim) and law enforcement: "Distrust between Arab communities and law enforcement, lack of cultural awareness among law enforcement officers, language barriers, and concerns about immigration status and fears of deportation." 
Terrorism expert Marc Sageman cautions that engagement can be a sign of government focus on Muslim communities when instead it should be stressed that Muslims are Americans just like everyone else. He sees another challenge arise when engagement on the government side is led by federal agencies with law enforcement and intelligence responsibilities. "It can send the message that we are only interested in Muslims because they are potential law breakers. No other foreign or religious communities in the United States get this type of scrutiny." 
Outreach may be most effective when U.S. Muslim communities initiate it and community-government contact revolves around countering the extremist messages popular among violent jihadists. Marc Sageman also suggests it would be more appropriate for local authorities, such as a mayor's office, to perform the engagement role because they know these communities better than federal officials. 
subsections: section_title: The Tension Between Enforcement and Engagement Activities
paragraphs: An inherent challenge to building trust and partnership involves law enforcement investigative activities and tactics that can be perceived to unfairly target law-abiding citizens or infringe on speech, religion, assembly, or due process rights. This challenge highlights how government counterterrorism work in the secretive operational realm depicted in Figure 1 can influence engagement conducted in the open marketplace of ideas. If a community views government counterterrorism investigative activity as overly aggressive, it may not willingly cooperate in engagement programs. One expert has noted that "counter-radicalization is not about intelligence-gathering nor is it primarily about policing." The HSAC Countering Violent Extremism Working Group found that
There can be tension between those involved in law enforcement investigations and those collaborating to establish local partnerships to stop violent crime. Community policing can be impeded if other enforcement tactics are perceived as conflicting with community partnership efforts.
This challenge is evident in some public discussions of law enforcement surveillance activities and efforts to recruit and manage informants. Revelations that the NYPD engaged in surveillance of mosques, Muslim businesses, and Muslim college students in New Jersey and elsewhere in 2006 and 2007 have prompted concern among a number of community groups and civil libertarians. The FBI's top official in New Jersey suggested that such activities undermined the bureau's efforts at community engagement. While New York City Mayor Michael Bloomberg and others defended the legality of such activities, some New Jersey officials have complained that the NYPD had not effectively coordinated efforts with them. Other former law enforcement officials in New Jersey believed that appropriate cooperation occurred. Also, as announced in May 2012, a fact-finding review conducted by New Jersey's Office of the Attorney General "revealed no evidence ... that NYPD's activities in the state violated New Jersey civil or criminal laws."
In pursuing a community engagement strategy, the use of informants can be a controversial issue, especially when law enforcement officials rely on informants with criminal records who may be working on behalf of authorities in exchange for reduced jail time. One Muslim community leader who has published widely on domestic terrorism states that "many Muslim Americans fear that paid FBI informants specifically target impressionable youth and that law enforcement agents coerce community members to become informants themselves to avoid complications with immigration procedures." Confidential informants have been used in post-9/11 violent jihadist cases occurring in the United States. In some of those cases, the informants had criminal histories. The use of informants poses the following risks:
Informants do not merely observe and collect data. They make things happen.... Informants can cause confusion and dissatisfaction among members of groups and communities they infiltrate, discrediting leaders, and fostering factionalism as people wonder if any of their colleagues are spies. Their handlers' structure of incentives—raises, promotions, transfers, financial rewards, waived jail time—creates a system where informants consciously or subconsciously create and then destroy terrorist threats that would not otherwise exist. These pressures can push them from passive observer to aggressive actor, with serious consequences for constitutionally protected free speech. Another unplanned result: government loses legitimacy and support in the eyes of targeted communities, if they feel they have been manipulated.
Acknowledging the challenge, then FBI Director Robert Mueller said in 2009, "Oftentimes, the communities from which we need the most help are those who trust us the least. But it is in these communities that we ... must redouble our efforts." Also in 2009, then-FBI spokesman John Miller said the agency values its relationships with Muslims and has worked hard on outreach efforts that range from town hall meetings to diversity training for FBI agents. Miller said there is no factual basis for claims the FBI infiltrates mosques or conducts blanket surveillance of Muslim leaders. "Based on information of a threat of violence or a crime, we investigate individuals, and those investigations may take us to the places those individuals go." 
Former FBI agents and federal prosecutors note that informants are "still one of the government's best weapons to thwart terrorists and that the benefit to national security is likely to far outweigh any embarrassment to the agency." They claim that "although the law places almost no constraints on the use of informants, the agency takes sending an informant into a mosque very seriously and imposes a higher threshold for such requests." Former FBI counterterrorism Chief Robert Blitzer states that "what matters to the FBI is preventing a massive attack that might be planned by some people ... using the mosque or church as a shield because they believe they're safe there. That is what the American people want the FBI to do. They don't want some type of attack happening on U.S. soil because the FBI didn't act on information."
Maher Hathout from the Muslim Public Affairs Council counters by saying that "people cannot be suspects and partners at the same time. Unless the FBI's style changes, the partnership with the Muslim community will not be fruitful." The HSAC's CVE Working Group also cautions that "Law enforcement should be sensitive to the fact that perceptions regarding enforcement actions and intelligence gathering can impact community-oriented policing goals." In considering the tradeoff between security and liberty, policy makers face a choice in those cases where an investigative tactic might inflame members of a particular community: Is the impact of that tactic counterproductive in the long run, or is it necessary, short-term collateral damage? 
section_title: U.S. Attorneys as Brokers
paragraphs: As mentioned elsewhere in this report, DOJ has pushed the U.S. Attorneys to become larger players in community outreach. This suggests a critical question: is it appropriate to have the nation's principal litigators be key players in the federal government's CVE outreach efforts? Can the same people responsible for prosecuting terrorism cases effectively broker trust among community members who may be wary of federal law enforcement? Maintaining the integrity of this dualistic U.S. Attorney role—chief terrorism litigators v. federal outreach coordinators—may be challenging in the implementation of the strategy. 
section_title: Legitimacy and Litmus Tests
paragraphs: Given their role in federal CVE engagement, U.S. Attorneys have to selectively cooperate with groups at the local level. Identifying specific groups for outreach may be challenging. There is little consensus among American Muslims regarding national advocacy groups: "many Muslims do not feel there is a national Muslim-American organization that represents them. When asked which of a list of national Muslim-American organizations represents their interests, 55% of Muslim men and 42% of Muslim women say that none do." 
The U.S. government can affect the legitimacy of community actors simply by choosing them as outreach partners. It is unclear how U.S. Attorneys will select the groups with which they will work. To this end, will the U.S. government establish litmus tests regarding federal interaction with community groups? What role will law enforcement considerations—potentially choosing only groups that have cooperated with FBI investigations by offering leads or providing informants, for example—play in the selection of community partners? Will federal investigators scour the backgrounds of groups prior to engaging with them? 
When selecting engagement partners, DOJ has made at least one very public choice that was driven by law enforcement or prosecutorial considerations. The FBI and DOJ have limited their ties to the Council on American-Islamic Relations (CAIR), because DOJ listed the group as an unindicted co-conspirator in a federal terrorism case. This is an example of the dynamics described in Figure 1 —the secretive (operational) realm driving community engagement activity in the marketplace of ideas. In November 2008, the Holy Land Foundation for Relief and Development and five of its leaders were convicted of providing material support to Hamas, a designated foreign terrorist organization. CAIR has opposed its listing as an unindicted co-conspirator. The listing is not a formal criminal charge, and subsequent terrorism charges have not been brought against CAIR. In spite of all of this, CAIR, a well-known Muslim advocacy group, maintains working relationships with local law enforcement officials.
section_title: Fusion Centers and Community Engagement—Potentially Alleviating Tensions
paragraphs: The CVE strategy mentions the role of the national network of fusion centers in alleviating tension between the government's investigative and engagement activities. Fusion centers play a part in reporting suspicious, terrorism-related activity nationwide, perhaps potentially causing some tension between communities and law enforcement. The strategy and the SIP mention the Building Communities of Trust Initiative (BCOT) as a project fostering relationships among three sets of actors—fusion centers, law enforcement, and the communities in which they operate. This type of outreach potentially informs local communities about how suspicious activity suggestive of terrorism is reported to law enforcement and how police protect civil rights and liberties as they look for such activity. The initiative's recommendations included items such as 
training of fusion center analysts in cultural sensitivity so that they can distinguish behavior that is constitutionally protected from criminal or terrorist activity; encouraging law enforcement to "embrace" community policing by "emphasizing partnerships and problem solving"; and encouraging communities to view information sharing with fusion centers and law enforcement as key to crime prevention and counterterrorism.
section_title: Building Government and Law Enforcement Expertise
paragraphs: The SIP emphasizes three key items in this area. First, the plan notes that the U.S. government has to improve its understanding of radicalization via research, analysis, and partnerships. Second, greater sharing of information among state, local, and federal agencies regarding terrorist recruitment and radicalization is necessary. Third, the SIP notes that the federal government has to improve the radicalization-related training offered to federal, state, and local agencies.
Paramount among the federal government's efforts to improve its understanding of CVE are efforts to study the radicalization process and identify radicalizing individuals. To this end, the National Institute of Justice included research on domestic radicalization in its list of funding opportunities. The Science and Technology Directorate (S&T) within DHS has also pursued the topic. To help identify radicalizing individuals, DHS, the FBI, and the National Counterterrorism Center (NCTC) produced a study of homegrown terrorists, which reportedly teased out warning signs of radicalization. The study was discussed by senior federal, state, and local law enforcement officials at the White House in January 2012. Along these same lines, in July 2011, NCTC released findings resulting from an interagency study of homegrown terrorists. This study was not made public officially, but a summary of its findings is available online. It describes four "mobilizing patterns" among extremists. These include "links to known extremists, ideological commitment to extremism, international travel, and pursuit of weapons and associated training." It also emphasized an approach to understanding and assessing radicalization via analysis of behavioral indicators. 
The SIP also calls for enhanced information sharing between federal, state, and local law enforcement. Prior to late 2011, these efforts largely revolved around disseminating information to and briefing state and local officials. Such activity included the development of case studies examining the experiences of known and suspected terrorists. This was recommended in 2010 by the HSAC. In February 2011 congressional testimony, then DHS Secretary Janet Napolitano remarked that DHS develops these unclassified case studies so 
that state and local law enforcement, state and local governments, and community members can understand the warning signs that could indicate a developing terrorist attack. These case studies focus on common behaviors and indicators regarding violent extremism to increase overall situational awareness and provide law enforcement with information on tactics, techniques, and plans of international and domestic terrorists.
Napolitano went on to note that DHS conducted what she dubbed "deep dive sessions" regarding CVE issues with local police intelligence experts—providing them with information they could pass to subordinates.
Additionally, the SIP notes that the federal government will enhance the radicalization-related training offered to federal, state, and local agencies. It argues that this is necessary because of "a small number of instances of federally sponsored or funded CVE-related and counterterrorism training that used offensive and inaccurate information." In March 2011, news reports and a study suggested that state and local law enforcement officials were receiving poor counterterrorism training from unqualified instructors, often from the private sector. Furthermore, news reports indicated that offensive material produced by an FBI employee was delivered in a variety of official training sessions up until August 2011. These revelations led to concerns from public officials and advocacy groups regarding training standards used by the bureau. In addition, reportedly biased material had seeped into the training made available to Joint Terrorism Task Force officers via a secure computer network.
In the midst of these revelations, in September 2011 the bureau announced a review
of all training and reference materials that relate in any way to religion or culture. Additionally, the FBI will consult with outside experts on the development and use of training materials to best ensure the highest level of quality for new agent training, continuing education for all employees, and any FBI-affiliated training. All training will be consistent with FBI core values, the highest professional standards, and adherence to the Constitution.
DOJ announced a similar review in September 2011 as well. Less than 1% of the material inspected was found to be inaccurate or inappropriate. In October 2011, the White House ordered a broader examination of CVE instructional efforts within the federal government. In the same month, DHS released guidance and best practices for CVE training. These highlighted five commonsense goals:
1. Trainers and training should be expert and well-regarded. 2. Training should be sensitive to constitutional values. 3. Training should facilitate further dialog and learning. 4. Training should adhere to government standards and efforts. 5. Training and objectives should be appropriately tailored, focused, and supported.
The same document notes that CVE education programs differ from strictly counterterrorism training (the latter presumably centered on topics such as terrorist threats, vulnerabilities, and trends in terrorism). CVE training focuses "on developing trust, enhancing community resiliency, prevention, intervention, and protecting civil rights and civil liberties." In March 2012, DOJ and FBI released their own sets of training principles that parallel DHS's goals. 
section_title: Risks and Challenges
paragraphs: Development of better training and improved information sharing are laudable law enforcement goals. However, because such efforts feature so prominently in the second SIP objective, its overall thrust may be perceived to be more about classic preventative policing than about countering radicalization at the grass-roots level. It is unclear how much of the activity described under this objective directly fits into the Administration's emphasis on "a community based" CVE approach. 
There is space in the CVE strategy for training law enforcement about constitutionally protected aspects of the radicalization process—in other words, efforts to train police to understand when suspects go from being law-abiding radicals to being terrorists. However, the SIP itself does not offer any formal means for federal, state, or local law enforcement to cope with radicalizing individuals outside of their traditional areas of expertise—investigation, arrest, and prosecution. The SIP does not outline mechanisms for law enforcement to refer radicalizing individuals for community intervention (whatever that might mean within a local context). Without such a process, police can become very adept at identifying radicalization and yet be only able to cope with a radicalized individual when he or she mobilizes and becomes a terrorism suspect. One of the risks implicit in this SIP objective is that it may sharpen police ability to investigate terrorists, without improving their ability to intervene with radicalizing individuals. 
If the SIP's efforts to improve law enforcement training mostly enhance the ability of police to detain suspects and provide no other means for coping with radicalization, then these elements of the strategy might be better described as counterterrorism in nature, not part of the nation's counter-radicalization strategy.
subsections: section_title: The Issue of Openness
paragraphs: Should the federal government be concerned about the over-classification of radicalization-related research and training material by the security agencies involved in its development? The SIP's second objective is an area in which a great deal of activity can occur behind closed doors (within the secretive realm described in Figure 1 ), especially if the objective largely involves security, intelligence, and law enforcement agencies that typically avoid public disclosure of much of their other work. However , the steps involved in the radicalization process involve largely constitutionally-protected activity that occurs in the public sphere. Excessive secretiveness regarding government efforts to understand the legally protected activities of Americans might actually fuel radicalization. For example, one study by a British think tank has suggested that conspiracy theories "are a reaction to the lack of transparency and openness in many of our [U.K.] institutions." This same study sees conspiracies as a "radicalizing multiplier." Could this be possible in the United States?
A project developed as part of the second SIP objective was not widely released. The study of radicalization among homegrown violent extremists performed by DHS, NCTC, and the FBI—mentioned above—was revealed to state and local law enforcement behind closed doors at the White House. This example poses the question: can the federal government build trust within local communities if it holds back from the general public its own study of how people in the United States radicalized and became terrorists? Will secretiveness in this area actually feed radical narratives? 
Additionally, will excessively secret government efforts to understand radicalization shake community trust in law enforcement? Federal attempts to develop classified theories about legally-protected activities may make community groups less willing to "share" information regarding those very activities— especially if that information is treated strictly as intelligence by the government and the results of such "sharing" are never seen . Transparency in this arena potentially opens government conceptualizations of radicalization and federal training materials to the scrutiny of outside experts. It is unclear what sway partnerships with non-government experts will have in the SIP's second objective. 
section_title: Talking about Ideology
paragraphs: Ideology is a key ingredient in the radicalization experience. It is unclear how the CVE Training Guidance issued by DHS accommodates discussion of ideology within an instructional environment. In fact, under one of its goals: "Training should be sensitive to constitutional values," the guidance indicates that "Training should focus on behavior, not appearance or membership in particular ethnic or religious communities," yet it is silent regarding radical ideologies. Should instructors focus on ideology? How should instructors discuss radical beliefs in the classroom? 
section_title: Countering Violent Extremist Propaganda
paragraphs: The SIP notes that countering violent extremist propaganda is "the most challenging area of work, requiring careful consideration of a number of legal issues, especially those related to the First Amendment." In this area the document highlights NCTC's efforts to develop a "Community Awareness Briefing." In 2010, NCTC's Director described the briefing in testimony to the Senate Homeland Security and Governmental Affairs Committee: 
It has become clear that government can play a significant role by acting as a convener and facilitator that informs and supports—but does not direct—community-led initiatives. Based on this, NCTC led the development of a Community Awareness Briefing that conveys unclassified information about the realities of terrorist recruitment in the Homeland and on the Internet. The briefing, which can be used by departments and agencies and has garnered very positive reactions, aims to educate and empower parents and community leaders to combat violent extremist narratives and recruitment.
NCTC has also connected community activists with technology experts in a seminar to "maximize the use of technology to counter violent extremism online" and the Department of State has developed exchanges between foreign CVE experts and U.S. communities. The SIP did not indicate any additional "current activity" in late 2011 to counter violent extremist propaganda other than working to inform the media, policy makers, and U.S. communities on the issue. It did mention the development of a separate approach for the digital environment. This was released in February 2013. In an online posting titled "Working to Counter Online Radicalization to Violence in the United States," the White House emphasized the creation of a new Interagency Working Group to Counter Online Radicalization to Violence. It is 
chaired by the National Security Staff at the White House and involving specialists in countering violent extremism, Internet safety experts, and civil liberties and privacy practitioners from across the United States Government. This Working Group will be responsible for developing plans to implement an Internet safety approach to address online violent extremism, coordinating the Federal Government's activities and assessing our progress against these plans, and identifying additional activities to pursue for countering online radicalization to violence.
The White House has charged the group with using existing federal programs to "raise awareness and disseminate tools for staying safe from online violent extremism."
section_title: Risks and Challenges
paragraphs: The SIP notes that government efforts to counter narratives that foster radicalization should affirm American unity and bolster community capacities to "contest violent extremist ideas." The document stresses the importance of First Amendment concerns in this area. 
Aside from First Amendment issues, a challenge in this area might revolve around the perceived legitimacy of the main agencies the Administration selects for its implementation efforts. If security agencies trawling the internet for potential suspects lead the charge in fostering a counter-narrative, will American Muslims see these efforts as legitimate? How willing will they be to partner with FBI, DOJ, NCTC, and DHS to further this SIP goal? 
section_title: Administration Plan and Future Activities
paragraphs: The SIP lists "future activities and efforts" under its three objectives. Figure 2 , Figure 3 , and Figure 4 each cover a single SIP objective. They depict the lead federal agencies responsible for the future activities and efforts subsumed by the relevant objective, and more than one agency can serve as a lead for a particular effort. For the sake of clarity, the figures do not depict partner agencies playing secondary roles and assisting the lead agencies in particular activities. The language used for each of the future activities and efforts in the three figures extensively paraphrases or directly quotes the language used in the SIP. Additionally, the three figures do not include all of the component agencies of specific executive departments. Only the component agencies responsible for future activities and efforts under each SIP objective are included.
subsections: section_title: Is DHS the De Facto U.S. CVE Lead Agency?
paragraphs: It appears that DHS is cited as a lead agency in 43 of the 62 future activities and efforts discussed in the SIP. Because it is a key player and decision maker in more than two-thirds of the SIP's impending plans, it seems that DHS may be the de facto lead agency in charge of U.S. CVE activity in the near future. This suggests a critical issue: while granted a large amount of responsibility for implementation of the CVE strategy, will DHS have a matching level of say in its further evolution? 
subsections: section_title: Possible Policy Considerations for Congress
paragraphs: "The United States has made great strides," says one federal counterterrorism official, "in what might be called tactical counterterrorism—taking individual terrorists off the streets, and disrupting cells and their operations ... an effective counterterrorism strategy must go beyond this ... (to address) the threat of violent extremism." With the announcement of the CVE strategy, the Obama Administration has begun to address this concern. These Administration efforts may attract greater oversight from Congress, especially because the strategy involves the interplay between the public marketplace of ideas involving constitutionally protected activity and the secretive operational realm where terrorists plot and law enforcement pursues. 
section_title: Implementing the CVE Strategy
paragraphs: As mentioned elsewhere in this report, federal CVE activity emphasizes engagement with Muslim communities across the country. It broadly recognizes this, training, and counter messaging as key components of CVE. However, aside from embracing robust outreach and training for government agencies, the strategy lacks specific initiatives to combat radicalization at the grass-roots level. This suggests a number of other issues.
subsections: section_title: Picking Partners and Establishing "Rules of the Road"
paragraphs: Who speaks for diverse Muslim communities in America? As mentioned above, "[w]hen asked which of a list of national Muslim-American organizations represents their interests, 55% of Muslim men and 42% of Muslim women say that none do." Perhaps sentiments are clearer at the local level, however these figures suggest the difficulty of selecting partners who accurately represent community needs. It is difficult to speak of one Muslim "constituency" in the United States. The 2.75 million Muslims in the United States have divergent sectarian points of view, come from many ethnic or national backgrounds, and live in a variety of areas. Muslim Americans support many secular and religious organizations. 
What criteria will the Administration employ in its selection efforts, and how transparent will the process be? Once approved as partners, what "rules of the road" will govern continued cooperation? In essence, what would have to happen for a Muslim community group to fall out of favor with the government? Ad hoc decision making might cause the whole CVE outreach process to appear arbitrary to some community participants. Congress may consider requiring the Administration to release public guidelines in this area. Public guidelines may be especially important, because engagement directly involves engaging people and issues in the open marketplace of ideas and protected constitutional activity.
section_title: Intervention with At-Risk Individuals
paragraphs: There appears to be little federally driven guidance to community groups on how to intervene with people vulnerable to radicalization. Such an intervention effort, the Channel Program, has been a key element of the United Kingdom's counter radicalization strategy since 2007. The British government describes Channel as a "multi-agency programme to identify and provide support to people at risk of radicalisation" and involvement in "all forms of terrorism." Channel "relies on close collaboration between police, partners and other key stakeholders ... and where necessary, provides an appropriate support package tailored to an individual's needs." Copying the Channel program in its entirety may not be appropriate for the U.S. context. However, it is unclear whether the Obama Administration considers some variant of Channel workable or even necessary in the United States.
The U.S. CVE strategy does cite the Office of Juvenile Justice and Delinquency Prevention (OJJDP) Comprehensive Gang Model as an example of "locally-based initiatives that connect communities and government to address community challenges through collaboration and the development of stakeholder networks." OJJDP—a component of DOJ's Office of Justice Programs—describes the model as "one of the few approaches to gangs that encompasses a multidisciplinary response to gangs on multiple levels." The preventative model is intended as a blueprint for organizing local counter-gang efforts that do not necessarily result in law enforcement-driven outcomes, such as investigations, arrests, and prosecutions. For intervention, it targets young adult and teen gang members, not entities such as hate groups, prison gangs, or ideologically driven gangs consisting of adults. The model involves five strategies:
Community Mobilization: Involvement of local citizens, including former gang members and community groups and agencies, and the coordination of programs and staff functions within and across agencies.
Opportunities Provision: The development of a variety of specific education, training, and employment programs targeting gang-involved youth.
Social Intervention: Youth-serving agencies, schools, street outreach workers, grassroots groups, faith-based organizations, law enforcement agencies, and other criminal justice organizations reaching out and acting as links between gang-involved youth and their families, the conventional world, and needed services.
Suppression: Formal and informal social control procedures, including close supervision or monitoring of gang youth by agencies of the criminal justice system and also by community-based agencies, schools, and grassroots groups.
Organizational Change and Development: Development and implementation of policies and procedures that result in the most effective use of available and potential resources to better address the gang problem. 
The model is designed to focus on youth active in gangs or those who exhibit factors indicating potential gang involvement. It also advocates engagement with the families of such youth. Among its many suggestions, the model discusses interventions such as job training, employment, family counseling, academic tutoring, and anger management classes for young people at-risk. It also calls on law enforcement agencies and courts to move beyond traditional roles in the suppression of gangs—urging them to consider more intervention-oriented activities such as referring youth to social service programs.
The CVE strategy provides little detail about how the Comprehensive Gang Model may be applied to keep vulnerable people from radicalizing and becoming terrorists. Congress may consider examining the utility and feasibility of developing a CVE intervention model for the United States. While elaborating the specific details of such a program may be best left to the federal agencies potentially involved, broadly and publicly exploring what shape it would take might be of value to Congress. Key questions may involve issues such as (1) which agencies would take the lead in creating a program based on the Comprehensive Gang Model? (2) how would the FBI have to adapt its counterterrorism mission—strictly focused on investigating and disrupting terrorist activity—to handle the notion of "social intervention" as suggested by the Comprehensive Gang Model?
section_title: Identifying Programs and Federal Contacts to Assist Grassroots CVE Efforts
paragraphs: The Administration's CVE strategy stresses that "the best defenses against violent extremist ideologies are well-informed and equipped families, local communities, and local institutions." Determining and explaining how local entities—whether public or private—should interact with federal partners may pose quite a challenge. For example, are there existing federal grant programs that can be harnessed by local actors to develop a CVE intervention program? A publicly available comprehensive list of grant programs that can be harnessed for CVE activities does not exist. Congress may opt to consider the feasibility or the value of such a list or a clearinghouse available to local entities to identify such programs. By possibly pursuing this, Congress may help to ensure that local constituents have better information about and more direct access to federal CVE programs. On the other hand, such a list may be perceived as an additional layer of bureaucracy between constituents and grant programs.
section_title: Countering Extremist Ideas: Choosing Good vs. Bad
paragraphs: As the United Kingdom has clearly stated in its counter-radicalization program, extremist ideologies play a role in radicalization. Furthermore, Quintan Wiktorowicz (at the time on the National Security Council) commented that "we [the United States] will push back against the full scope of different violent ideologies with an inclusive, positive narrative." However, in the United States, mere belief in radical notions, no matter how reprehensible they are, is not necessarily illegal. The American Civil Liberties Union's (ACLU's) Michael German has stated that the ACLU is "deeply concerned about the potential for government censorship of Internet content based on the [CVE] strategy's proposal for countering violent extremist propaganda." 
Even more fundamentally, the task of countering extremist ideas raises key issues regarding the implementation of the CVE strategy. In the SIP, the Administration notes that when countering violent extremist propaganda, "In many instances, it will be more effective to empower communities to develop credible alternatives that challenge violent extremist narratives rather than having the federal government attempt to do so." This begs the question: do the strategy and the SIP place the federal government in the business of determining which ideologies are dangerous and which are safe—essentially determining which beliefs are good and which are bad? This can be viewed from two angles. One involves establishing parameters for engagement with local communities, the other involves evaluating the end product of engagement, the counter-narrative. 
First, while the SIP may suggest that the government should not be involved in creating alternatives to violent extremist propaganda, it appears to assume that the government will be involved in sifting between dangerous and safe ideas—establishing parameters for engagement on this issue. Without picking and choosing between good and bad ideologies, "empowering" local activists to counter specific concepts may prove difficult. Empowering individuals and groups to counter un-named, un-described concepts may prove challenging. Second, if the framing of a counter-narrative challenging terrorist ideologies is necessary, how precisely should the federal government partner with state and local government and civilian counterparts in the development of this counter-narrative? How do government entities keep a counter-narrative from being publicly viewed as propaganda or fueling terrorist conspiracy theories about the United States? 
Oversight in this area may be vital. As a start, Congress may wish to ask the Administration to better define what it means when referring to "violent extremist narratives."
section_title: The Lack of a Lead Agency
paragraphs: There is no designated single lead agency for any of the three objectives laid out in the SIP. Likewise, there is no single agency managing all of the individual activities and efforts of the plan. At the national level, it arguably may be of value to have a single federal agency in charge of the government's CVE efforts. One expert has stated as much: 
The White House should designate a single agency that serves as the principal hub for collecting, disseminating, and evaluating information on counter-radicalization. Its main function would be to collect, analyze, and share best practices with a wide range of governmental and non-governmental actors, including community leaders and non-profits. 
Without a lead agency it may be difficult to monitor the levels of federal funding devoted to CVE efforts. How many personnel are devoted to CVE in the federal government? For how many of these employees is counter radicalization a full-time job? Are there mechanisms to track federal CVE expenditure? Which federal body is responsible for this? Very specifically, the lack of a lead agency is reflected in the fact that DOJ, DHS, and FBI have each issued training guidelines for CVE. They are very similar, but the issuance of three almost identical but separate guidelines raises the question: why not just have one set created by one body overseeing the CVE program? Congress may pursue with the Administration the feasibility or value of designating a lead agency, or the possibility of naming a lead via legislation. However, it is unclear what types of authority—especially in the budgetary realm—such a lead may be able to wield over well-established agencies playing central roles in the CVE strategy.
subsections: section_title: Measuring Input and Results
paragraphs: On the other side of these budgetary questions, without a lead agency, how will the Administration evaluate the effectiveness of federal CVE efforts? The SIP underscores that individual departments and agencies involved in CVE "will be responsible for assessing their specific activities in pursuit of SIP objectives, in coordination with an Assessment Working Group." While this may seem straight-forward, the British government has struggled with measurement issues related to its counter-radicalization strategy. U.K. officials have made "progress ... in measuring outputs but not always in measuring outcomes." In other words, counting the number of engagement events is one thing. It is quite another thing to evaluate their impact. The SIP mentions this problem as well. However, the SIP does not discuss (1) specific metrics, (2) what real authority the Assessment Working Group will have to independently evaluate and impact CVE activity within federal departments and agencies, and (3) whether the Assessment Working Group will have the power to standardize measures of success across federal agencies and departments. In the end, the lack of a lead agency with budgetary control over CVE efforts and clear responsibility for implementation of the strategy makes it difficult to conceptualize exactly how spending in this area will be prioritized, evaluated, and then re-prioritized based on results. 
section_title: Secretiveness vs. Transparency
paragraphs: Without a high degree of transparency, an engagement strategy driven by federal agencies charged with intelligence gathering and law enforcement responsibilities may run the risk of being perceived as an effort to co-opt communities into the security process—providing tips, leads, sources, and informants. This threatens to "securitize" a relationship intended as outreach within the marketplace of ideas. It has been noted that "unlike counterterrorism, which targets terrorists, counter-radicalization is focused on the communities that are targeted by terrorists for recruitment. The aim is to protect, strengthen, and empower these communities so that they become resilient to violent extremism." As such, some suggest that it might not be particularly effective to have the same federal agencies responsible for counterterrorism also be the main players in the CVE strategy. The SIP rejects this notion stressing that "traditional national security or law enforcement agencies such as DHS, DOJ, and the FBI will execute many of the programs and activities outlined in the SIP." The strategy relies on agencies whose enforcement and intelligence missions are undergirded by secretiveness. As it stands, 19 of the 20 "future activities and efforts" for SIP objective 1, which focuses on community engagement, have DOJ, DHS, or a national task force headed by DOJ and DHS as lead agencies. The lone remaining future activity/effort is headed by the Department of Treasury and is focused on terrorism financing, an area of enforcement for the department. 
The fact that DOJ, DHS, and Treasury are key counterterrorism agencies may make it difficult for community groups to view them as full partners, especially if community confidence in them is shaky to start. According to a 2011 study, American Muslims have less confidence than other faith groups in the FBI—"60% of Muslim Americans saying they have confidence in the FBI, versus 75% or more of Americans of other faiths who say this." Because of this reality, Congress may decide to assess whether there is a need for greater transparency from the Administration in its CVE efforts.