FIGHTING THE FUNDING OF TERRORISM UTILIZING TERRORIST FINANCING OPERATIONS

A Strategic Planning Project Submitted

By

Lee M. Flowers

to

University of Maryland University College

HMLS 304

Professor

Dr. Robert L. Ditch, EdD

December 7th 2013

TABLE OF CONTENTS

CHAPTER

1. INTRODUCTION

Background …………………………………………………………….3

Statement of the Problem……………………………………………….4

Operational Definitions…………………………………………….…...5

Significance of the Study..…………….………………………………..6

Summary………………………………………………………………..9

2. LITERATURE REVIEW

Pertinent Studies……………………………………………………….. 13

Reflection …………….………………………………………………... 18

Summary……………………………………………………………….. 19

3. STRATEGIC PLAN

Introduction…………………………….………………………………. 20

Restatement of the Problem…………………………………….……….20

2

Mission and Vision Statement…………………………………………..22

Strategic Plan Description……………………………………………….23

Summary………………………………………………………………... 35

4. CONCLUSION AND RECOMMENDATIONSConclusion………………………………………………………………37

Recommendations………………………………………………………39

REFERENCES …………………………………………………………………40

CHAPTER ONE

INTRODUCTION

Background

In response to the September 11, 2001 terrorist

attacks, U.S. government officials publicly declared that

the fight against al Qaeda financing was as critical as the

fight against al Qaeda itself. “After 9/11, President Bush

said, ‘Let’s round up all the usual suspects and freeze

their assets.” Making the financial front the first

considered area of focus in the war on terror. It has been

presented as one of the keys to success in the fight against

terrorism: if we choke off the terrorists’ money, we limit

their ability to conduct mass casualty attacks. In reality,

3

completely choking off the money to al Qaeda and affiliated

terrorist groups has been impossible. At the same time,

tracking al Qaeda financing has proven a very effective way

to locate terrorist operatives and supporters and to disrupt

terrorist plots. Money fuels the operations of terrorists.

It’s needed to communicate, buy supplies, fund planning, and

carry out acts of destruction. This spending leaves a trail;

a trail that we can follow to help expose extremists and

their network of supporters; sometimes before they can

strike. That’s why shortly after 9/11, we established the

Terrorist Financing Operations Section (TFOS).

Within the Federal Bureau of Investigation, TFOS is

responsible for following the money, providing

financial expertise on our terrorism investigations,

and centralizing efforts to identity extremists and

shut down terrorism financing in specific cases.

(Tracking the Money Trails 2013)

More recently, TFOS has adopted a broader strategy to

identity, disrupt, and dismantle all terrorist-related

4

financial and fundraising activities. “A key element is

using financial intelligence to help identify previously

unknown terrorist cells, recognize potential terrorist

activity/planning, and develop a comprehensive threat

picture, while continuously being mindful of the money

trail.” (Tracking the Money Trails 2013)

Statement of the Problem

As detailed in the March 2005 U.S. Department of State

International Narcotics Control Strategy Report, “the United States has

a three-tiered anti-money laundering-

counter-narcotics/counterterrorist financing (known as

TFOS): strategy that employs traditional and non-traditional

law enforcement techniques and intelligence operations to

disrupt and dismantle terrorist financial networks.”

(Charles, R. B. 2005) These efforts may include

investigations, diplomatic actions, criminal prosecutions,

and designations, among other actions. While also ensuring

that the programs continue to improve among US allies in

order to safeguard Global efforts and deter terrorist

5

financing. In order to implement this strategy it requires

communicating effectively at all levels in order to achieve

the desired results.

TFOS will continue to set anti-money laundering and

counter-terrorist financing standards in the context of

an increasingly sophisticated financial system, and

work to ensure global compliance with those standards.

TFOS will enhance its focus on informal and non-

traditional methods of financing terrorism and money

laundering, including through cash couriers,

alternative remittance systems, and the abuse of non-

profit organizations. (Tracking the Money Trails 2013)

For years America has attacked terrorist cells and

groups, with little emphasis focused on their operational

funding and logistics. If our attacks focused on cutting

terrorists’ supplies and logistics, this would make it

nearly impossible for these cells to operate.  For example,

Southeast Asia remains an important financial center of Al

Qaeda. Rudner, M. stated in his work on Terrorism financing

6

that;

“They have developed their own funding mechanisms,

including charities, front companies, donations,

underground banking, gold and gem smuggling, and petty

crime to support their operations. Terrorism depends on

a substantial mobilization of financial resources to

support its complex organization, from domestic

activities to its world wide organizational operations.

Focusing on the assistance provided by other middle

eastern communities, consisting of front organizations,

clandestine networks, business enterprises, propaganda

media and other local exactions to create funding for

operations.” (Rudner, M. 2010)

Another interesting fact that was pointed out by Rudner is

that in some places, where an organization is dominant in

the community, they will make the people pay a heavy tax to

ensure their safety. These organizations have become

extremely successful and well organized much like a Fortune

500 company.

7

Operational Definitions

An overview of the organizational functions of Al Qaeda

to ensure their budgets are met:

“Administrative Superstructure: Funds for salaries, physical

facilities, office equipment and supplies, communications,

travel, protective security;

Armed Militia: Funds for recruitment, training camps,

command and control systems, procurement of explosives,

armaments, rockets and missiles, logistics, infrastructure;

Economics and Social Services: Funding for housing, medical

clinics, social services, Water supply, agricultural

extension, rural electrification;

Inter-Terror Cooperation: Provision of training and material

support to Hamas,

Palestinian Islamic Jihad, and other international partner

organizations,” (Terrorism Finance: Fund-Raising And Money-

Laundering)”

“Martyr’s Charity” (Bonyad-e Shahid): Pay benefits to

8

families of suicide bombers;

Political Campaigns: Funds for publicity, rallies, and

patronage;

Propaganda: Subsidies to support the Hezbollah-backed

Lebanese Media Group And its subsidiaries, especially Al-

Manna television and Al-Nor radio; Religious Institutions:

Financial support for mosques, clergy, education, dawa

(Islamic outreach)

Acronym Directory

AML Anti-Money Laundering

AML/CFT Anti-Money Laundering/Combating the Financing

of Terrorism

BSA Bank Secrecy Act

CFT Countering the Financing of Terrorism

CTAG Counter-Terrorism Actions Group

9

CTAP Counter-Terrorism Action Plan

ECHR European Convention on Human Rights

FASP Financial Sector Assessment Program

GCC Gulf Cooperation Council

GWOT Global War on Terrorism

IFTS Informal Funds Transfer System

JI Jemaah Islamiyah

KMM Kumpulan Mujahidin Malaysia

MENAFATF Middle East and North Africa Financial Action

Task Force

MERC Medical Emergency Relief Charity

MILF Moro Islamic Liberation Front

OFAC Office of Foreign Assets Control

QK Quality King

RICO Racketeer Influenced and Corrupt

10

Organizations Act

SDGT Specially Designated Global Terrorist

TFOS Terrorism Financing Operations Section

Significance of the Study

When TFOS specifically targets the above resources it

makes the War on Terrorism a much more simple process.

Throughout history, successful combat missions have revealed

when the enemy has no supplies or necessities to fight,

operate or train; they lose. “Shutting down terrorist

funding is difficult, but not impossible. It is also an

important investigative tool that can be exploited, but the

political will must be there.” (Hoffman, B. 2010) Terrorism

costs money. In fact, some experts have described money as

“the lifeblood” of terrorist organizations. Without money,

these groups could not conduct their operations or exist. It

is estimated according to our intelligence community that in

order to successfully operate their organization they make

11

about 500 million annually us dollars. Surprisingly a

majority of their funds comes from charitable donations,

most of the donations are of prepaid cards from Germany.

Just as we in America have established support for our

wounded through the Veterans affairs and other support

groups, the terrorist cells have also started a similar

charity for wounded resistance fighters to support the

martyrs of the resistance.

International governmental sources have noted Al Qaeda

involvement in human smuggling, drugs and arms

trafficking, trade in contraband, money-laundering,

forging travel documents, and financial fraud.

Hezbollah sympathizers and operatives are also reputed

to have resorted to hostage taking, extortion, drug

trafficking, and trade in counterfeit goods, import-

export scams, and mafia-style shakedowns of local Arab

communities. (Rudner, M. 2010)

To date, none of these mechanisms have effectively been

shut down. Our authorities are willing to arrest known

12

operatives, however, they are not effectively pursuing

individuals financing the terrorist acts. This is the

biggest failure; the enforcement of sanctions has proven to

be politically driven and unequal. Little has been done to

obstruct the means for funding terrorism. A Council on

Foreign Relations task force said that: “Al Qaeda’s

financial backbone is built from the foundation of

charities, non-governmental organizations, mosques,

websites, fund-raisers, intermediaries, facilitators, and

banks and other financial institutions that helped finance

the mujahidin. This network extends to all corners of the

Muslim world.” (Roth, J., Greenburg, D., & Wille, S. 2004)

To help prevent terrorism TFOS devised and implemented

sanctions to freeze the funds, financial assets, and

economic resources of individuals who finance and support

acts of terrorism. The Terrorist Financing Operations

Section has been characterized as "the sole vehicle for

truly global action against the twin threats of Al-Qaida and

the Taliban." (Ball, H. 2005) To date, approximately 490

individuals and entities have been placed on a list, known

13

as the "Consolidated List," and their assets are required to

be frozen. Despite its importance in combating global

terrorism, the TFOS asset freeze program has not been

implemented effectively.

“However, there has been no significant increase in the

amount of funds frozen under the sanctions regime since

2004. Member States are not freezing terrorist-related

assets, despite their obligation to do so.” (Gurulé, J.

2009) Furthermore, the TFOS Monitoring Team estimates that

ninety-five percent of the total value of the assets frozen

to date results from the freezing actions of only nine field

offices. Proving the failure of TFOS to inspect and ensure

proper procedures are being followed. “In an age of

international terrorism, drug violence in our streets and on

our borders, and organized crime, stopping illicit money

flows that support those atrocities is a national security

imperative,” said Sen. Carl Levin, D-Mich.

HSBC used its U.S. bank as a gateway into the U.S.

financial system for some HSBC affiliates around the

world to provide U.S. dollar services to clients while

14

playing fast and loose with U.S. banking rules. Due to

poor TFOS controls, TFOS allowed banks to expose the

United States to terrorist financing, suspicious

travelers checks, bearer share corporations, and rogue

jurisdictions. (CARL, L. 2005)

Summary

The finding of the Monitoring Team suggests that TFOS

is not taking seriously their obligations to ensure the

freezing of al Qaeda-and Taliban-related assets. Even when

names are added to the List, TFOS has been reluctant to

follow and ensure the policies set in place are followed.

Several reasons have been offered for the decline in the

number of listing submissions to the Committee and the lack

of enforcement by TFOS, including the: “(1) lack of capacity

by the section to enforce these sanctions; (2) lack of

information for names on the list; and (3) due process and

human rights concerns regarding the procedures employed for

designation.” (Tracking the Money Trails 2013) TFOS has been

hesitant in enforcing these sanctions and has allowed

15

certain offices and sections of the Government to violate

the legal laws set forth to protect America.

Sometimes an organization may need a quiet reminder of

its obligations in order to tighten its procedures, but

at other times, a more public encouragement might be

necessary. The Terrorist Financing Operations Section

may need to decide what action to take in what

circumstances. It will want to exhaust every possible

avenue before allowing the situation to become

confrontational. The intermediate steps should invoke a

close and confidential dialogue between the TFOS and

the office of concern to establish the facts and

illuminate the underlying reasons for non-compliance.

(Gurulé, J. 2005)

“The goal of counter-terrorism,” according to Mathew

Levitt, “should be to constrict the environment in which

terrorists operate,” including “their logistical and

financial support networks,” which “denies terrorists the

means to travel, communicate, procure equipment and conduct

attacks.” (Abuza, Z. 2003) This is the most difficult part

16

in the war on terrorism, as terrorist organizations use

creative ways to fund their operations. It has never been a

priority for law enforcement or counter-terrorism officials.

Terrorist financing was always seen as secondary to

counterterrorist operations, but never a priority. One of

the problems in the current counterterrorist strategy is

that it is too focused on arresting the leaders of Al Qaeda

to collapse these organizations. Yet both have proven they

are capable of replacing their leadership and developing new

command and control.

Counter-terrorist strategy has not focused on targeting

the “institutions of terror.” Disrupting the terrorist

foundation, including sources of funding, and

eliminating the space that terrorists need to plan,

train, and execute attacks must be given as much

attention as the arrests of individual terrorists for

the war on terrorism to be successful. (Abuza, Z. 2003)

The International Monetary Fund is especially concerned

about the possible consequences of terrorist financing.

Their research has shown that money laundering and financing

17

terrorism go hand in hand. Ultimately, creating chaos to

the financial sector of the economy. These activities can

destroy the integrity and stability of financial

institutions and systems, discourage foreign investment, and

change international capital flows. They have negative

consequences for a country’s financial stability at the

microeconomic level, resulting in losses, draining resources

from more productive economic activities, and some even have

spillover effects on the economies of other countries,

inevitably leading to macroeconomic catastrophe. As the

world becomes more and more interconnected, the negative

effects of these activities are felt at the macro level, and

their impact on the financial integrity and stability of

countries is devastating. Specifically stating that,

problems in one country will quickly spread to other

countries until it affects the entire world.

18

Chapter Two

Literature Review

This literature review will focus on the ways the

(TFOS) can effectively fight terrorist organizations beyond

simply trying to deny terrorist access to financing.

Specifically, TFOS can use the financial information or the

flow of money to connect terrorist to their supporters

discovering their actual operations base. More importantly,

when TFOS disrupts access to financial aid and effectively

follows the money trail, our Government will be able to

19

coordinate effective attacks and disrupt terrorist

operations. This will be accomplished by centralizing our

intelligence efforts (internationally and domestically),

ensuring we remain diplomatic within our dealings with the

United Nations committee, by sharing investigative

information effectively, building camaraderie and enhancing

our relationship within the United Nations committee.

Ultimately, allowing the section to alleviate terrorist

attacks nationally and eventually globally. The purpose of

this literature review is to review specific information

from resources and establish common ground on the

effectiveness of disrupting the financial aid of terrorism.

The question used for this literature review will be, “What

strategies can the Terrorist Financing Operations Section

utilize in order to effectively identify, disrupt, and

destroy all terrorist related financial assets, while

ensuring member states are held accountable?”

“There are two things a brother must always have for

jihad, himself and money.” al-Qaeda Operative (John Roth

2004)

20

The blanket statement; “Winning the War on Terrorism”

unfortunately this is not an option, there will always be

radicals and extremists willing to sacrifice everything to

make their voices heard or to gain political and religious

ground, meaning villains will always exists as proven

throughout history. TFOS goal should not focus solely on

defeating terrorism, but should focus on disrupting

terrorist making it dangerous for them to operate, train,

and conduct their mission, while making it exceedingly

costly for them to support their intentions. Since the

attacks of September 11th, discovering and counteracting

terrorist activities have been top priorities for the

Government. The main goal of President George Bush’s Global

War on Terror (GWOT) “was to deny terrorist access to the

international financial system, to impair their ability to

raise funds, and to expose, isolate, and incapacitate their

financial networks. (Executive Order 13224)

6

Like most

organizations, terrorist groups need financing to operate,

organize, recruit, train, and equip followers. However, if

TFOS is going to be effective in its mission it will need to

expand on the President’s statement. Simply trying to deny

terrorist access to financing and funding is not feasible.

The most important step is following the money by using

21

coordinated intelligence agencies, and investigations

domestically and internationally leading to the bases of the

terrorist cells and organizations allowing the capture and

seizures of all assets preventing further support,

disrupting their flow of money and denying them access to

financial resources and preventing attacks.

“For more than 2,000 years, military strategists have

recognized the truism that armed conflict cannot be waged

until it has been financed.” (Hinnen T. 2003) Combating

terrorist financing must be done by stopping the flow of

money that provides these organizations with support

necessary to carry out their acts. Targeting and regulating

charities has been a main focus of the Terrorist Financing

Operations Section since September 11, 2001. Funding of

Islamic charities through the zakat creates a large pool of

assets than can be used inappropriately and disbursed to

terrorist cells. Zakat is the amount of money that every

adult, mentally stable, free, and financially able Muslim,

male and female, has to pay to support specific people. This

category of people is defined in surah at-Taubah verse 60:

The alms are only for the poor and the needy, and those

who collect them, and those whose hearts are to be

reconciled, and to free the captives and the debtors,

22

and for the cause of Allah, and the wayfarers; a duty

imposed by Allah. Allah is knower, Wise. (Qur'an)

When taken into perspective the Zakat accounts for an

incredible amount of money that is required by all Muslims

to be contributed annually, the money is loosely regulated

and can easily become compromised and used to support

terrorism. Making the United States efforts of watching

these and following the money a number one priority since

9/11.

Today, we have launched a strike on the financial

foundation of the global terror network... we will

direct every resource at our command to win the war

against terrorists: every means of diplomacy, every

tool of intelligence, every instrument of law

enforcement, every financial influence. We will starve

the terrorists of funding, turn them against each

other, rout them out of their safe hiding places and

bring them to justice.

(Bush G. 2001)

“There are five ways through which terrorist’s finance

their organizations: direct contributions, international

donations into charitable foundations, state sponsorship,

23

criminal activities, and the collection of the

zakat.”( Jeanne K. Giraldo and Harold A. Trinkunas 2007) “Of

these five, international donations and the zakat made to

Islamic charitable foundations stand out as the primary

concerns for combating terrorism.” The zakat is intended to

support specific Muslims, “those with no possessions or

livelihood, those that cannot meet basic needs, zakat

workers, converts, those escaping slavery, bondage or

indebtedness, stranded travelers, and those with fulfilling

a strong cause for Allah.” (Costigan and Gold 2010) With the

last intention “fulfilling a strong cause for Allah” loosely

interpreted by the extremists and radicals, to mean

supporting their terroristic missions in the name of their

God. Meaning that through interpretation, manipulation, or

force the terrorist will use much if not all of the

donations. “Terrorist organizations receive funds for a

myriad of different activities other than operational

efforts of attack to include propaganda, recruitment, and

maintaining the organizational network.”( Costigan and Gold

2010) This is obviously a concern that these charities can

24

be easily controlled and molested by terrorist organizations

to acquire the zakat. “Evidence points out that one-third of

all Islamic charities have supported terrorist organizations

in one way or another.”(Alterman 2006)

“As the lead agency in of the Department of Justice for

national security and combating criminal activities,

and empowered by Title III of the USA PATRIOT act’s

“material support” legislation, the Federal Bureau of

Investigation is an important part of countering

terrorist financing.”(Weiss 2006)

The FBI is required to bridge the gap between local and

state governments while spear heading the “Joint Terrorism

Task Forces, participation in the National Security

Council’s Policy Coordination Committee on Terrorism

Financing and The State Department Terror Finance Working

Group.” However, the question remains; “Are the efforts of

the FBI more specifically TFOS meeting the goals necessary

to eradicate, disrupt, dismantle, and or following the money

enough to make financing terrorism more difficult through

25

legal channels?” The fight against the financing of

terrorism is aimed at effectively identifying, disrupting,

and destroying all terrorist related financial assets and

prosecuting those who are aiding them in completing their

missions. TFOS mission is to ensure that it constricts the

lifeblood of support from terrorism inevitably making it

more difficult for terrorists to use their means and

resources. By using the available tools proactively, TFOS

can identify terrorist networks and development counter

intelligence on these cells. The main goal is to ensure that

Member States are appropriately adopting and using the

asset-freezing program (which have reduced the possibilities

for terrorists and their organizations to misuse the

financial sector and make it more difficult to raise and

move funds) of suspected terrorist, whether it is

supporters, banks, or charities thus limiting the amount of

funds available to the terrorist. The second step is for

the Member States to implement this rule in a consistent

way, while monitoring the progress will be part of the

Terrorist Financing Operations Section.

26

Currently, there is no policy established that forces

intelligence and information sharing within the U.S.,

between, law enforcement, local, state, and tribal officials

let alone our partner nations. There is currently an ample

amount of ways to allow for intelligence sharing amongst the

needed sectors that are not being utilized effectively nor

in a timely manner in order to restrict terrorist funding.

The U.S. must keep continuously calling on Member States to

increase the cooperation of information sharing through each

financial intelligence community and private financial

sectors until improvement of the exchange of information is

successful in combating terrorist financing.

Reflection

Evaluating the details of the research above shows the

need for funding in order to support terrorist missions is

significant. Showing that the only true way to stop

terrorism is the disruption of funding to their

organizations Even though some attacks have been

accomplished at a low cost, the overhead of the terrorists’

organizations is costly to maintain; from the direct costs

27

of attacks, to maintaining and developing a “modern day

terrorist” and their ideology to spreading propaganda and

recruiting. This understanding of terrorist financing will

allow TFOS to organize and ensure the strategic plan

implementing specific areas to target in order to restrict

the flow of currency into terrorist hands. The objective of

this review was to pinpoint the areas of focus for future

planning. With the information that has been obtained you

can logically decipher that in order to “Win the War on

Terrorism” TFOS must effectively target the correct sources

of funding and eradicate the suppliers. Most importantly

that a multicultural relationship is developed and nurtured

to be successful and productive in preventing the financial

flow of funds to the terrorist. Meaning that TFOS must

establish a trusting relationship with our counterparts

overseas.

Summary

The literature review cemented the role of TFOS and why

it is vital to the financial sectors in combating terrorist

financing. History has also proven that, important

28

information on suspicious or unusual transactions needs to

be reported without limits between all relevant parties,

nationally as well as internationally. The effective

multicultural communication through information exchange and

feedback are vital in a global attack on terrorism

financing. In order to disrupt terrorist financing it is

imperative that TFOS be given the funding authority to

coordinate and direct the actions without restraining their

flexibility or resources against terrorist organizations.

The Member States must work together in sharing information

in a timely effective manner without limitations. And

modifications must be made to laws in order to allow for

swift and active measures to be taken against terrorist

financing stateside and abroad. Just as the terrorists are

very cellular and mobile we must also be flexible and mobile

in order to adapt to this new asymmetrical type of combat.

Over the past 12 years the fight against terrorist and

terrorism has been fought with our Department of Defense, by

putting boots on the ground and attacking them heads on. It

is now time to be proactive and direct our attention towards

29

preventing the fight and disabling terrorism by constricting

the flow of money until the last cell can no longer operate

and is strangled from existence.

Chapter Three

Strategic Plan

Introduction

This strategic plan gives vision to future of the

Terrorist Financing Operations sections imbedded within the

FBI. This plan will inevitably and continuously adapt to

ensure its success against terrorism. The plan is a

foundation to build from with flexibility to ensure mission

success. This plan was formulated due to the lack success

30

currently against terrorism financing, noting that all

assets necessary to be successful are available, but are not

being utilized to achieve the desired results.

Restatement of Problem

As detailed in the March 2005 U.S. Department of State

International Narcotics Control Strategy Report, “the United States has

a three-tiered anti-money laundering-

counter-narcotics/counterterrorist financing (known as

TFOS): strategy that employs traditional and non-traditional

law enforcement techniques and intelligence operations to

disrupt and dismantle terrorist financial networks.”

(Charles, R. B. 2005) These efforts may include

investigations, diplomatic actions, criminal prosecutions,

and designations, among other actions. While also ensuring

that the programs continue to improve among US allies in

order to safeguard Global efforts and deter terrorist

financing. In order to implement this strategy it requires

communicating effectively at all levels in order to achieve

the desired results.

31

TFOS will continue to set anti-money laundering and

counter-terrorist financing standards in the context of

an increasingly sophisticated financial system, and

work to ensure global compliance with those standards.

TFOS will enhance its focus on informal and non-

traditional methods of financing terrorism and money

laundering, including through cash couriers,

alternative remittance systems, and the abuse of non-

profit organizations. (Tracking the Money Trails 2013)

For years America has attacked terrorist cells and

groups, with little emphasis focused on their operational

funding and logistics. If our attacks focused on cutting

terrorists’ supplies and logistics, this would make it

nearly impossible for these cells to operate.  For example,

Southeast Asia remains an important financial center of Al

Qaeda. Rudner, M. stated in his work on Terrorism financing

that;

They have developed their own funding mechanisms,

including charities, front companies, donations,

underground banking, gold and gem smuggling, and petty

32

crime to support their operations. Terrorism depends on

a substantial mobilization of financial resources to

support its complex organization, from domestic

activities to its world wide organizational operations.

Focusing on the assistance provided by other middle

eastern communities, consisting of front organizations,

clandestine networks, business enterprises, propaganda

media and other local exactions to create funding for

operations. (Rudner, M. 2010)

Another interesting fact that was pointed out by Rudner

is that in some places, where an organization is dominant in

the community, they will make the people pay a heavy tax to

ensure their safety. These organizations have become

extremely successful and well organized much like a Fortune

500 company. To date, none of these mechanisms have

effectively been shut down. Our authorities are willing to

arrest known operatives, however, they are not effectively

pursuing individuals financing the terrorist acts. This is

the biggest failure; the enforcement of sanctions has proven

to be politically driven and unequal. Little has been done

33

to obstruct the means for funding terrorism. To help prevent

terrorism TFOS devised and implemented sanctions to freeze

the funds, financial assets, and economic resources of

individuals who finance and support acts of terrorism. The

Terrorist Financing Operations Section has been

characterized as "the sole vehicle for truly global action

against the twin threats of Al-Qaida and the Taliban."

(Ball, H. 2003) To date, approximately 490 individuals and

entities have been placed on a list, known as the

"Consolidated List," and their assets are required to be

frozen. Despite its importance in combating global

terrorism, the TFOS asset freeze program has not been

implemented effectively.

“However, there has been no significant increase in the

amount of funds frozen under the sanctions regime since

2004. Member States are not freezing terrorist-related

assets, despite their obligation to do so.” (Gurulé, J.

2009)

Furthermore, the TFOS Monitoring Team estimates that

ninety-five percent of the total value of the assets frozen

34

to date results from the freezing actions of only nine field

offices. Proving the failure of TFOS to inspect and ensure

proper procedures are being followed.

Mission Statement

To follow and track terrorist financing operations

Following the Money, provide financial expertise on our

investigations, and centralize authority that identify

terrorists and shut down terrorism financing. Enforce state

participation to encourage international cooperation.  While

keeping the specific strategy to identify and destroy all

terrorist financing and support.

Vision Statement

To constrict the Life Blood of Terrorism, (financial

flow) and prevent terrorist attacks domestically and

internationally.  We will starve the terrorists of funding

driving them from their hiding places and relentlessly

attacking them until they are unable to operate.  Using

their fear against the extremist driving them to a state of

35

paranoia, and making them turn on one another.  We will

force anyone supporting them to abandon immediately leaving

them vulnerable and exposed. Inevitably leading to the end

of terrorism.

Strategic Plan Description

We will first begin the planning following the

announcement and promotion process of developing a strategic

plan. The involvement of elected personnel as well as the

appropriate stake holders while simultaneously informing the

appropriate government officials to ensure collaboration

amongst all parties and to ensure all team members are on

board with the initial planning process. When this is

established we identify the facilitator or the entire

planning process to ensure compliance with all missions and

task. The next step will be gaining the support of the FBI

where a majority of all stakeholders will be established; it

is imperative they are provided with as much information

about the process as possible to ensure that the lanes of

communication are open and feedback is welcomed. Then

begins the detailed information gathering process such as

36

relevant intelligence pertaining to the organization as well

as the specific statistics needed to organize the basis of

the plan and to establish in black and white where the

problem lies. Once the information process is established

it will be necessary to develop the Mission Statement as

well as the Vision Statement it is vital that stakeholders

are involved in this process to ensure their support in the

strategic plans overall goals. The mission for Terrorist

Financing Operations Section is to follow and track

terrorist financing operations Following the Money, provide

financial expertise on our investigations, and centralize

authority that identify terrorists and shut down terrorism

financing. Enforce state participation to encourage

international cooperation.  While keeping the specific

strategy to identify and destroy all terrorist financing and

support. The mission statement allows everyone to easily

identify what are main objectives are and to focus on the

assignment during the planning process. The vision

statement is to constrict the Life Blood of Terrorism,

(financial flow) and prevent terrorist attacks domestically

37

and internationally.  We will starve the terrorists of

funding driving them from their hiding places and

relentlessly attacking them until they are unable to

operate.  Using their fear against the extremist driving

them to a state of paranoia, and making them turn on one

another.  We will force anyone supporting them to abandon

immediately leaving them vulnerable and exposed. Inevitably

leading to the end of terrorism. The vision statement

relies on what our long-term goals are, it is the end result

of our hard work and dedication. It is essential to the

strategic planning process that the mission and vision

statements are clear and concise to ensure all parties have

an understanding of the foundation to ensure the plan is

designed accordingly.

The analysis will focus on what is currently working

for other terrorist financing prevention sections and what

areas are problematic amongst these types of organizations.

Keeping in mind terrorism financing is an issue we face

globally not just nationally this is an issue and a task to

be addressed by all members to ensure the safety and

38

security internationally as well.

The plans goal is to reach the U.N. to ensure

compliance with previously designated plans and the

reiteration of the importance of freezing terrorist assets

through programs sanctions by the U.N. that are not

currently being upheld. The key players we need to target

will begin with director James B. Comey (FBI), Rand Beers

(DHS), but most importantly the Security Council sanctions

committees of the United Nations. It is extremely important

to have the support of all individuals to ensure

implementation of this plan; it is also imperative that they

are reminded that they are the primary stakeholders in this

mission as well. The factors that need to be considered are

political and economical. The politics involved will be of

a delicate nature to ensure there are no offenses made to

the states that have faulted in their mission to freeze

terrorist assets. The issue will need to be addressed

lightly to ensure their compliance in this mission as well

as their support. The economic effects for other countries

will rely on their ability to fund the necessary programs to

39

prevent terrorist financing as well as train the appropriate

amount of field agents to ensure they have the resources

necessary to follow and exploit the flow of money to

terrorist organizations. However, the first steps remain

constant that the US must first establish a universal

concept of constricting the flow of money that supports

terrorism. Once the US has established a concept that is

proven and statistically challenged it will encourage

multilateral international concepts that mirror our plan.

Lastly, the focus will unavoidably return to funding where

the idea of following the money allows the organization to

pay for itself. The money that will be frozen or

confiscated from terrorist will be used to acquire the

resources necessary to evolve with the changing and ever

mobile terrorist, allowing us to profit from their

wrongdoings and pushing to support other terrorist financing

operations sections globally. The funding will come from

the terrorist organizations, meaning the more funds that are

seized, the more sophisticated our organizations will

become. Our section will revolve around four specific

40

goals:

1. Safeguarding the financial system against corruption

by freezing terrorist assets and following the flow

of money back to origination.

2. Preventing or reducing the flow of capital to

support terrorism, by preventing money laundering

and other monetarist crimes.

3. Increase international collaboration to freeze

funding of terrorist while establishing a strong

stance against money laundering

4. Ensure compliance with intelligence sharing to

ensure timely and relevant information is being

passed through SIPR domestically as well as

internationally.

41

Strengths, Weaknesses, Opportunities, Challenges

(SWOC) Analysis

StrengthsProgram Funds Itself Education/ Training

Creating Revenue State of the art EquipmentTraining Facility Expert Field AgentsCommunications Capabilities System previously createdExperienced Agents Previous Expertise Agency collaboration International Relationships establishedFBI establishedUnited Nations backed programsTechnical Expertise

WeaknessesRefusal to share Information abroad Multiple Government agenciesRecruitment of agents Burnout rate of agentsAmount of agents needed UN inability to cooperateTrust issues with secret intelligence Newly developedsections (growing pains)Complex analysis Investigative support

Opportunities

42

Grants Law enforcement involvement Amount of funding available Intelligence communitySupport from the FBI Multi Supporting agencies Benefits Package Technological advancementsCross Training Global attention

Training UN supported program Increased Staffing Interoperable system

Flexibility in adjusting to terrorism

ChallengesBurnout rate of agents Working globally Communication internationally Communicating effectively amongst all involved agencies Becoming proactive vrs. Reactive Ensuring compliance overseasImplementing consequences to member states who are non-compliant Complete focus on the mission Very little time away from workEffective use of resources and time Cooperating

with our peers internationally

Developing camaraderie internationally Strict rules

and regulations

The overall goal of this strategic plan is to

defeat terrorism by constricting its lifeblood until

terrorist organizations and cells are no longer able to

43

operate or function. This can only be realized when all

objectives are met, on the home front as well as overseas.

This plan will lay the foundation that will successfully

lead to the demise of terrorism, as we know it. As of today

little has been done to disrupt the extensive financial

networks that Al Qaeda and other terrorist cells have

established. It is imperative that we take into account our

history of past success when fighting any war, first cut off

supplies and logistics making our enemy desperate and

bringing them into the open. When you take away their will

and means to fight, America will inevitably destroy all

terrorist cells and win the war on terrorism. In order to

accomplish this we must first outpace our enemies globally

and digitally. Al-Qaeda has become more of a cellular

structure over the years making them more mobile and without

a need for a typical hierarchical organization meaning they

have lowered cost to the point of just being cheap. The

U.S. must combat Al-Qaeda’s resiliency (and other terrorist

cells) through constant technical innovations and enforcing

the policies set by the U.S. and sanctioned by a unified

44

U.N. only in this way can we successfully stop terrorist

financing.

"Money laundering and the financing of terrorism are

financial crimes with economic effects. They can

threaten the stability of a country's financial sector

or its external stability more generally. Effective

anti-money laundering and combating the financing of

terrorism regimes are essential to protect the

integrity of markets and of the global financial

framework as they help mitigate the factors that

facilitate financial abuse. Action to prevent and

combat money laundering and the financing of terrorism

thus responds not only to a moral imperative, but also

to an economic need." (Zhu M, 2012)

Implementation of Plan

The implementation of this plan will begin immediately

and will follow guidelines set in the following objectives

to ensure compliance and success. This plan will take place

over a five-year period focusing on each objective starting

at the beginning of each calendar year. For example;

45

objective one will begin January 2014, objective two

commences January 2015, objective three January 2016, and

objective four January 2017. The fifth year beginning with

January 2018, will focus on adapting the objectives to new

intelligence gathered as well as feedback from our agents.

The plan is designed as a foundation to build from;

predictably leading to success. To ensure accomplishment of

this plan it is imperative that the plan has the flexibility

to remain malleable during its growing process. The

objectives of the plan and strategies are described:

Objective 1:

The first step in implementing this plan begins with

safeguarding the financial system against corruption by

freezing terrorist assets and following the flow of money

back to terrorist originations. Terrorist or criminal

access to our financial market poses a threat to the

national security of the U.S. and the U.S. financial system.

The September 11th attacks on the World Trade Centers cannot

be looked at as a coincidence. These attacks were executed

in hopes of destroying our financial network and destroying

46

America. Now our focus must be on preventing terrorist from

integrating itself into our financial market to support

terroristic missions. The strategies must be implemented in

order to achieve our desired objectives; protecting specific

areas of the financial industry by utilizing our anti-money

laundering programs following the rules and regulations

under the Bank Secrecy Act. Any suspicious activity must be

reported immediately and an extremely detailed record of the

activity is required. Informing financial institutions of at

risk activity and properly training them to ensure

compliance, while encouraging employees to report suspicious

activity. Constantly informing small businesses and the

public to be mindful of terrorist activities and their

financing methods. When a report is generated and has

successfully reached TFOS, we will then engage our plan to

either freeze the assets or follow the money; using the

institution to further gather information. Success will be

measured by tracking the financial institutions efforts on

freezing assets. This measure will be effective because it

will show in real-time and whole dollar amounts how much was

47

seized and from where. Allowing our field agents to

continually follow the trail and develop new leads.

Objective 2:

To prevent or reduce the flow of capital to support

terrorism, by preventing money laundering and other

monetarist crimes. The Terrorist Financing Operations

Section combined with the FBI is one of the largest

collectors of financial intelligence in the U.S.; the

information collected is extremely valuable as an

investigative tool that will expose terrorist funding and

other financial crimes. The data will be collected and

placed strategically in order to allow an agent to follow

the trail of money in a chronological order. We will

continuously expand our analysis of pertinent information as

well as classified information to better allow for the

section to adapt and evolve with the terrorist (flexibility

in our approach is key). The fist step to accomplishing our

mission is to ensure we have established a secure

infrastructure that will allow us to analyze classified

data; as the information increases so will the need for more

48

field agents to disburse the workload. This will also

create the need to ensure our agents are constantly being

trained and updated on new information immediately. No

agent field or otherwise will be authorized OJT they will

all complete the mandatory curriculum before engaging and

acting on behalf of TFOS. Remembering that this objective

will consistently grow and change in real-time, agents must

be flexible and willing to adapt immediately to ensure the

growth of the section and implement new technology.

Finally, we must ensure that constant supervision over the

financial institutions to ensure compliance with asset

freeze program. It is TFOS agent’s responsibility to

analyze financial institutions data to ensure compliance

with the programs set in place; any data that is not

characteristic or reasonable will constitute a red flag in

that institution. Where we will need to follow the

interactions of the institution to establish whether it has

been compromised, infiltrated, or supporting terrorist cells

or organizations. If this is established and confirmed that

either the bank is helping terrorist activities in money

49

laundering or funding our agents have the authority to act

immediately and freeze the institution until we can complete

our investigation thoroughly. Success will be measured by

the monetary value seized that was prevented from reaching

its destination. It will also be analyzed by the amount of

terroristic activities before and after, to establish what

cell or organization was impacted.

Objective 3:

Increase international collaboration to freeze funding

of terrorist while establishing a strong stance against

money laundering As TFOS is part of the financial crimes

enforcement network; we are members of the Egmont Group a

group of financial intelligence units (FIU) allowing us to

collaborate effectively using over 139 member FIU’s. The

main objectives and goals of these FIU’s are to promote the

exchange of ideas as well as training opportunities for

these units. In order to be successful it is vital that

these units around the world cooperate effectively in the

fight against terrorism, money laundering, and the financing

or support of terrorism through monetarist support. TFOS

50

will remain the leader in the financial intelligence field;

combating terrorist funding, therefore it is imperative that

we excel in our leadership role while involved in the Egmont

process. This will allow TFOS to increase awareness and

help develop international cooperation. With the focal

point remaining to attack the financing of terrorism at the

international level leading to a more secure financial

network globally. TFOS will develop and implement new FIU’s

in regions that are deemed more susceptible to terrorism

funding and money laundering, in areas such as the Middle

East. TFOS will develop and train these new FIU’s to ensure

compliance will the universal goal established and

sanctioned by the U.N. While TFOS is developing these new

agencies it will allow us to work on interagency

communications and expand our knowledge on the overall

picture. TFOS will also establish cross-training measures

within these units to ensure the amount of knowledge is

shared internationally as well as building trust and

camaraderie amongst peers in these FIU’s. As these FIU’s

develop and grow and each new unit is established it is

51

crucial that leadership is established to ensure compliance

of the objectives and to ensure collaboration amongst the

units. Constantly reinforcing the idea of communicating and

sharing information if the terrorism financial sections.

Success will be measured by the amount of FIU’s established;

they must be running efficiently and effectively will little

support. This will only be accomplished through proper

training, mentoring and development of their field agents.

Success will also be tested during times of real life

situations and how effectively communication flow within the

units.

Objective 4:

Ensure compliance with intelligence sharing to ensure

timely and relevant information is being passed through SIPR

domestically as well as internationally. This objective

will be the most challenging; even with the known threat of

terrorist activity around the globe. TFOS has established

that in order to achieve success in fighting the funding of

terrorism we must gather and rapidly disperse accurate

intelligence in order to follow the money trail. The data

52

that is collected and managed by all agents within TFO’s as

well as the FIU’s must maintain its integrity to ensure well

derived leads can be established and followed. It is our

focus to ensure we expand on the proper technology to ensure

we have the ability to meet this objective. When used

correctly these methods will dramatically increase our

response times and allow for tremendously fast transfers of

information to appropriate units. The strategy is to take a

very aggressive stance in this area to encourage and enhance

a more secure and easily accessible web-based product to

analyze and transfer data that can be shared amongst all

units. It will also become necessary for TFO’s to provide

the technology training necessary to all units in order to

accommodate this objective. During training sessions TFO’s

will ensure that a single member from each unit is available

to guarantee that collaboration, ideas, information sharing

as well as feedback is available for these field agents to

report back to their units and disperse the information.

The training provided will remain under strict guidance and

controls to safeguard the integrity of the training and

53

enhance our international relationships. Success will

ultimately be measured by the development of a user-friendly

web-based system that allows our field agents to easily

communicate and analyze necessary data in order to stop the

flow of money to support terrorism.

Schedule for Performance Assessment

To ensure our success with the strategic plan, it will

be necessary to access the plan on a monthly basis. Each

objective will receive the attention of 12 meetings, over

the span of one year, to ensure we are on track to meet our

goals. These conferences will take place on the 1st Monday

of every month, this will be designated as a training day

and the entire section of TFOS will be present and three

representatives from each FIU (to ensure international

compliance). The first portion of the meeting will focus on

the challenges with achieving our objectives, meaning what

areas need adjusted or improved to ensure our success. The

second portion will focus on what part of our strategic plan

is successful and why it was successful. The final and third

54

portion of our conference will focus around team building,

we will design programs and activities that allow for agents

to work in teams; they will be required to successfully

prevent a false terrorist attack. This will allow for the

agents to develop some possible new strategies in

successfully obstructing the flow of money to terrorist

cells. It is also, important to keep in mind if we are

failing to achieve our objectives then we must immediately

adjust to guarantee success in our endeavors. The

assessment of TFOS development will happen simultaneously

with the growth of our sections on a daily basis, the

constant analysis of data will prove our overall success.

The only true measures of success will be the effective

countering of terrorist financing through multiple measures,

that include asset-freezing, deterrence, disruption, or

prevention of terrorist attacks; and the identification of

new terrorist cells, suspects and their supporters.

Summary

The strategic plan presented will allow TFOS’s

influence to spread internationally and allow for a wide

55

array of information sharing globally. TFOS will remain the

tip of the spear in these endeavors, while leading our

international peers to success as well as protecting America

from terrorist attacks. As financial institutions become

aware of terrorist activities they will become exceedingly

successful at freezing and preventing the funding of

terrorism. Allowing the initial constriction of lifeblood

supporting these terrorists. This will permit our agents to

begin following the money trails that are left behind; this

information will become our most valuable investigative

tool, permitting us to branch off into distinctive areas of

terrorist financing. The agents will follow all leads to

either a dead end, or a successful capture and seizure of

either terrorists or their money. During this process of

following the money, it will permit our agents to ensure

compliance with the asset-freezing program internationally.

The field agents will unavoidably be working overseas while

following these leads, this will allow them access to the

other FIU’s offices, while the agents are there it will

allow them to oversee the development of the asset-freezing

56

program. The agents will either encourage them to freeze

known terrorists assets or report them for their non-

compliance; leading to a quick reprimand and exposure of

their sections failures. This is necessary to ensure the

integrity of the FIU’s and to ensure they remain fearful of

TFOS rather than the terrorist. If an agent realizes an FIU

has been compromised the unit will be immediately shut down

and disbanded while each individual will be placed in

discrete holding cells until they can be aggressively

interrogated. This measure in itself will also be a

successful attack against terrorist and their infiltration

into the global financial market. Our agents will be

trained to be ever vigilant in areas such as the Middle East

that are easily susceptible to terrorist funding. However,

not all FIU’s are will be under a negative light; with our

agents travel overseas this will allow for more information

sharing amongst peers in our field. This will encourage

international collaboration and ensure that our counterparts

develop a trusting relationship that will foster growth and

success in our fields. Making the information sharing

57

process vital in the success of stopping terrorist funding.

The terrorist will remain a global threat; they are

dispersed all over the world and communicate effectively

amongst their cells, and just as they are mobile, we will

become their shadow that follows the trail leading to their

demise.

Chapter Four

58

Conclusion

September 11, 2001, was a wakeup call to all

Americans, as well as the international population,

challenging everyone’s policies on countering and preventing

terrorism. Up to that point terrorist attacks were not

necessarily on the catastrophic level such as 9/11, claiming

only a small number of lives and property damage, never

truly pushing the United States government to change its

policies regarding terrorism. We previously had the

misconception that our government was managing terrorism

effectively, never allowing any real threats to reach our

doors. America truly believed that living in the United

States made them impenetrable to terrorist attacks or

invasions. September 11th was the foundation that leads to

policy changes nationally and internationally, opening our

eyes to the enemy’s far-reaching capabilities, and

highlighted our previous policies, proving the need for

modification. The reactionary stance our government was

taking against terrorism was no longer effective, making it

crucial that the United States as well as the international

59

community; to develop a campaign against terrorism as a more

offensive approach. Allowing us to take the offensive route

we established the USA Patriot act specifically Title III,

allowing the FBI the ability to counter terrorist financing,

leading to the development of TFOS. The success of this

plan relied solely on its ability to undermine terrorist

financial networks. The TFOS has proven it has the ability

to bridge the gap between local and state governments with

the need to gain support internationally, in order to attack

terrorism on a global level. TFOS most valuable

contributions has been from their development of financial

profiles, of terrorist organizations, providing a solid

foundation to predict terrorist financing operations,

stemming from investigations and “following the money”.

These methods have been building attention domestically and

internationally helping TFOS develop laws that have become

sanctioned by the U.N. to combat terrorist financing and

funding worldwide. TFOS has remained the tip of the spear

and will continue to develop new FIU’s in sections of the

world that are susceptible to terrorism allowing us a strong

60

hold in their operating grounds. TFOS has helped to develop

these laws domestically and internationally, however,

internationally is still proving to be a challenging

endeavor.

Terrorist Financing Operations Sections will continue

to develop our relationships with the international

governments and communities, educating our predecessors on

the processes of denying access by terrorist and their

supporters to the international financial system. While

continuously pressing the matter of open lines of

communication as well as valuable feedback provided from

field agents. Combating terrorism cannot rely solely on

military engagements, it must include coordinated attacks

from our FIU’s orchestrated by TFOS to disrupt, prevent, and

seize all assets of terrorist related financing. These

proactive measures will allow us to take an offensive stance

against terrorism and effectively prevent another 9/11-size

assault. In order for us to realize success in our

endeavors against terrorism, we must continue to adapt to

the ever-mobile terrorist cells. We must continue our

61

efforts internationally to develop open lines of

communication, and we must continue to work together

globally sharing vital information and resources to further

our cause against terroristic attacks. The focus must

remain on constricting the flow of money to terrorist, by

safeguarding our financial systems, freezing terrorist

assets, following the money trail, and developing

international relationships that are conducive to mission

success. This is how we will attain our vision to constrict

the Life Blood of Terrorism, (financial flow) and prevent

terrorist attacks domestically and internationally; starving

the terrorists of funding driving them from their hiding

places and relentlessly attacking them until they are unable

to operate.  Using their fear against the extremist driving

them to a state of paranoia, and making them turn on one

another.  We will force anyone supporting them to abandon

immediately leaving them vulnerable and exposed. Inevitably

leading to the end of terrorism.

Recommendation

62

In order for the plan and measures to achieve success,

we must gain attention and support from the U.N., with the

support of our international brethren the attack on

terrorist funding and financing will begin. It is necessary

that specific consequences be established from the beginning

to ensure member states are compliant with the rules and

regulations established. With a plan supported by the U.S.

and sanctioned by the U.N. member states will be forced into

compliance, out of trepidation of the consequences they will

be forced to maintain their character and integrity in the

fight against terrorism universally. We must be allowed to

aggressively pursue whatever means necessary to deny the

funding or financial support of terrorism, and have the

ability to serve swift consequences to those who choose the

latter. As a universal stance we must establish the mindset

that terrorism can, and will cease to exist, when all

parties domestically and internationally unite against this

atrocity, to protect humanity and destroy terrorism leaving

the world a secure and safer place. We can make military

attacks unnecessary, if the terrorist can no longer support

63

their supply and logistics train. When this stance is taken

globally we will ensure the end of terrorism.

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