| |
BLOOD MONEY
Part 2: On the terrorists'
global money trail
Part
1: Searching for buried treasure
For outside
observers, the tactical actions that have been taken are
difficult to evaluate, as much of the subject matter is
highly classified. However, based on the personal
experiences of many members of the task force and on
informal conversations with others who are currently
working on this subject officially in the United States
and other countries, we can confidently conclude that
the United States has received markedly improved
cooperation from most key foreign governments, both on
law enforcement and intelligence matters. Though some
task force members retain significant doubts, as a group
we accept the administration's generalized assurances
that the degree of tactical law enforcement and
intelligence cooperation now being received is broadly
satisfactory.
Similarly, the general willingness
of most foreign governments to cooperate with US-led
efforts to block the assets of designated persons and
businesses with ties to terrorist financing has been
welcome and unprecedented. However, in this area
obstacles have emerged and the coalition may be fraying.
The frequently cited total amount of terrorist-related
assets blocked overstates the amount of money taken from
al-Qaeda and its supporters specifically, and
undoubtedly represents only a small fraction of total
funds available to that terrorist organization. Certain
countries had difficulties implementing blocking orders
owing to deficiencies in their technical capabilities or
regulatory infrastructure. Moreover, after a quick
start, the rate of blocking has clearly slowed.
America's closest allies in Europe are now
publicly complaining that the United States is unwilling
to share intelligence on many designated individuals or
organizations. As a result, they are refusing to block
bank accounts in some cases. On the other hand, only a
handful of European states have invested the minimal
resources necessary to develop their own intelligence
capabilities in the Middle East and South Asia, so they
too could play a leading role in identifying and
disrupting terrorist financial networks.
Many
observers have noted a widening divide between the
United States and Europe on the basic salience and
parameters of global terrorism. This has repercussions
on the financial campaign, and many US allies, as a
matter of policy, apply the blocking orders
inconsistently. The European Union, for instance,
forbids fundraising only for the "military wing" of
Hamas - Izzedine al-Qassam Brigades - even though funds
raised by other branches of Hamas for purportedly
humanitarian purposes are known to be used for terrorist
attacks. The European Union does not forbid the
Iran-backed terrorist organization Hezbollah from
fundraising at all. (The policy divide is even greater
in the Middle East, where almost no country
characterizes Hamas or Hezbollah as terrorist
organizations. Many allow, and even encourage, those
terrorist organizations to fundraise on their soil.)
And finally, Europe's own domestic institutional
capacities are often found wanting. The annual number of
suspicious activity reports (SARs) submitted by
financial institutions in many European countries has
long been unusually low. As the recent report of the UN
group monitoring global sanctions against members of
al-Qaeda and the Taliban noted, EU efforts are hampered
by lax border controls in many European countries,
particularly those in the Schengen Area group - 13 of
the 15 EU member countries that abolished border
controls among themselves - and the "stringent
evidentiary standards" required by certain European
legal systems to block assets.
And finally, as
Brown University's Watson Institute documented in its
research on targeted financial sanctions several years
ago, while the US Treasury's Office of Foreign Asset
Controls (OFAC) had more than 100 staff working full
time on implementation of financial sanctions (and was
still understaffed), the Bank of England had a staff of
about seven, the French Ministry of Finance had two
people working part-time, the German Bundesbank had one,
and the European Commission in Brussels had only one
person and a half-time administrative assistant.
This being the case, the administration's recent
announcement of a "second phase" in the war against
terrorist financing that will rely on greater leadership
by America's coalition partners may well be overly
optimistic, and risks not producing future tactical
successes. Greater participation of US coalition
partners in the targeting process is welcome and can
help further international cooperation. But coalition
efforts will most certainly require US leadership to
maintain the momentum that has been achieved since
concerted international efforts began last year.
At the same time, the US government has not made
full use of all relevant legal and policy tools at its
disposal. IEEPA designations - among the most powerful
tools in the US legal arsenal - have become less
frequent, and have focused primarily on the "low-hanging
fruit" in countries like Yemen and Somalia. In the
"second phase" they will, as a matter of policy, become
less frequent still. None of the new "special measures"
provided to the secretary of the Treasury in the Patriot
Act to restrict or prohibit access to the US financial
system have ever been used. Not once.
Any
weaknesses in the US government's tactical responses to
terrorist financing have been exacerbated by the lack of
interagency coordination within the US government on
these issues. This problem is compounded by the
multifaceted nature of the terrorist financing problem,
which requires information to be shared both among and
between the US diplomatic, intelligence, law enforcement
and regulatory communities.
After September 11,
for example, officials from the Treasury Department, the
Central Intelligence Agency, and other agencies wrangled
over the president's direction to form a Foreign
Terrorist Asset Tracking Center. The center was intended
to serve as the lead organization within the US
government on issues pertaining to terrorist financing.
Despite the fact that US$6 million was appropriated and
spent to construct facilities for the center within the
Treasury Department, after months of bureaucratic
infighting the group ended up at the CIA, and the
facility constructed to house the center at the Treasury
Department stands empty.
Relevant law
enforcement functions are divided between the Federal
Bureau of Investigation (FBI) and enforcement agencies
of the Treasury Department, such as Customs. FBI
officials complain that they are not adequately apprised
of Treasury-led initiatives (such as the Customs-led
"Operation Green Quest"), and vice versa. And
coordination problems exist within particular agencies.
Since the September 11 attacks, the American public has
learned about some of the structural, cultural and
technological barriers within the FBI that prevented
certain parts of the organization from getting access to
important information held by other parts.
Turning to the strategic initiatives to combat
terrorist financing, obstacles to effective action
appear increasingly insurmountable, at least given the
current approach.
Far too many key countries -
including virtually all in the Middle East and South
Asia - still have in place ineffective or rudimentary
bank supervisory and anti-money laundering regimes. In
those cases where laws are on the books, implementation
has often been weak or nonexistent. The relevant
governmental institutions are not well developed, and
international law enforcement cooperation has been slow,
made inordinately difficult or simply refused
altogether. In no country - including the United States
- are either Islamic charities or the underground
hawala system effectively regulated.
Progress in these areas has simply not been made
a high enough priority. Judging from White House
briefings and reported accounts, it has unfortunately
become uncommon for the president or the vice president
to raise these subjects in bilateral discussions with
counterparts from key states. Rather, these discussions
have recently been left to working level subordinates, a
clear signal of their relative importance to the United
States.
Even in those cases in which laws have
been passed in recent years, effective implementation in
key states has generally not followed - with no adverse
repercussions. In 1999, for instance, Saudi Arabia
approved amendments to its existing money laundering
laws intended to bring it into compliance with
international standards, but to date these amendments
have not been implemented, according to the most recent
State Department reports. Pakistan only recently
announced plans to introduce amendments to its
Anti-Terrorism Act of 1997 that would, consistent with
international standards, criminalize the laundering of
terrorist funds and fundraising by terrorists.
The never-used punitive provisions of the
Patriot Act were intended to provide critical leverage
over recalcitrant states to assure sustained compliance
in these areas. So too, in recent years, was a FATF
"blacklist" of noncooperative countries in the
international fight against money laundering. Within one
year of the first such FATF designations in 2000, for
example, eight of the 15 states included on the FATF
blacklist took steps to bring themselves into
substantial compliance with international standards.
It is unfortunate that the United States has
recently avoided full use of these powerful levers of
influence. The United States recently allowed Lebanon,
for example, to be removed from the FATF blacklist
before it demonstrated a commitment to real
implementation of its new anti-money laundering law and
despite what the State Department's own report on the
subject called its "historical commitment to bank
secrecy". Egypt has been allowed to stay on the FATF
blacklist without any real threat of sanctions - and may
soon be removed without any real implementation. And as
this report was going to press, published reports
indicated that, with the acquiescence of the United
States, the FATF blacklist process would be suspended
and "superceded" by a "universal, cooperative approach".
Aside from compromising enforcement
capabilities, the failure to build institutional
capacities has resulted in the neglect of nascent
international efforts to develop, analyze, and share
financial intelligence. In 1995, international efforts
resulted in the formation of the Egmont Group, which was
intended to knit together like-minded nations focused on
preventing financial crimes through the work of
Financial Intelligence Units (FIU) in each member
nation. Each FIU would develop and analyze financial
intelligence with respect to its jurisdiction and share
that information with other member nations, enabling
each to develop better intelligence in respect of
financial flows beyond its jurisdiction. However, a lack
of resources and technical capacity in most member
nations of the Egmont Group has prevented this effort
from realizing its theoretical potential. Indeed,
America's FIU - the Treasury Department's Financial
Crimes Enforcement Network (FinCEN) - is vastly
under-resourced and lacks the capacity to serve as the
FIU for the US government. Implementation of the Patriot
Act will significantly increase the burdens on FinCEN,
making resource restraints and effectiveness concerns
even more acute.
It would be wrong to say that
no progress has been made in building many countries'
institutional capacities to cooperate in the global war
against terrorist financing. But it would be equally
wrong to overstate the progress that has been made - a
fault that is too often made by US government
spokespersons. In recent years, for instance, it is true
that Saudi Arabia has taken two or three important steps
to improve its capability to cooperate on these matters
with the United States, for which it should be
commended. A hundred more steps and Saudi Arabia may be
where it needs to be.
This is not to ignore the
political context in which those steps are being taken
or avoided. It may well be the case that if Saudi Arabia
were to move quickly to share sensitive financial
information with the United States, regulate or close
down Islamic banks, incarcerate prominent Saudi citizens
or render them to international authorities, audit
Islamic charities and investigate the hawala
system - just a few of the steps that nation would have
to take - it would be putting its current system of
governance at significant political risk. Successors to
the current regime could easily be drawn from the very
elements in their societies that the United States is
seeking to suppress.
However, it may just as
well be the case that by not moving quickly to combat
the infrastructure of terrorist financing on their own
soil, these governments are allowing the terrorists and
their supporters to gain strength and influence steadily
among their own populations - and in so doing are
setting the stage for their own eventual demise.
In truth, nobody knows which scenario is more
likely. In the past, the first scenario provoked the
most concern, both inside the ruling families of the
nations in question and among US government regional
experts. As a result, the United States did not
seriously push these countries to make necessary
reforms. However, in the wake of the terrorist attacks
of September 11, both the United States and the royal
families in the concerned states must recognize the
risks of inaction and must push reform efforts far more
aggressively.
Fundamentally, US efforts to
curtail the financing of terrorism are impeded not only
by a lack of institutional capacity abroad, but by a
lack of political will among US allies. Some have a
history of "turning a blind eye" to the problem, some
simply do not ascribe the same priority to the issue -
or perceive correctly or incorrectly that US attention
to the subject has waned. Some fear the domestic
political repercussions of taking action, and some
simply disagree with the US view of the nature and
severity of the problem.
Confronted with this
lack of political will, the administration appears to
have made a policy decision not to use the full power of
US influence and legal authorities to pressure or compel
other governments to combat terrorist financing more
effectively. Nearly all steps taken have been tactical
rather than strategic in nature. And the lack of a
single senior US official with the mandate to define,
direct, and reaffirm US policy on a day-to-day basis
reflects and compounds this strategically deficient
approach.
Principal findings
The task
force recognizes and welcomes the recent progress that
has been made in combating terrorist financing, both at
home and abroad. It congratulates Congress and the Bush
administration - and President Bush personally - for
focusing on this issue, particularly in the immediate
wake of the September 11 terrorist attacks.
Notwithstanding substantial efforts, the task
force finds that currently existing US and international
policies, programs, structures and organizations will be
inadequate to assure sustained results commensurate with
the ongoing threat posed to the national security of the
United States. Combating terrorist financing must remain
a central and integrated element of the broader war on
terrorism.
Two administrations have now grappled
with this difficult, cross-cutting problem. Neither has
found a single "silver bullet," because none exists.
Given the very nature of the problem, it must be
continually "worked" rather than "solved".
Gaining international cooperation though a mix
of incentives and coercion is a necessary prerequisite
for progress. Effective international efforts will
require strong US leadership. Deficiencies in political
will abroad - along with resulting inadequacies in
regulatory and enforcement measures - are likely to
remain serious impediments to progress. One-time
affirmations cannot substitute for sustained
enforcement, regulatory and institution-building
measures.
In the short term, "following the
money" can go a long way toward disrupting terrorist
cells and networks, and thereby help prevent future
terrorist attacks. But real and sustainable success will
be achieved only over the very long term, as key
countries make fundamental changes to their legal and
regulatory environments.
Long-term success will
depend critically upon the structure, integration, and
focus of the US government - and any intergovernmental
efforts undertaken to address this problem.
Structural recommendations
With these
findings in mind, the task force makes the following
core structural recommendations: First, the president
should designate a Special Assistant to the President
for Combating Terrorist Financing with the specific
mandate to lead US efforts on terrorist financing
issues. Such an official would direct, coordinate and
reaffirm the domestic and international policies of the
United States on a day-to-day basis and with the
personal authority of the president of the United
States. He or she would report to the president through
the national security adviser. In addition, he or she
would serve as sous-sherpa to the G-7 and chief US
representative to all important regional organizations
with respect to terrorist financing issues once they are
made permanent agenda items as described below. He or
she would be responsible for implementing the strategic
and tactical recommendations contained in this report
and leading US efforts with respect to the international
initiatives described below.
The United States
should lead international efforts, under the auspices of
the G-7, to establish a specialized international
organization dedicated solely to combating terrorist
financing. Such an organization would assume ad hoc
terrorist financing-related initiatives undertaken by
the FATF since September 11, 2001, and support and
reinforce the activities of the UN Counter-Terrorism
Committee undertaken since that time to coordinate and
assist in the implementation of member states'
obligations under Security Council resolutions
pertaining to terrorist financing. Membership in this
specialized organization could initially be limited to
the G-7 itself, an approach similar to that taken by the
G-8 in 1994 in forming the Lyons Group against
international crime. Membership could then be expanded
to include other states with highly developed financial
regulatory and enforcement systems that are committed to
the top-down promulgation of the most stringent
international standards to combat terrorist financing.
This new organization would be tasked with the
implementation of the multilateral initiatives described
below.
Strategic recommendations
The
US should put issues regarding terrorist financing front
and center in every bilateral diplomatic discussion with
every "front-line" state in the fight against terrorism
- at every level of the bilateral relationship,
including the highest. Where sufficient progress is not
forthcoming, speak out bluntly, forcefully, and openly
about the specific shortfalls in other countries'
efforts to combat terrorist financing. The task force
appreciates the necessary delicacies of diplomacy and
notes that previous administrations also used phrases
that obfuscated more than they illuminated when making
public statements on this subject. Nevertheless, when US
spokespersons are only willing to say that "Saudi Arabia
is being cooperative" when they know very well all the
ways in which it is not, both our allies and adversaries
can be forgiven for believing that the United States
does not place a high priority on this issue.
The US should reconsider the conceptually flawed
"second phase" policy that (1) diminishes the likelihood
of additional US designations under IEEPA of foreign
persons and institutions with ties to terrorist
finances, and (2) relies on other countries for
leadership, a role they are not suited for nor willing
to play. IEEPA designations and blocking orders - actual
or threatened - are among the most powerful tools the
United States possesses in the war on terrorist
finances. The United States should not relinquish them,
nor should the United States relinquish US leadership to
coalition partners uninterested or unsuited for this
role.
As an example to US friends and allies,
the government should bring hawaladars and other
underground money service businesses fully into the
federal regulatory system. During both the Clinton and
Bush administrations, FinCEN has been very slow in its
efforts to register hawaladars. There is
currently no federal plan to coordinate federal, state,
and local law enforcement efforts to identify, surveil
and prosecute unregistered hawaladars. FinCEN
should immediately make its register of money services
businesses available online, to facilitate the use of
the information by federal, state and local law
enforcement agencies seeking to determine the legality
of local money changers' and money transmitters'
operations.
Similarly, as a further example to
America's friends and allies, the government should
require charities operating in the United States to
abide by certain US anti-money laundering laws, by, for
example, having the Treasury Department define them as
"financial institutions" for purposes of implementing
any "special measures" put in place pursuant to the
Patriot Act.
The US should expand bilateral
technical assistance programs in problem countries to
assist in the creation of effective regulatory,
enforcement and control regimes for financial
institutions and charitable organizations. The
president's fiscal year 2003 budget includes only US$4
million for the Treasury Department's Office of
Technical Assistance to provide training and expertise
to foreign governments to combat terrorist financing;
funding for such efforts should increase at least
tenfold. Rather than being distributed directly to
individual providers, such funds should be centralized
and then distributed to appropriate providers,
consistent with priorities established by an interagency
process. Integration and coordination of such assistance
is vital so that such assistance reflects administration
policy. The United States should urge other nations with
developed financial regulatory infrastructures, and the
IMF and World Bank, to provide similar assistance.
The US should immediately develop and implement
a comprehensive plan to vet and conduct background
investigations on institutions, corporations and
nongovernmental organizations that receive US government
grant funding to ensure that US funds are not diverted
to organizations that either have links to terrorist
groups or a history of supporting terrorist aims.
The US should, for the first time, make use of
the new powers given to the secretary of the Treasury
under the Patriot Act to designate individual foreign
jurisdictions or financial institutions as being of
"primary money laundering concern" to the United States,
and thereby impose sanctions short of full IEEPA
blocking orders. These sanctions could include cutting
off correspondent relations between foreign financial
institutions with weak anti-money laundering practices
and US banks. Unlike IEEPA, these "special measures" do
not require presidential action and do not require the
United States to prove a specific connection to
terrorism, only that the jurisdictions or institutions
targeted do not have adequate anti-money laundering
controls-a much lower hurdle.
Tactical
recommendations
The US should create streamlined
interagency mechanisms for the dissemination of
intelligence, diplomatic, regulatory and law enforcement
information. All information relating to terrorist
financing - regardless of its source - should be
centrally analyzed and distributed to all relevant
policymakers. The formation of the CIA-based Foreign
Terrorist Asset Tracking Group is a good start, but
adequate budgets should be requested, and intelligence
agencies will need to build up the level of linguistic,
financial, and cultural expertise to investigate and
combat Islamic terrorist financing effectively.
It should also broaden US government covert
action programs to include the disruption or dismantling
of financial institutions, organizations and individuals
knowingly facilitating the financing of terror.
Information warfare - computer hacking - and other forms
of disruption should be considered when intelligence
compellingly demonstrates that foreign financial
institutions are knowingly and actively participating in
the financing of terrorism.
The US should
reinvigorate US intelligence and law enforcement
capacities against terrorist finance by further
strengthening FinCEN. As the financial intelligence unit
for the United States, FinCEN needs to be able to play a
significant role in terrorist finance intelligence and
analysis; liaise with other financial intelligence units
and with domestic and international training and
institution building efforts to combat terrorist
finance; and play a role in international regulatory
harmonization. The administration should act promptly to
strengthen FinCEN's funding, personnel, and authorities
to make it possible for FinCEN to perform these roles.
Multilateral recommendations
The new
international organization dedicated solely to issues
involving terrorist financing would be tasked with the
implementation of the multilateral initiatives described
below. Contribute to agenda-setting for the G-7 and
other international and regional organizations, as
described below.
From the top down, all
countries should establish strong international
standards on how governments should regulate charitable
organizations and their fundraising. Once those
standards have been set, have technical experts publicly
evaluate countries, including those in the Middle East,
against them.
Countries should engage in similar
international standard setting with regard to the
regulation of hawala, and create and maintain a
global registry of institutions that participate in
hawala and similar alternative remittance
systems.
Countries should work with the private
and nongovernmental organization sectors to create
global "white lists" of financial institutions and
charities that, regardless of the legal environment in
their home jurisdiction, commit to the highest due
diligence, anti-money laundering, and anti-terrorist
financing procedures, and agree to a system of external
assessment of compliance.
In addition to the
reputational benefit from being included on such a
"white list," inclusion on the list could be a factor
taken into consideration by the World Bank, the IMF and
other international financial institutions (IFIs) in
considering which financial institutions to work with.
It could similarly be a factor taken into account by the
US Agency for International Development (USAID) and
other national development and humanitarian relief
agencies, as well as the United Nations High
Commissioner for Refugees (UNHCR), the United Nations
Development Program (UNDP), and other multilateral
agencies in determining what charities or relief
organizations to work with.
All countries should
facilitate multilateral cooperation and information
sharing between the various government offices
responsible for sanctions enforcement, such as the US
Treasury's Office of Foreign Asset Controls (OFAC). This
will require each government to identify a central
contact point to coordinate implementation of efforts to
block terrorist finances. They should also facilitate
the provision of technical assistance to all countries
that need it, and further the development of the Egmont
Group and capabilities to develop and share, on an
intergovernmental basis, tactical financial
intelligence.
Countries should recommend to the
IMF ways in which its funding can be made contingent
upon countries' implementation of strict anti-terrorist
financing laws, and make formal recommendations to the
FATF concerning which countries should be included in
its "naming and shaming" processes on the basis of
passive acquiescence to terrorist financing.
Countries should establish procedures for appeal
and potential removal of the names of individuals and
institutions wrongly designated as being associated with
the financing of terrorism. Legitimate disquiet in some
quarters concerning the potential for due-process
violations associated with the inaccurate listing of
targeted individuals can retard progress in global
efforts. Since the full sharing of sensitive
intelligence information is unlikely, the establishment
of such procedures will take such concerns "off of the
agenda" and prevent them from being used as an excuse
for inaction.
Terrorist financing should become
a permanent agenda item of the G-7/8 and a permanent
part of the agenda of all regional organizations as
appropriate, such as the Association of Southeast Asian
Nations (ASEAN), Asian-Pacific Economic Cooperation
(APEC), and the US-SADC (Southern African Development
Community), among others.
Terrorist financing
should become a permanent agenda item of the
twice-yearly EU-US summit. The Senior Level Group of EU
and US officials, which meets two or three times a
semester, can and should act as a "scorecard" to monitor
the progress of transatlantic cooperation.
Rather than superceding the FATF process of
"naming and shaming" non-cooperative jurisdictions in
the fight against money laundering with a "cooperative"
approach, the G-7 should agree to resume and expand
immediately the blacklisting of such countries.
Countries on the FATF blacklist should be ineligible for
certain types of IMF and World Bank lending. Once
reinvigorated, the FATF needs to begin requiring full
implementation and enforcement of laws and regulations,
not just their passage or issuance. The World Bank
should provide technical assistance to less developed
countries to help them establish anti-money laundering
and anti-terrorist financing regimes that meet
international standards.
Significant "source and
transit" countries - especially Saudi Arabia, Pakistan,
Egypt the Gulf States and other regional financial
centers - have special responsibilities to combat
terrorist financing. They should make a fundamental
policy decision to combat all forms of terrorist
financing and - most importantly - publicly communicate
this new policy to their own nationals.
They
should cooperate fully with international - especially
US - requests for law enforcement assistance and
intelligence requests for information and other forms of
cooperation. This means, among other things, allowing US
investigators direct access to individuals or
organizations that are suspected of being involved in
terrorist financing. They should bring their bank
supervision and anti-money laundering laws, regulations
and institutions completely up to international
standards, and have them cover all financial
institutions, including Islamic and underground ones -
like the hawala system. Implementation of laws is
necessary, not just their drafting and passage. For the
most part, these countries each have the resources to do
this themselves. If not, international financial and
technical assistance are readily available from a
variety of multilateral and bilateral sources. The UN
Counter-Terrorism Committee has compiled a directory of
sources of support for this purpose.
They should
require the registration and licensing of all
alternative remittance mechanisms, such as
hawalas, and close down financial institutions
that fail to obtain licenses or that fail to maintain
adequate customer and transaction records. They should
fully and unapologetically regulate charities subject to
their jurisdiction, particularly those with branches
dispersing funds overseas. Donors to legitimate
charities deserve to know that their money is actually
going to good causes; unknowing donors to illegitimate
charities deserve to know they are being defrauded;
individuals who knowingly donate to terrorist front
organizations deserve to be prosecuted.
They
should fully regulate the trade in gems, precious metals
and other stores of value regularly used to store and
transfer terrorist wealth. This effort can draw on the
precedents established by international efforts (what is
known as the Kimberly Process) to curtail the trade in
"blood diamonds".
Recognizing that the financial
services sector does not have the necessary information
and intelligence to identify potential terrorists or
their activities, the US government should work
diligently with the financial services sector to create
new public-private partnerships that facilitate the
sharing of intelligence information.
Banks and
all other financial institutions should build specific
anti-terrorism financing components into their
compliance and due diligence processes. They should
utilize widely available name recognition software to
improve the efficiency of their compliance with
regulatory efforts. They should avail themselves of
reputable public and private sources of information on
the identities of persons and institutions who are
suspected of links to terrorist financing and who
therefore should be the subject of additional due
diligence. They should cooperate fully with any
multilateral efforts to build a "white list" of
institutions that have adequate anti-terrorist financing
controls. A key factor for inclusion on such a list
would be evidence of an institution's ability to
identify and manage potential risks, such as the
development and implementation of adequate anti-money
laundering controls.
Though the level of
dedication and effort in the realm of countering
terrorist financing within the US government has been
both impressive and comprehensive, there is still
insufficient creative and strategic thinking as to how
the financial network of an unconventional adversary
such as al-Qaeda might be defeated. There are numerous
proposed and implemented bureaucratic initiatives, many
of which have been mentioned here, but they lack the
same creativity and innovation that al-Qaeda financiers
use each day in their planning. Unless, as this report
suggests, one individual and one office emerge that will
focus and direct US government efforts, then our efforts
will remain divergent, and we will remain one step
behind the terrorists.
This article comprises
excerpts from the Independent Task Force Report on
Terrorist Financing, copyright 2002, by the Council on
Foreign Relations. All rights reserved.
|
| |
|
|
 |
|
