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National Commission
on the
TerroristAttacks upon the United States
o
Team
#4
Funding of
Terrorist
Activities
Team members: John RothDouglas GreenburgSerena
Wille
 
List of key
questions
1.
What are,
and
should
be, the
goals
of
government efforts
in the
area
of
terrorist
financing?
•
Government
efforts
concerning terrorist
financing
appear
to
have three goals:
(1)
obtaining intelligence regarding terrorist activities and operations; (2) disruption
of
terrorist activities and operations; and (3) depriving terrorists of resources
through
executive or judicial action. To what degree has the government
pursued
each of these goals? Have the goals changed over time? How muchemphasis should be placed on each of these goals?
• The
government
has
stated that
the
premise
of the
effort
on
terrorist
financing
is
that
"money is the lifeblood of terrorism." Given the demonstrated ability ofterrorists
to use
relatively tiny amounts
of
money
to
create significant attacks,
should
thisbe themost important goal?Are
efforts
directedat
that
goaldetracting
from
the other goals?
2.
Prior
to
9/11, what
did the
U.S.
do to
identify
and
stop terrorist
funding?
• The
primary public
effort
within
the
U.S.
was to
identify
and
name specificterrorist groups and then attempt to financially
isolate
them through the use ofexecutive orders.
How
successful were these
efforts?
•
Various government policies were instituted
to
allow
for
more
effective
tracking
and
attacking
of terrorist
assets.
What were
these
policies?
Did
they work?
Why
or why
not?
•
There have been
a
number
of the
public criticisms about
the
government's
pre-
9/11
efforts:
a failure to appreciate the threat, unclear roles among the institutionsinvolved,
a
failure
to
share information,
no
overall strategy,
and an
unwillingnessor inability to get the necessary cooperation
from
key
foreign
governments. Howvalid are these criticisms?
3. How
were
the
9/11
terrorists
able
to
generate
and
move their money?
•
What were
the
identifiable financial transactions
of the
hijackers? Where
did
they
get
their
funding,
where
did
they keep their
funds
in the
United States
and howdid
they distribute their
funds
among
the 19
hijackers?
Did
anyone
in the
UnitedStates itself provide
funding
to the
hijackers?
•4.
•
What
do
these transactions
say
about
how
organized, planned terrorist operations
operate
within
the
United
States?
Are
they different
from
otherterrorist
operations, suchasad-hoc terrorist operationsor themaintenanceofsleeper cells?
 
• How did
Al
Qaeda generally raise
and
move
funds
to
support itself
as an
institution?
For example, how did it raise money to pay for training camps and
bring
recruits
to
Afghanistan
for
training?
4. Does
the
fact that
the
9/11 hijackers were able
to evade
detection
and
disruption
tell
us
anything about
the
system
in
place
at the
time?
•
Were
the
various anti-money laundering controls
in
place
sufficient
to
detect
the
types
of
movement
of
money involved here?
Why or why
not?
Was the
existingsystem simply not designed to detect the type of transactions engaged in by the
9/11
terrorists?
• Was
there
any concerted
effort
to
track contemporaneously known terrorists
cells
through
their
financial
transactions? Did the government have the technicalabilityto do so? What would such a system look like?
•
What were
the
other deficiencies with
the pre
9/11
system?
For
example, werethere shortcomingsin
efforts
topreventtheabuseofcharities, regulate informal
money
transmitters,
identify
illegal trade-based money movements? Did we
effectively
engage key
foreign
governments, particularly Saudi Arabia, to assist?
5. What
are we
currently doing,
and
have
these
efforts
eliminated
the
deficienciespresent before
9/11?
• The
U.S. government
has
devoted substantial resources since
9/11,
includingenacting significant
new
regulations,
in an
effort
to
disrupt
and
curtail
the
funding
of
terrorist organizations. What were those changes?Arethey
effective?
Are the
deficiencies
that may have contributed to the
9/11
failures still present?
6.What specific, actionable policy
recommendations
can be
made
to
improve
the
current efforts
in
light
of the
lessons
of
9/11?
10
•
Should
the
goals
of the
efforts
regarding terrorist
financing
be
changed?
If so,
how?
• Is the
government effectively
organized
to
provide
for
adequate coordinationamong
the
various agencies
and
actors involved
in the
effort?
If
not,
how
could
the
structure be improved?
• How
has,
and how
will,
the
raising
and
movement
of
money
for
terroristoperationschange in response to government actions? Is there a move away
from
formalfinancial
systems into something more
difficult
to
detect?
Can thegovernment
recognizeandquickly adapttothose changes?
•
What
is the
best approach
to
increase
the
ability
and the
willingness
of key
foreign
states to track and disrupt terrorist financing?
of 00

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