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T4 B12 Workplan- Draft Fdr- 4-24-03 Workplan Team 4 (See T4 B1 Team 4 Workplan Fdr for Different Red Actions) 040

T4 B12 Workplan- Draft Fdr- 4-24-03 Workplan Team 4 (See T4 B1 Team 4 Workplan Fdr for Different Red Actions) 040

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05/11/2014

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Group 4 (terrorist finance) workplan Draft 4/24/2003

List of key questions

1) Is this trip really necessary? Given the demonstrated ability of terrorists to use tiny amounts of money to create significant attacks, is there really a purpose to this? a) What is the nature of the problem? How are funds used by terrorists generated, and how does it move? How is the worldwide terrorist infrastructure funded? How are terrorist cells within the US funded? Is it different? 2) Prior to 9/11, how big of a focus was there on identifying and stopping the flow of funds to terrorist organizations? a) Within the USG? i) What was the role of the 1C in gathering intelligence about the flow of funds to terrorist organizations? (crosscut with team#2) (much of this may have been explored in the joint intelligence report) ii) What was the role of Treasury, particularly OF AC, in blocking and seizing assets? (1) Al-Qaida designations (2) Foreign terrorist asset tracking center (3) Support from the intelligence and law enforcement communities in getting evidence to support designations? iii) What was law enforcement's role in investigating and prosecuting the financing of terrorist operations domestically? How effective was it? (1) FBI and the use of2339(A) and (B) (2) FinCEN (3) Customs, IRS and others iv) What regulatory controls were in place to prevent the US financial system from being used by terrorists to move money? Were they effective? Had there been any efforts to improve the controls? What do the money movements nfthe highiackers tell us. if anything?
9/11 Closed by Statute

3) What are our current efforts, and are we on the right track?

9/11 Closed by Statute

Group 4 (terrorist finance) workplan Draft 4/24/2003 c) Law enforcement? i) Prosecution of charities and other groups ii) Cooperation with 1C? (lowered walls and what does that mean?) (crosscut with the LE team) iii) Cooperation within agencies in area of terrorist finance d) Regulatory? i) USA PATRIOT act: What does it do? Is it effective? Can it be made better? ii) Is BSA data on terrorist finance being used by LE? How? iii) Any way to substantively regulate charities to prevent abuse?
9/11 Closed by Statute

4) Miscellaneous issues a) Investigation of possible manipulation of financial markets in relation to 911 (airline stocks, etc.)

Group 4 (terrorist finance) workplan Draft 4/24/2003 Briefing plan for commissioners Reading list Terrorist Financing, Council on Foreign Relations, 2002 (3 1 pages) FinCEN Report no. 4 - identifying terrorist finance transactions in US financial institutions Financial Action Task Force (FATF) Special Recommendations

Essential categories of documents 1) Select OF AC decision packages - Treasury
a) Al-Barakaat (11/7/2001) b) Holy Land Foundation (12/4/200 1) c) Honey companies (10/12/2001) Policy Coordination Committee (PCC) minutes and agendas ~ NSC or Treasury Litigation documents regarding investigation and prosecution of charities - Justice or otherwise FinCEN BSA data and other information serving as the backup to Report #4 Treasury CTC, UBL Task Force materials as it related to terrorist finance (overlap with Team #2) .US Customs Service Office of Strategic Trade and Intelligence report, October 200 1

2) 3) 4) 5) 6)

9/11 Law Enforcement Sensitive

7) Other documents as suggested by the joint committee's report Persons to interview Informal (background) Kenneth Katzman, Congressional Research Service Lee Wolowsky William Wechsler Jon Winer Steven Emerson - the Investigative Project Jody Myers - NSC Rick Small, Citigroup Jeff Breinholt, CT section, Justice Gordon Kromberg, AUSA, EDVA AUSA. NDTX Holy Land Foundation
9/11 Closed by Statute

Formal

Group 4 (terrorist finance) workplan Draft 4/24/2003 Marcy Forman, US Customs Dennis Lormel, FBI David Aufhauser, General Counsel, US Treasury Juan Zarate, D AAS for terrorism Bob McBrien, head of OF AC OF AC

etc

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