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Lines of inquiry
1) Intelligence
a) Pre9-ll
i) What was the role of the intelligence community
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) Did the intelligence community collect useful J^~f,C:/{ ////
intelligence in this area? How was that
information used? Could have it been put to
better use?
iii) What was the intelligence community proposal
for covert action against bin Laden financial
accounts? Why was the proposal not approved?
* . :*•""' "^

b) Post 9-11 P
i) What is the current role of the intelligence
community in gathering intelligence about the
flow of funds to terrorist organizations?
ii) Is information useful? Is it being put to good use?
iii) Is the Foreign Terrorist Asset Tracking Group
operational? What does it do? Is it effective?

2) Executive/Administrative

a) Pre9-ll
i) What was the role of Treasury, particularly ^yuu^n h*°c ^ ^
OFAC, in blocking and seizing assets associated '
with terrorist groups generally? Was it effective?
ii) What role did the State Department play in
designating Foreign Terrorist Organizations
(FTOs)? Was it effective?
iii) When were al-Qaida and the Taliban designated?
What efforts were made in finding and freezing
assets after the designation? Were they effective?
How could this be measured? Could anything
else have been done?
iv) Congress appropriated money for the
development of the foreign terrorist asset tracking
center (FTAT) for FY 2000, to be placed in
Treasury, but the Center was not operational until
after 9/11. What were the circumstances
surrounding that delay? What was the impact of

that delay? Why did Treasury oppose the White
House efforts to fund this center? What does the
9/11 Closed by Statute

v) What was the level of support from the
intelligence and law enforcement communities in
gathering evidence to support both the OFAC and
FTO designations?

b) Post 9-11
i) Domestically:
(1) What have we blocked and why? Is blocking
being used in appropriate circumstances?
What has been the net effect of the blocking?
(a) Who have we designated and why? What
has been the net effect of the blocking?
(2) Have there been any before and after
assessment of money flows that occurred as a
result of blocking? What do we think
terrorists groups have done in reaction to

3) Law Enforcement
a) Pre9-ll
i) What was law enforcement's role in investigating
and prosecuting the financing of terrorist
operations domestically? How effective was it?
(Partial crosscut with team 6)
ii) The terrorist fundraising statutes, 18 USC 2339A
and 2339B, had never been used until after 9/11. s. 3r
What was the level of investigative effort
generally into terrorist funding? If there had not
been an effort, why not?
(1) The FBI knew of the Holy Land Foundation's
links to Hamas as early as 1993. Why no law
enforcement or blocking action taken against
it until 2001?
iii) The Financial Crimes Enforcement Network
("FinCEN") is the government's center for
analysis and distribution of financial crimes
information. What was the level of effort prior to
(1) In 1999, there were specific law enforcement
requests to FinCEN, asking for assistance
from its hawala expert. Those requests were
not acted upon. Why? [Washington post]

iv) Besides the FBI, did other law enforcement
agencies (either federal of state) investigate
terrorist financing? Was there any confusion as
to the roles of the various law enforcement
agencies? What was the general level of
coordination among agencies?

b) Post 9-11
i) Prosecution of charities and other groups. Who
have we prosecuted? What do the investigations
reveal about the nature of terrorist financing?
How effective has the use of the terrorist
fundraising statutes been? Has FinCEN helped?
(1) IANA associate "help the needy" prosecution
of charity using Jordan Islamic Bank
ii) What is the level of cooperation with intelligence
community? What has been the effect of greater
information sharing powers contained within the
USA Patriot Act? (crosscut with team 6)
Hi) What is the level of cooperation within and
among law enforcement agencies? Are they
coordinating efforts? Are there any institutional
barriers? What can be improved?

4) Regulatory and Private
a) Pre9-ll
i) What regulatory controls were in place to prevent
the U.S. financial system from being used by
terrorists to move money? Were they effective?
(1) How much feedback (or SAR reporting) from
financial institutions re terrorist financing?
(2) Hijacker's financial transactions merited
suspcicious reporting, but none of those
reports reached the proper authorities until
after 9/11 [Ievitt64]
(3) There were specific legislative proposals to
assist in curbing the unregulated movement of
money, identify transactions and also to assist
in getting foreign banks to open their books to
legitimate law enforcement requests.
(a) Section 311 was administration proposal.
Why not acted on? Eizenstat 10/3/01: bill
with special measures had strong support
by law enforcement.
(b) What was the "know your customer"
proposal and why wasn't it implemented?

(c) Congress had directed FinCEN in 1994 to
regulate the money transmitter business,
yet the regulations doing so were not put
into place until after 9/11. Why? Could
the controls have detected the money
movements of the 9/11 hijackers?
(4) Regulation aside, was the private sector doing

b) Post 9-11
(1) General background. What does it do? Is it
(2) Policy re general balancing of bank burden,
privacy interests and law enforcement utility.
(a) What are the burdens on the financial
services industry? Are they too much?
Should the,re be more? Are there privacy
issues? Can it be made better?
(b) Will the new regulations of non-bank
financial institutions catch methods used
by terrorists? Who is to regulate non-bank
financial institutions in this area? Do they
have sufficient resources?
ii) Is BSA data on terrorist finance being used by law
' enforcement? How? Does it result in assisting
cases and investigations? Does it contribute to
our understanding of terrorist financing
investigations? If not, why not?
iii) What have we learned about what the financial
transactions of a U.S.-based terrorist cell looks
like? Are we able to get any predictive data on
terrorist financing?
iv) How do we get information, either concerning
general trends or specific individuals, to financial
institutions? How effective is it?
v) Is there a way to regulate charities to prevent
abuse? What do other countries rin?

9/11 Closed by Statute

5) Overall Government Strategy And Coordination
a) Pre9-ll

i) Was there an overall U.S. interagency strategy for
combating the financial support given to terrorist
ii) How effective was that coordination? What was
the level of cooperation among government
agencies in this area? Between government and
the private sector? If there were shortcomings in
this area, what were the causes?
(1) Presidential Decision Directive 42 (1995)
ordered other agencies to increase and
integrate efforts against terrorist financing and
money laundering. What efforts did the
directed agencies make in complying with this
(2) After the East Africa bombings in 1998, a new
interagency team was created under the
auspices of the NSC to look at terrorist
financing. What did this group do?
(3) The National Commission on Terrorism
released a report in 1999, making specific
recommendations in the area of terrorist
financing. Who was responsible for assessing
and implementing these recommendations?
Were they implemented? If not, why not?
(4) To what extent did any identified failures of
coordination contribute to the failure to detect
the 9/11 hijackers or other Al-Qaeda activity?

b) Post 9-11
i) Do we have a government-wide strategy on
terrorist financing? How is this enforced within
the interagency community?
ii) What is the current mechanism for coordinating
and ensuring cooperation? Do gaps (still) exist?
Is information being shared? Is there something
else that needs to be done?
iii) How effective are the current efforts to disrupt
terrorist financing in preventing another 9/11 or
making another 9/11 substantially more difficult
to accomplish?

6) International efforts
a) Pre9-ll
i) What were the U.S. government's diplomatic
efforts to ensure that other countries would assist

us in the tracking, seizing and freezing terrorist

9/11 Closed by Statute

ii) Were there any particular countries whose lack of
effort, or ability, impeded the U.S. government's
efforts to disrupt terrorist financing? What efforts
did the U.S. government make, if any, to improve
the effort nr ability nf any snc;h f-.nnnfrip.s?

9/11 Closed by Statute

iv) What was the level of law enforcement
cooperation between countries?
v) Bow effective were these efforts?
b) Post 9-11
i) How well are other countries cooperating with
U.S. regulatory, intelligence and law enforcement
authorities in the area of terrorist financing?
(1) What has the U.S. requested other countries to
do? How has the U.S. tried to influence
enforcement in other countries?
(2) Who are key allies that need to improve
enforcement? Who are non-allies that need to
improve enforcement?
(3) Does the U.S. see the problem the same way
as the international community? If not, what
is the disconnect?
ii) What has been the level of cooperation with US
generated (OFAC) lists? What are the perceived
flaws, if any, in the current approach (crosscut
with Team #3)?
iii) Do other countries have the technical capacity to
regulate and monitor for transactions relating to
terrorism? What can be done about that?
iv) Are there international organizations that address
this problem? How effective are they?

7) How were the 9/11 attacks funded? (in conjunction
with team 1A)

a) What was the source of funds of the 9/11 hijackers,
and how did those funds get to the hijackers? How
much did the operation actually cost?
b) To what extent was the U.S. financial system used by
the hijackers?
c) Why did the financing of the 9/11 operation go
undetected? Was it a specific failure of an individual
or group, or was the failure more systemic?
d) What do the methods of the 9/11 terrorists tell us
about current government efforts?
e) Charities
i) International Islamic Relief Organization (HRO)
(1) 86 to 94 Muhammad Jamal Khalifa (bin laden
brother in law) headed UK's Philippine Office,
channel money to Al Qaeda affiliates [levitt

1) Select OFAC decision packages - Treasury
a) Al-Qaida and bin Laden (8/22/1998)
b) Taliban (7/4/1999)
c) Al-Barakaat (11/7/2001)
d) Holy Land Foundation (Hamas) (12/4/2001)
e) Al-Hamati Sweets Bakeries, Al-Shifa' Honey Press
For Industry and Commerce, et al., (the honey
companies) (10/12/2001)
f) Afghan Support Committee and Revival of Islamic
Heritage Society (1/9/2002)
g) Al-Harimain Islamic Fountation (3/11/2002)

2) Policy Coordination Committee (PCC) for terrorist
finance — minutes and agendas for post 9/11 activities.

3) NSC documents relating to terrorist financing,
particularly Presidential Decision Directives 39 (counter
terrorism coordination), 42 (international organized
crime) and 63 (critical infrastructure protection), and
documents relating to the implementation of those

4) Agenda, minutes and notes of meetings of
Counterterrorism Strategy Group, pre 9/11.

5) Lists and summaries of FBI terrorist financing
investigations, both pre and post 9/11.

6) Lists and summaries of Operation Green Quest or other
Customs/IRS/Secret Service investigations into terrorist
financing pre and post 9/11.

7) FinCEN BS A data and other information, including pre
and post 9/11 Suspicious Activity Reports and analytical
products resulting from this analysis. Includes 1998
report on hawala prepared by Patrick lost.

8) CTC, UBL Task Force materials as it related to terrorist
finance (overlap with Team #2)

9) Cables to/from State Department to US embassies
concerning cooperation on terrorist financing intelligence
gather or law enforcement.

10) U.S. Customs Service Office of Strategic Trade and
Intelligence report, October 2001 (re: honey shipments)

11) Financial analysis of 9/11 attacks, created by FBI's
Terrorist Financial Review Group (later renamed
Terrorist Financing Operations Section)

12) Other documents as suggested by the joint committee's

Jody Myers
William F. Wechsler
Richard E. Clarke

Marcy Forman, Director, Operation Green Quest, US
Director, US Customs Service Office of Strategic Trade and

Dennis Lormel, Terrorist Finance Operations Section

Jim Johnson, former Undersecretary for Enforcement
Ron Noble, former Undersecretary for Enforcement
Elisabeth Bresee, Assistant Secretary for Enforcement
Kenneth Dam, former Deputy Secretary
David Aufhauser, General Counsel
Jimmy Gurule' former Undersecretary for Enforcement,
Juan Zarate, DAAS for terrorism
Bob McBrien, OFAC
Richard Newcomb, OFAC, Director
Jim Sloan, FinCEN, Director
David Voght, FinCEN, Office of Intelligence
Peter Djinis, former FinCEN, Office of Financial

Steven Miller, Director, Exempt Organizations, Tax
Exempt/Government Entities Division, IRS
Martha Sullivan, Director, Compliance, Small and Medium
Sized Businesses, IRS (MSBs)

Unit head, Office of the Coordinator for Counterterrorism,
Counterterrorism Finance and Designation Unit

Michael Chertoff, AAG
James Robinson, former AAG


Alice Fisher, DAAG
Bruce Swartz, DAAG
Jim Reynolds, former Chief TVCS
Barry Sabin, Chief CT (formerly TVCS)
Jeff Breinholt, CT section, terrorist financing
Gordon Kromberg, AUSA, EDVA

Private industry and independent policy analysts
John Byrne, American Bankers Association
Rick Small, Director for Global Anti-Money Laundering,
Director of compliance, SunTrust
Michael Zeldin, partner, Deloitte and Touche
Kenneth Katzman, Congressional Research Service
Lee Wolosky, Council on Foreign Relations
Jon Winer, former Deputy Assistant Secretary of State
Steve Emerson, The Investigative Project
Matthew Levitt, Washington Institute for Near East Policy
Rachel Ehrenfeld, author, Funding Evil
Thomas Biersteker, Professor, Watson Institute, Brown