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

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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? ... ef ,
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 theTole of Treasury, particularly OFAC, in blocking and seizing
(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?
(l)FBIandtheuseof2339(A)and(B) ,

(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^he controls? What do the money
mnvp.tnents of the hiehiackers tell us, if anything?

9/11 Closed by Statute

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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?
e) Diplomatic?
i) How well are other countries, particularly those in the middle east,
cooperating with US 1C and LE authorities in the area of terrorist finance?
4) Miscellaneous issues
a) Investigation of possible manipulation of financial markets in relation to 911
(airline stocks, etc.)

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

Briefing plan for commissioners

Reading list

Terrorist Financing, Council on Foreign Relations, 2002 (31 pages)
FinCEN Report no. 4 - identifying terrorist finance transactions in US financial
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 (12/4/2001)
c) Honey companies (10/12/2001)
2) Policy Coordination Committee (PCC) minutes and agendas - NSC or Treasury
3) Litigation documents regarding investigation and prosecution of charities - Justice or
4) FinCEN BSA data and other information serving as the backup to Report #4 -
5) CTC, UBL Task Force materials as it related to terrorist finance (overlap with Team
6) US Customs Service Office of Strategic Trade and Intelligence report, October 2001
(re: honey shipments)
7) Other documents as suggested by the joint committee's report
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Persons to interview . 0

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

Marcy Forman, US Customs
Dennis Lormel, FBI
David Aufhauser, General Counsel, US Treasury
Juan Zarate, DAAS for terrorism
Bob McBrien, head of OF AC
Alice Fischer, DAAG, Justice
US Customs Service Office of Strategic Trade and Intelligence