Follow the Money: Leveraging Financial Intelligence to Combat

Follow the Money Leveraging Financial Intelligence to Combat Transnational Threats Matthew Levitt

Dr. Matthew Levitt In July 2006 al-Qaeda nearly executed what would have directs the Stein pro- been its most devastating terrorist attack since 9/11. A group gram on Counterter- rorism and Intelligence of British citizens had planned to detonate liquid explosives at The Washington aboard at least ten airliners en route from the United King- Institute for Near East Policy and served as dom to the United States and Canada. British authorities Deputy Assistant Secre- were able to foil the plot, in large part because of critical tary of the Treasury for intelligence and analy- financial intelligence. As a result they quickly announced sis from 2005 to early plans to increase the use of financial intelligence tools to 2007. He is the co- author, with Michael disrupt future terrorist operations. “Our aim is simple,” Jacobson, of The then-Chancellor of the Exchequer Gordon Brown asserted. Money Trail: Finding, Following and Freez- “Just as there be no safe haven for terrorists, so there be no ing Terrorist Finances hiding place for those who finance terrorism.”1 (Washington Institute Mr. Brown described this effort as a “modern 2008) Bletchley Park.” Much as intercepted communications foiled Axis military planning during World War II, tracking the financial footprints left by today’s terrorists, proliferators, drug kingpins, and other adversaries can thwart attacks, disrupt logistical and financial support networks, and identify unknown operatives. Despite the fact that well-publicized uses of financial intelligence may be few and far between, it remains an integral component of international efforts to confront transnational threats. Tracking funds as they trav-

Winter/Spring 2011 [34] FOLLOW THE MONEY el through the global financial system not independently defeat these threats— demands both interagency and inter- nor is it intended to. These tools must national cooperation to develop intelli- be part of a broader strategy that lever- gence collection, storage, and dissemi- ages all elements of national power to nation policies. Since 9/11, both U.S. successfully confront and eliminate the and international intelligence agencies international security threats we face have restructured to reflect this cur- today. rent threat environment. Tremendous In the aftermath of nearly every recent strides have been made to stop the flow terrorist attack, the utility of financial of funds to illicit actors, but the inter- investigative tools has been reaffirmed. national community must continue to Financial data provided investigators emphasize the importance of finan- with critical and early leads immediately cial intelligence in order to constrain following the attacks on 9/11, as they did terrorists’ operating environment and following the 11 March 2004 attacks in pursue individual threats. Madrid and the 7 July 2005 attacks in London, among others. Focusing on Effective but Underappreci- the financing of transnational threats ated. Despite the effectiveness of has other benefits as well: financial intelligence (often referred to as FININT), it is underappreci- Deterrent effect. It is difficult ated. Intelligence activities, when prac- to deter hardcore operatives, yet the ticed best, are unreported. The public threat of terrorist designations can and pundits alike must judge efforts to deter non-designated parties. Major combat the financing of transnational donors inclined to finance extremist threats solely on overt actions such groups—who may be heavily involved in as U.S. Treasury designations, indict- business activity throughout the world— ments and prosecutions. These are not will think twice before putting their the sum total of international efforts personal fortunes and reputations at to combat terrorist financing—they are risk. only the most visible. Diplomacy, law enforcement, and intelligence collec- Preventive intelligence. Finan- tion operations also provide a variety of cial transfers are a matter of fact. Rais- other equally productive ways of com- ing, storing, and transferring money bating terrorist financing. leaves a financial trail for investigators Freezing funds will constrict the to follow that links numbered accounts operating environment for illicit actors and moneychangers with individuals in and disrupt their activities, while fol- terrorist organizations and cells. This is lowing the money trail up and down a powerful preemptive tool that allows the financial pipelines of terrorists and authorities to interdict potential threats insurgents will expose their donors and before they fully develop. operators. Although these tools have tremendous tactical utility, it is impor- Disruptive tool. Denying terror- tant to recognize that combating the ists, insurgents, and proliferators easy financing of transnational threats will access to the international financial

[35] Georgetown Journal of International Affairs Espionage Exposed system forces them to use more costly, (BDA), a small Macanese bank, access less efficient, and often less reliable to the U.S. financial system. Accord- means of financing. This may not stop ing to a U.S. government statement all plots, but it will likely frustrate illic- issued at the time, “Sources show that it activities. In 1995, captured World senior officials in Banco Delta Asia are Trade Center bomber Ramzi Yousef working with [North Korean] DPRK was flown over the twin towers on his officials to accept large deposits of cash, way to a New York jail. When an FBI including counterfeit U.S. currency, agent pointed out that the towers were and agreeing to place that currency still standing, Yousef replied, “They into circulation.”4 U.S. officials not- Illicit actors leave financial footprints that can often be traced by virtue of having to op- erate within the single global financial system. wouldn’t be if I had enough money and ed that the bank pursued activities on explosives.”2 behalf of a “well-known North Korean All of these efforts are intel- front company” involved in distribut- ligence-driven and have proven to be ing counterfeit currency and smug- quite successful. Those who follow the gling counterfeit tobacco products, and money are increasingly being called on “has also long been suspected of being to use their skills and tools against the involved in international drug traffick- hardest targets. ing.”5 The Treasury Department cited the bank as a “primary money launder- Identifying Illicit Conduct. ing concern” under Section 311 of the Identifying covert financial activity is USA Patriot Act and blocked BDA—and inherently difficult given that criminals any other banks continuing to do busi- will go to great lengths to cover their ness with BDA—from accessing the U.S. tracks and evade detection. Often, only financial system. intelligence gleaned through a variety of Similarly, intelligence gathering sources and methods can inform poli- efforts directed toward Iran’s illicit cymakers as to which banks and human- activities revealed the use of Iranian itarian organizations should be targeted state-owned banks, including its cen- for engaging in illegal and deceptive tral bank, to secretly facilitate terrorism financial practices that mask their sup- financing and WMD programs. For port of terrorism. In the United States, example, Iran has used Bank Saderat the Treasury Department’s Terrorism as a preferred means of transferring and Financial Intelligence branch dis- funds to terrorist organizations such as cusses potential targets based on all- Hezbollah, Hamas, Palestinian Islamic source intelligence.3 Jihad, and the Popular Front for the In 2005, for example, the U.S. Liberation of Palestine–General Com- government denied Banco Delta Asia mand. In 2006 the Treasury Depart-

Winter/Spring 2011 [36] FOLLOW THE MONEY ment went public with declassified hunt terrorists, understand their net- intelligence, stating that from 2001 works, and disrupt their operations.”9 to 2006 Iran transferred $50 million Following the money gives the added to Hezbollah by sending funds from benefit of using confirmable streams of its central bank through Bank Sad- data to create linkages between known erat’s London subsidiary.6 Iran’s state- and unknown terrorist operatives and owned Bank Sepah was also blacklisted supporters. Though the nature of that for providing extensive financial servic- link must still be determined, such lead es to Iranian entities involved in WMD- information is critically important to related activities. According to the investigators and analysts. Moreover, Treasury Department, Sepah engaged Treasury officials note, “While terror- in “a range of deceptive financial prac- ist supporters may use code names on tices in an effort to avoid detection,” the phone, when they send or receive which included asking that its name be money through the banking system they removed from international transac- often provide information that yields tions.7 As U.S. officials have discov- the kind of concrete leads that can ered, providing hard financial evidence advance an investigation.”10 Armed helps to build international consensus with details like names and addresses, and to “achieve a multilateral alignment analysts can identify key actors and map of interests.” Faced with hard evidence, their networks. even states that are not traditional allies Consider the case of al-Qaeda in cooperate to support actions that target Iraq (AQI). Documents seized by the the financing of illicit conduct.8 United States have revealed a treasure trove of information about AQI fund- Following the Money Trail ing, organizational structure, and pos- and Constricting the Operat- sible fissures within the organization. ing Environment. Illicit actors In one illuminating example, on 11 leave financial footprints that can often September 2007 coalition forces raid- be traced by virtue of having to oper- ed a suspected AQI safe house in Sinjar, ate within the single global financial an Iraqi town along the Syrian border. system. Following money up and down Analysis of seized documents revealed these financial pipelines helps pro- AQI managers’ concern when they were vide critical intelligence that identi- unable to account for every dollar in fies which key nodes in these financial their control.11 Given the operation- networks should be targeted. Using this al and security risks associated with financial intelligence as an investigative maintaining such an extensive paper tool also allows intelligence agencies to trail, these details provided insight into more fully understand the scope of tar- AQI operations and helped analysts geted networks. In the words of the 9/11 understand the importance AQI senior Commission, while stemming the flow leaders attached to the organization’s of funds to terrorists is a useful tool, finances.12 “Expect less from trying to dry up ter- Financial intelligence has been suc- rorist money and more from following cessfully leveraged to disrupt terrorist the money for intelligence, as a tool to operations, target individuals, and even

[37] Georgetown Journal of International Affairs Espionage Exposed prevent attacks. For example, Phil- supporters in the United States.17 ippine police reported that the Abu Sayyaf Group’s plans to set off bombs A Case in Point: The Terrorist in Manila and target a chemical plant Finance Tracking Program. in 2006 were never executed due to Following the 9/11 attacks, the U.S. a lack of funds—a direct result of the Treasury Department initiated the group’s inability to access the interna- TFTP to take advantage of the finan- tional financial system and the funds cial footprint left behind when terror- they were holding elsewhere.13 Simi- ists and their backers transfer funds larly, intelligence analysis contributed in order to enable the U.S. govern- to the capture of Hambali, Jemaah ment to proactively identify terrorist Islamiyah’s operations chief, who mas- threats. Under this program, the Trea- terminded the Bali bombings in 2002. sury obtains financial data substantively Treasury officials stated that financial connected to terrorist activity by issu- transactions between a known al-Qaeda ing an administrative subpoena. The suspect and a previously unknown fig- requested data is provided by the Soci- ure in South Asia provided the link ety for Worldwide Interbank Financial that helped locate Hambali in Thailand Telecommunication (SWIFT), a Brus- in 2003.14 According to Undersec- sels-based entity responsible for con- retary of the Treasury Stuart Levey, ducting much of the world’s bank-to- the Terrorist Finance Tracking Pro- bank communications. Financial intel- gram (TFTP) “played an important ligence provided by TFTP has assisted role in the investigation that even- in many investigations, including the

Financial intelligence has been successfully leveraged to disrupt terrorist operations, target individuals, and even prevent attacks. tually culminated in the capture of Van Gogh murder in 2004, a plot to Hambali.”15 Additionally, the U.S. attack New York’s JFK airport in 2007, Treasury Department reported that a the Mumbai attacks in 2008, and the financial intelligence collection pro- Jakarta hotel attacks in 2009. As of gram supplied a key piece of evidence April 2010, over 1,550 TFTP reports confirming the identity of a major have been shared with European Union Iraqi terrorist facilitator and financier, member states.18 This shared informa- leading to his designation as a Specially tion allows both the United States and Designated Global Terrorist (SDGT).16 the EU to direct local law enforcement Finally and perhaps most importantly, toward specific threats. As Levey noted four different terrorist attacks abroad in April 2008, “In many circumstances have been disrupted, according to the we have found that our most effec- FBI, based in part on its investigations tive tool is simply sharing information of the financial activities of terrorist about illicit actors with other govern-

Winter/Spring 2011 [38] FOLLOW THE MONEY ments and members of the internation to handle financial intelligence tional private sector.”19 issues. Even the Treasury Department, In June 2006 the New York Times whose enforcement capabilities had and other media exposed the existence been nearly eliminated with the 2003 of the TFTP.20 When SWIFT sub- reorganization that created the Depart- sequently moved its U.S. facility to ment of Homeland Security, began to Europe, the United States and Euro- ramp up its efforts once again. pean Commission began negotiations In 2004, the Treasury Department to ensure data would continue to be created the Office of Terrorism and available to TFTP. These talks were Financial Intelligence (TFI) and the largely informed by two reports from Office of Intelligence and Analysis.22 French counterterrorism magistrate These offices couple authorities at Jean-Louis Bruguiere, issued in late Treasury with intelligence community 2008 and early 2010, which found that resources and expertise to identify, dis- TFTP was subject to significant and rupt, and follow the flow of illicit funds effective controls and safeguards, and supporting terrorism or other national generated significant value for counter- security threats.23 In a sign of its dem- terrorism investigations.21 After several onstrated utility, the 9/11 Commis- fits and starts, an agreement was ulti- sion’s Public Discourse Project high- mately reached in July 2010 autho- lighted the government’s “significant rizing Treasury Department access to strides in using terrorism finance as an SWIFT’s data, with specific measures intelligence tool.”24 added to allay privacy concerns. The Treasury Department has had an enhanced role at the center of a major Structural Changes to Com- national security initiative that reflects bat Illicit Finance. Structural a broader shift in its post-9/11 mission. reforms following 9/11 have enabled In the past, the Treasury—like other intelligence organizations to focus their finance ministries around the world— attention on following the money. The was largely focused on economic and FBI established a special branch at its financial issues and often reluctant to headquarters, known as the Terror- get involved in matters of national secu- Structural reforms following 9/11 have enabled intelligence organizations to focus their attention on following the money. ist Financing Operations Section, to rity. As a former Clinton State Depart- focus exclusively on tracking financial ment official noted, “Years ago, people intelligence and coordinating investi- at State would go to Treasury and say, gations at its fifty-six field offices. The ‘We’ve got a lot of financial muscle, we Justice Department also established an should use it to pursue political goals.’ office within its counterterrorism sec- But Treasury would always say it didn’t

[39] Georgetown Journal of International Affairs Espionage Exposed want to mess around with the interna- action plan to combat the financing of tional financial system.”25 This historic terrorism in the aftermath of 9/11.26 reticence has changed drastically in the In September 2006 the G7 finance last decade. For example, the Depart- ministers agreed to expand their focus ment of Treasury has been instrumen- to address money laundering in sup- tal in building pressure on Iran outside port of terrorist and WMD prolifera- of the UN. The Treasury has focused its tion networks, and to concentrate on strategy specifically on Iran’s illicit con- “those jurisdictions that have failed to duct—mainly its nuclear-related activi- recognize international standards”—a ty, support for terrorism, and deceptive pointed reference to Iran’s support for financial practices—and the dangerous terrorist organizations and efforts to ramifications Iran could have on the attain nuclear weapons.27 integrity of the global financial system. The British government has also been a leader in this effort, unveiling a com- Interagency and International prehensive strategy in 2007 to combat Efforts. While the creation of the terrorist financing and money laun- TFI represented an important step dering, titled The Financial Challenge forward, combating the financing of to Crime and Terrorism. The strategy transnational threats must be an inte- provided the British finance minis- grated, interagency effort. The Iraq try—Her Majesty’s Treasury (HMT)— Threat Finance Cell (ITFC), based with additional tools to crack down in Baghdad, is a perfect example of effectively on terrorist financing in the one such interagency effort that works. United Kingdom. For example, the Co-led by the Department of Defense British established a “Terrorist Asset and Treasury, ITFC was established in Freezing Unit” within HMT to work 2005 with the purpose of enhancing closely with British law enforcement the collection, analysis, and dissemina- and intelligence agencies. HMT was tion of timely financial intelligence on also, for the first time, allowed to use the Iraqi insurgency. It has become classified information to freeze assets in a key component of interagency and certain cases.28 Multi-National Force – Iraq (MNF-I) International and interagency efforts efforts to detect, identify, and disrupt have produced tangible results. In his financial networks supporting insur- April 2008 testimony, Levey noted gent and terrorist elements operat- that the government’s efforts to com- ing in Iraq. The new Afghan Threat bat terror financing “are more inte- Finance Cell in Kabul, run by the Drug grated than ever before” and have made Enforcement Administration with the “significant progress mapping terrorist help of Defense and Treasury deputies, networks” to enable the government builds on the demonstrated success of to disrupt or deter some sources of al- the ITFC. Qaeda finance. Proof positive, in a May Other countries’ finance ministries 2007 interview al-Qaeda leader Musta- have also assumed greater national fa Abu al-Yazid stated “there are hun- security responsibilities. The G7 and dreds wishing to carry out martyrdom- G20 finance ministers released an seeking operations, but they can’t find

Winter/Spring 2011 [40] FOLLOW THE MONEY the funds to equip themselves.”29 The transnational threats arise, FININT will CIA’s former Deputy Director John increasingly be called upon—Bletch- McLaughlin testified that the govern- ley Park style—to connect the dots and ment’s success in this area was attrib- prevent attacks. Making effective use of utable to the “relentless grinding away lead intelligence demands international at other essential components of the cooperation. The recent renewal of the terrorist networks—the couriers, the SWIFT agreement is an important step facilitators, the fundraisers, the safe- in maintaining one of the internation- 30 house keepers, the technicians.” al community’s most effective financial intelligence tools. Meanwhile, it is Conclusion. The international com- imperative that we further strengthen munity has undoubtedly made great our commitment to strategies aimed headway combating the financing of at making it more difficult for illicit various security threats. The Unit- actors to raise, launder, and access the ed States’ efforts to combat terrorist funds they need to carry out operations. financing have been particularly effective, earning an A- from the 9/11 Com- There is much that the United States mission’s Public Discourse Project in can do on its own, yet in the words 2005.31 Interagency efforts that threat- of Assistant Secretary of the Treasury en finance cells in Iraq and Afghanistan David Cohen, “When the community and improved intelligence gathering of nations works together, in a coor- methods such as the TFTP are impor- dinated fashion, to combat terrorist tant factors in these successes. financing, we all benefit.”32 The public Traditional efforts to combat terror should take comfort in knowing that financing by “seizing and freezing” ter- both financial intelligence tactics—seiz- rorists’ assets are effective counterter- ing funds and following the money rorism tools. But as terrorist groups trail—are being pursued, even if only continue to evolve and as additional one makes the daily paper. NOTES

1 “Brown outlines terror crackdown,” BBC, 10 tember 2005, http://www.ustreas.gov/press/releases/ October 2006, Internet, http://news.bbc.co.uk/2/ js2720.htm (date accessed: 8 January 2011). hi/uk_news/politics/6035861.stm (date accessed: 8 5Ibid. January 2011). 6 U.S. Department of the Treasury, “Treasury 2 Benjamin Weiser, “Suspected Chief Plot- Cuts Iran’s Bank Saderat Off From U.S. Financial ter in Trade Center Blast Goes on Trial Today,” System,” 8 September 2006, http://www.ustreas.gov/ New York Times, August 4, 1997, http://www.nytimes. press/releases/hp87.htm (date accessed: 8 January com/1997/08/04/nyregion/suspected-chief-plotter- 2011). in-trade-center-blast-goes-on-trial-today.html (date 7 U.S. Department of the Treasury, “Prepared accessed: 8 January 2011). Remarks of Stuart Levey Under Secretary for Terror- 3 Remarks by Treasury Assistant Secretary for ism and Financial Intelligence On the Designation of Terrorist Financing Patrick M. O’Brien, Washington Bank Sepah for Facilitating Iran’s Weapons Program,” Institute for Near East Policy, 27 February 2008, 9 January 2007, http://www.treas.gov/press/releases/ Internet, http://www.washingtoninstitute.org/tem- hp220.htm (date accessed: 8 January 2011). plateC05.php?CID=2724 (date accessed: 8 January 8 Testimony of Daniel Glaser, Deputy Assis- 2011). tant Secretary for Terrorist Financing and Financial 4 U.S. Department of the Treasury, “Treasury Crimes, before the House Committee on Foreign Designates Banco Delta Asia as Primary Money Laun- Affairs Subcommittee on the Middle East and South dering Concern under USA PATRIOT Act,” 15 Sep- Asia and the Subcommittee on Terrorism, Nonpro-

[41] Georgetown Journal of International Affairs Espionage Exposed liferation, and Trade, 17 April 2008, http://www. Finance,” 1 April 2008, http://www.treas.gov/press/ treas.gov/press/releases/hp933.htm (date accessed: 8 releases/hp898.htm (date accessed: 8 January 2011). January 2011). 20 The New York Times would later run an apology. 9 9/11 Commission, “Final Report of the National See Byron Calame, “Can ‘Magazines’ of The Times Commission on Terrorist Attacks Upon the United Subsidize News Coverage, Banking Data: A Mea States: Executive Summary,” http://govinfo.library. Culpa,” New York Times, 22 October 2006, http:// unt.edu/911/report/911Report_Exec.htm (date www.nytimes.com/2006/10/22/opinion/22pubed. accessed: 8 January 2011). html?pagewanted=2&_r=2. For more on the protec- 10 Testimony of Stuart Levey, Undersecretary for tions built into the TFTP program, see States Depart- Terrorism and Financial Intelligence, U.S. Depart- ment of the Treasury, “Statement of Undersecretary ment of the Treasury, before the House Financial Stuart Levey on the Terrorist Finance Tracking Pro- Services Committee on Oversight and Investigations, gram,” 23 June 2006, http://www.treas.gov/press/ 11 July 2006, http://www.treas.gov/press/releases/ releases/js4334.htm. Also see Elizabeth Kelleher, hp05.htm (date accessed: 8 January 2011). “U.S. Defends Use of Bank Messaging System to Track 11 The Sinjar documents show that the AQI’s bor- Terrorists,” The Washington File, Bureau of Interna- der emirate spent $727 on food during a two-month tional Information Programs, United States Depart- period, in addition to tracking a number of other ment of State, 23 June 2006, Internet, http://www. different subcategories for expenditures, including america.gov/st/washfile-english/2006/June/200606 salaries, weapons, document forgeries, and smuggling 23173804berehellek0.1277277.html (date accessed: costs. 8 January 2011). 12 Brian Fishman, ed., “Bombers, Bank Accounts, 21 U.S. Department of the Treasury, “Assistant and Bleedout: Al-Qai’da’s Road in and Out of Iraq,” Secretary for Terrorism and Financial Intelligence Harmony Project, Combating Terrorism Center at West David S. Cohen, Remarks to the Washington Insti- Point: 2008, Internet, http://www.ctc.usma.edu/ tute for Near East Policy,” 7 April 2010, Internet, harmony/pdf/Sinjar_2_Jul_23.pdf (date accessed: 8 http://www.washingtoninstitute.org/templateC07. January 2011). php?CID=522 (date accessed: 8 January 2011). 13 “Militants in SE Asia Rely on Donations – 22 U.S. Department of the Treasury, “Bush Experts,” Reuters, 9 July 2008. Administration Announces Creation of New Office 14 Eric Lichtblau and James Risen, “Bank Data in Ramped Up Effort to Fight the Financial War on is Sifted in by U.S. in Secret to Block Terror,” Terror,” press release, 8 March 2004, Internet, www. New York Times, 23 June 2006, Internet http://www. treas.gov/press/releases/js1219.htm (date accessed: 8 nytimes.com/2006/06/23/washington/23intel. January 2011). html?pagewanted=print (date accessed: 8 January 23 OFAC and FINCEN participate in the process 2011). of enforcing sanctions and tracking criminal organi- 15 Elizabeth Kelleher, “U.S. Defends Use of Bank zations, but they continue to rely on the intelligence Messaging System to Track Terrorists,” The Washington organizations within the U.S. government (such as the File, Bureau of International Information Programs, TFI) to provide the intelligence necessary to carry out U.S. Department of State, 23 June 2006, Internet, their office missions.” http://www.america.gov/st/washfile-english/2006/ 24 Thomas H. Kean et al., “Final Report of the June/20060623173804berehellek0.1277277.html 9/11 Commission Recommendations,” 9/11 Public (date accessed: 8 January 2011). Discourse Project, December 5, 2005, http://www.9- 16 U.S. Department of the Treasury, “Treasury 11pdp.org/press/2005-12-05_report.pdf. Designates Financial Supporter of Iraqi Insurgency,” 25 Bay Fang, “Treasury wields financial sanctions; 17 June 2005, Internet, http://www.treas.gov/press/ US strategy straddles the line between diplomacy, releases/js2500.htm (date accessed: 8 January 2011). military might,” Chicago Tribune, 23 April 2007. 17 Federal Bureau of Investigation, Testimony of 26 Statement of G-7 Finance Ministers and Cen- John S. Pistole before the U.S. Senate Committee on tral Bank Governors, Washington, D.C., 6 October Banking, Housing, and Urban Affairs, “Identifying, 2001; Statement of G-20 Finance Ministers and Tracking and Dismantling the Financial Structure of Central Bank Governors, Ottawa, Ontario, Canada, Terrorist Organizations,” 25 September 2003, www. 17 November 2001. fbi.gov/congress/congress03/pistole092503.htm. 27 Statement of G-7 Finance Ministers and Cen- 18 U.S. Department of the Treasury, “Assistant tral Bank Governors, Singapore, 16 September 2006. Secretary for Terrorism and Financial Intelligence 28 “Move to combat terror gang funding,” London David S. Cohen, Remarks to the Washington Insti- Evening Standard, 28 February 2007; “The Financial tute for Near East Policy,” 7 April 2010, Internet, Challenge to Crime and Terrorism,” February 2007. http://www.washingtoninstitute.org/templateC07. 29 U.S. Department of the Treasury, “Under php?CID=522 (date accessed: 8 January 2011). Secretary for Terrorism and Financial Intelligence 19 U.S. Department of the Treasury, “Under Sec- Stuart Levey Testimony Before the Senate Commit- retary for Terrorism and Financial Intelligence Stuart tee on Finance,” 1 April 2008, http://www.treas.gov/ Levey Testimony Before the Senate Committee on press/releases/hp898.htm.

Winter/Spring 2011 [42] FOLLOW THE MONEY

30 Testimony of John McLaughlin, before the on Finance,” 1 April 2008, Internet, http://www. Senate Foreign Relations Committee, “The Chang- treas.gov/press/releases/hp898.htm (date acce. ing Face of Terror – A Post 9/11 Assessment”, 6 June 32 Remarks by Assistant Secretary for Terror- 2006, Internet, http://www.senate.gov/~foreign/ ism and Financial Intelligence David S. Cohen, testimony/2006/McLaughlinTestimony060613.pdf (date accessed: 8 January 2011). Washington Institute for Near East Policy, 7 April 31 U.S. Department of the Treasury, “Under 2010, Internet, http://www.washingtoninstitute.org/ Secretary for Terrorism and Financial Intelligence templateC07.php?CID=522. (date accessed: 8 Janu- Stuart Levey Testimony Before the Senate Committee ary 2011).

[43] Georgetown Journal of International Affairs