Stephen A. Grimaldi Senior Supervisory Resident Agent ... · Charleston Resident Agency Columbia Division (843) 722-0135. The #1 Mission of the FBI Post 9/11: ... FBI used court approved

Stephen A. GrimaldiStephen A. GrimaldiSenior Supervisory Resident Senior Supervisory Resident

AgentAgentCharleston Resident AgencyCharleston Resident Agency

Columbia DivisionColumbia Division(843) 722(843) 722--01350135

The #1 Mission of the FBI Post The #1 Mission of the FBI Post 9/11:9/11:

COUNTERTERRORISMCOUNTERTERRORISM

Identifying terrorists, disrupting Identifying terrorists, disrupting their operations and preventing their operations and preventing

future acts of terrorismfuture acts of terrorism

DirectorDirector’’s Directives Directive

Each and every terrorism threat is to be Each and every terrorism threat is to be immediately addressedimmediately addressed

No higher investigative priority than No higher investigative priority than addressing terrorism; the smallest terror addressing terrorism; the smallest terror lead will always outweigh all other lead will always outweigh all other investigative matters worked by the FBI investigative matters worked by the FBI

Reprioritization Reprioritization CT (both IT and DT) investigations are up CT (both IT and DT) investigations are up dramaticallydramaticallyCI and Cybercrimes resources increased CI and Cybercrimes resources increased significantlysignificantlyZero Sum resources Zero Sum resources –– other programs cutother programs cutFugitives Fugitives –– no to the USMSno to the USMSDrugs (except for Task Force cases) to DEADrugs (except for Task Force cases) to DEAWhite Collar White Collar –– significantly higher thresholds significantly higher thresholds (MF/WF min loss $500K)(MF/WF min loss $500K)TFIS/ITSP TFIS/ITSP –– very little work in this areavery little work in this area

JFK JFK -- 19611961

““Terror is not a new weapon. Throughout Terror is not a new weapon. Throughout history it has been used by those who history it has been used by those who could not prevail, either by persuasion or could not prevail, either by persuasion or example. But inevitably they fail, either example. But inevitably they fail, either because men are not afraid to die for a life because men are not afraid to die for a life worth living, or because the terrorists worth living, or because the terrorists themselves came to realize that free men themselves came to realize that free men cannot be frightened by threats, and that cannot be frightened by threats, and that aggression would meet its own response.aggression would meet its own response.””

JFK and TodayJFK and Today

The terrorism stakes are much higherThe terrorism stakes are much higherSmaller groups can inflict tremendous loss Smaller groups can inflict tremendous loss of life and economic damageof life and economic damageChemical, Biological, Nuclear WMD threats Chemical, Biological, Nuclear WMD threats are a realityare a realityKatrina Katrina –– the collapse of something as the collapse of something as basic a levee brought devastating damage basic a levee brought devastating damage and chaos to the City of New Orleans and chaos to the City of New Orleans Smallpox or dirty bomb scenarioSmallpox or dirty bomb scenario

Deterrence and DisruptionDeterrence and Disruption

A free and open society is vulnerableA free and open society is vulnerableCanCan’’t prevent every attackt prevent every attackThe goal is to minimize the risk by The goal is to minimize the risk by aggressively and proactively aggressively and proactively investigating all terror threatsinvestigating all terror threatsWe do this through our JTTFsWe do this through our JTTFs

JOINT TERRORISM TASK JOINT TERRORISM TASK FORCEFORCE(JTTF)(JTTF)

JTTFJTTF

In the field, JTTFs carry out the BureauIn the field, JTTFs carry out the Bureau’’s CT s CT missionmissionMultiMulti--agencyagencyOne in every judicial district in the countryOne in every judicial district in the countryConducts a wide range of IT/DT investigative Conducts a wide range of IT/DT investigative tasks to include the investigation of terror tasks to include the investigation of terror financingfinancingMaterial Support violations are the most Material Support violations are the most widely used charges by JTTFs to disrupt and widely used charges by JTTFs to disrupt and dismantle terror organizations dismantle terror organizations Develop a relationship with your JTTF repsDevelop a relationship with your JTTF reps

09/11/200509/11/2005A terrorism plot to be executed on 09/11/2005 A terrorism plot to be executed on 09/11/2005 was thwarted in Torrance, CA; obscured by was thwarted in Torrance, CA; obscured by Katrina newsKatrina newsA group intended to commit mass murder at a A group intended to commit mass murder at a military recruiting center in Santa Monica, CA military recruiting center in Santa Monica, CA and another to open fire on families gathered and another to open fire on families gathered at a temple in West LA.at a temple in West LA.The attackers financed the plan through a The attackers financed the plan through a string of gas station robberiesstring of gas station robberiesA member of the Torrance PD was assigned to A member of the Torrance PD was assigned to the JTTF. Based on local arrests by the the JTTF. Based on local arrests by the Torrance PD, documents were discovered Torrance PD, documents were discovered listing military and Jewish locationslisting military and Jewish locationsThe officer enlisted the JTTF investigating this The officer enlisted the JTTF investigating this matter and hundreds of investigators worked matter and hundreds of investigators worked around the clock to uncover the entire cell.around the clock to uncover the entire cell.The plot was initiated in Folsom Prison and The plot was initiated in Folsom Prison and were inspired by al Qaedawere inspired by al Qaeda

Terrorism Financing Operations Terrorism Financing Operations Section (TFOS)Section (TFOS)

Supports the JTTF Supports the JTTF Located at the new NCTC in McLean, Located at the new NCTC in McLean, VAVAConducts full financial analysis of Conducts full financial analysis of terrorist suspects and their financial terrorist suspects and their financial support structures here and abroadsupport structures here and abroadWorks directly with law enforcement Works directly with law enforcement organizations and regulatory organizations and regulatory communitiescommunities

TFOS (conTFOS (con’’t)t)

Identifies and tracks terrorist Identifies and tracks terrorist financial transactions after an attackfinancial transactions after an attackMore importantly exploits financial More importantly exploits financial information to identify previously information to identify previously unknown terrorist cells, recognize unknown terrorist cells, recognize potential terrorism activity/planning, potential terrorism activity/planning, and predict/prevent future terrorist and predict/prevent future terrorist acts.acts.Provides operational support to Provides operational support to the JTTFsthe JTTFs

Targeting The Financing of TerrorTargeting The Financing of Terror

Disrupt/dismantle mechanisms by Disrupt/dismantle mechanisms by which terror organizations receive which terror organizations receive financial supportfinancial supportTerror financing investigations have Terror financing investigations have proven to be an effective means to proven to be an effective means to locate and track terrorists locate and track terrorists –– ““follow follow the moneythe money””

September 11, 2001September 11, 2001

SEPTEMBER 11, 2001SEPTEMBER 11, 2001SEPTEMBER 11, 2001

Al Qaeda and Financing 9/11

Al Qaeda and Financing Al Qaeda and Financing 9/119/11

9/11/20019/11/2001Estimated that 9/11 cost $400,000 to 500,000 to Estimated that 9/11 cost $400,000 to 500,000 to plan and executeplan and execute$300,000 of that passed through the hijackers $300,000 of that passed through the hijackers US bank accountsUS bank accountsThe 9/11 hijackers returned $26,000 to a The 9/11 hijackers returned $26,000 to a facilitator in the UAE in the days prior to the facilitator in the UAE in the days prior to the attackattackMoney went towards travel, flight training, and Money went towards travel, flight training, and living expensesliving expensesNone of the 9/11 attackers received any domestic None of the 9/11 attackers received any domestic financial supportfinancial supportNone of the financial transactions were None of the financial transactions were sophisticated as there was an extensive sophisticated as there was an extensive paper trailpaper trail

09/11/200109/11/2001

Al Qaeda funded the 9/11 attackers Al Qaeda funded the 9/11 attackers using three routine means: wire using three routine means: wire transfers, the physical transport of transfers, the physical transport of cash or travelers checks into the US, cash or travelers checks into the US, and through the use of debit cardsand through the use of debit cards

Terror FinancingTerror Financing

Pre 9/11 money laundering controls Pre 9/11 money laundering controls were focused on drug trafficking and were focused on drug trafficking and large scale financial fraud large scale financial fraud –– the the hijackers were able to easily blend hijackers were able to easily blend into our banking systemsinto our banking systemsMoney laundering controls were not Money laundering controls were not intended to and could not detect intended to and could not detect these routine transactionsthese routine transactions

Terror FinancingTerror FinancingContrary to public reports, UBL did not personally Contrary to public reports, UBL did not personally fund al Qaeda but rather worked on an annual fund al Qaeda but rather worked on an annual income estimated to be 30 million dollars funded income estimated to be 30 million dollars funded by diversions of money from Islamic charities and by diversions of money from Islamic charities and from unwitting donors primarily in the Gulf regionfrom unwitting donors primarily in the Gulf regionSignificant funds generated in the US from both Significant funds generated in the US from both legitimate and illegitimate means are regularly legitimate and illegitimate means are regularly sent to these Islamic charitiessent to these Islamic charitiesPre 9/11, terror financing was not a priority for Pre 9/11, terror financing was not a priority for the intelligence communitythe intelligence communityPost 9/11, we now have extensive knowledge of Post 9/11, we now have extensive knowledge of terror financing and expanded investigative tools terror financing and expanded investigative tools to address terror financingto address terror financing

Impediments to Investigating Terror Impediments to Investigating Terror FinancingFinancing

The inability to get financial records The inability to get financial records from foreign countries (Legats)from foreign countries (Legats)The complexity of linking cash flows The complexity of linking cash flows to terror organizations overseasto terror organizations overseasThe commingling of terrorist money The commingling of terrorist money with legitimate funds (function like with legitimate funds (function like organized crime groups)organized crime groups)

Terror FinancingTerror Financing

Due to the effectiveness of law Due to the effectiveness of law enforcement and the IC in shutting enforcement and the IC in shutting down sources of revenue for terror down sources of revenue for terror organizations as well as the organizations as well as the freezing/seizing of their assets, they freezing/seizing of their assets, they now rely more heavily on now rely more heavily on underground financial networks and underground financial networks and the physical transport of money to the physical transport of money to support their terror operationssupport their terror operations

The United States has focused on groups supporting or funding terrorism:

The United States has focused on The United States has focused on groups supporting or funding groups supporting or funding terrorism:terrorism:

Terrorism in the 21st

CenturyTerrorism in the 21Terrorism in the 21stst

CenturyCentury

Al QaedaAl QaedaHizballahHizballah

HAMASHAMAS

•• Islamic terrorism is not newIslamic terrorism is not new•• Evolving over past 30 years Evolving over past 30 years

and has become much more and has become much more lethallethal

•• Islamic terrorists were at Islamic terrorists were at war with us but we didnwar with us but we didn’’t t know itknow it

•• 9/11 9/11 –– a turning pointa turning point

Terrorism in the 21st Century

Terrorism in the 21st Terrorism in the 21st CenturyCentury

Al QaedaAl QaedaAl Qaeda

Led by UBL; Fatwa in 1998 – declared warSeek to replace governments with fundamentalist Islamic regimesOperate through Autonomous Cells: 60 to 100 in the United States and around the world

Led by UBL; Fatwa in Led by UBL; Fatwa in 1998 1998 –– declared wardeclared warSeek to replace Seek to replace governments with governments with fundamentalist Islamic fundamentalist Islamic regimesregimesOperate through Operate through Autonomous Cells: 60 to Autonomous Cells: 60 to 100 in the United States 100 in the United States and around the worldand around the world

5



CenturyCentury

“Party of God”Established in 1980’s during Lebanese Civil WarShia Muslim groupState sponsorship from Syria and IranPolitical movement with military wing

““Party of GodParty of God””Established in 1980Established in 1980’’s s during Lebanese Civil during Lebanese Civil WarWarShia Muslim groupShia Muslim groupState sponsorship State sponsorship from Syria and Iranfrom Syria and IranPolitical movement Political movement with military wingwith military wing

HizballahHizballahHizballah

TWA 847

U.S. Marine Corp BarracksU.S. Marine Corp Barracks



CenturyCentury

Terrorism in the 21Terrorism in the 21stst CenturyCenturyHamas/Secular

Palestinian Groups

Hamas/Secular Hamas/Secular Palestinian Palestinian

GroupsGroups

Funds deposited into established bank accounts

Funds sent through the following mechanisms:

• Money changers

• Hawala system

• Wire transfers to banks in Lebanon, Israel, and Occupied Territories

Funds deposited into Funds deposited into established bank established bank accountsaccounts

Funds sent through the Funds sent through the following mechanisms:following mechanisms:

•• Money changersMoney changers

•• Hawala systemHawala system

•• Wire transfers to Wire transfers to banks in Lebanon, banks in Lebanon, Israel, and Occupied Israel, and Occupied TerritoriesTerritories



CenturyCentury

oooooo

Increased use of the InternetIncreased use of the Internet

Jihadists instructed to spread out across the Jihadists instructed to spread out across the globe and carry out terrorist activitiesglobe and carry out terrorist activities

Satellite terrorist groupsSatellite terrorist groups

•• SelfSelf--funding (legal and illicit activities)funding (legal and illicit activities)

•• US cells (Portland, Buffalo, Detroit)US cells (Portland, Buffalo, Detroit)

•• European cells (Spain, UK, France)European cells (Spain, UK, France)

•• Other international operationsOther international operations



CenturyCenturyGeneral CharacteristicsGeneral CharacteristicsGeneral Characteristics

Increase in overt activityIncrease in overt activityIncrease in deaths and injuriesIncrease in deaths and injuriesEmergence of radical religious extremismEmergence of radical religious extremismIncreased violence tied to nationalistic, ethnic Increased violence tied to nationalistic, ethnic and tribal motivationsand tribal motivationsMore powerful weaponsMore powerful weaponsEmergence of individual or ad hoc groupsEmergence of individual or ad hoc groupsInstitutionalization of terror organizationsInstitutionalization of terror organizations



CenturyCenturyGeneral CharacteristicsGeneral CharacteristicsGeneral Characteristics

•• FBI investigations in US have FBI investigations in US have revealed:revealed:-- Widespread Islamic militant Widespread Islamic militant

presence;presence;-- Extensive fundraising, recruitment, Extensive fundraising, recruitment,

training;training;-- Support structure sufficient to carrySupport structure sufficient to carry

out additional operationsout additional operations

•• Greatest concern:Greatest concern:--Sleeper cells not yet identifiedSleeper cells not yet identified

Existing ThreatExisting ThreatExisting Threat

Terrorism in the 21st Century

Terrorism in the 21st Terrorism in the 21st CenturyCentury

Identity Identity theft/fraudtheft/fraud

Alien smugglingAlien smuggling

Travel facilitatorsTravel facilitators



CenturyCenturySystemic VulnerabilitiesSystemic VulnerabilitiesSystemic Vulnerabilities

Money launderingMoney laundering

NGOs/Charities/MosqNGOs/Charities/Mosques (cash collection)ues (cash collection)

Fraud schemesFraud schemes

•• Insurance/Tax fraudsInsurance/Tax frauds

•• Credit Card Bust outCredit Card Bust out

•• Bankruptcy Bust outBankruptcy Bust out

•• GovGov’’t programst programs

Informal Value Informal Value Transfer SystemsTransfer Systems

Comparison of MethodsComparison of Methods

Funding MechanismsFunding MechanismsFunding Mechanisms

Traditional Traditional CrimesCrimesMotivation is profitMotivation is profitLaundering of dirty Laundering of dirty moneymoneyFunds derived from Funds derived from crimecrimeLarge, repetitive Large, repetitive transactionstransactionsShell companies and Shell companies and offshore centersoffshore centersLawyers and trusteesLawyers and trustees

Terrorism Terrorism FundingFundingMotivation is Motivation is ideological ideological Funds derived from Funds derived from donationsdonationsLaundering of clean Laundering of clean moneymoneyBanks and Money Banks and Money ExchangesExchangesCharities and Charities and ““frontfront””operationsoperationsState SponsorshipState Sponsorship

AlAl--Arian was a tenured professor at the U. of Arian was a tenured professor at the U. of South FloridaSouth Florida

On trial now in FloridaOn trial now in Florida

FBI used court approved wire taps (FISA) from FBI used court approved wire taps (FISA) from mid 90s to mid 90s to ’’0303

ProsecutorProsecutor-- ““a crime bossa crime boss”” for the Palestinian for the Palestinian Islamic Jihad; like the LCN, just as responsible Islamic Jihad; like the LCN, just as responsible for the terror actsfor the terror acts

Alleged to have used Palestinian charities to Alleged to have used Palestinian charities to fund the PIJ and terrorismfund the PIJ and terrorism

Sami Al-ArianSami AlSami Al--ArianArian

Funding MechanismsFunding MechanismsFunding MechanismsTraditional CrimesTraditional Crimes

•• Violent crimes Violent crimes -- theft, robberytheft, robbery

•• Drug trafficking Drug trafficking

•• Financial fraud, whiteFinancial fraud, white--collar collar crimescrimes

Over/Under InvoicingOver/Under Invoicing

Front companiesFront companies

Import/Export, Real estateImport/Export, Real estate

•• Illegal contraband, counterfeit Illegal contraband, counterfeit goodsgoods

•• Other criminal activityOther criminal activity

State SponsorsState Sponsors•• Syria, Iran, North Korea (Iraq and Libya Syria, Iran, North Korea (Iraq and Libya

prepre--OEF)OEF)

Traditional criminal activitiesTraditional criminal activities•• Bank fraud, extortion, robbery, kidnapping, Bank fraud, extortion, robbery, kidnapping,

illicit drugsillicit drugs

Wealthy Wealthy supporters/fundraising/charitiessupporters/fundraising/charities

Legitimate businesses as Legitimate businesses as ““frontsfronts””

Other terror groupsOther terror groups

Combinations of the aboveCombinations of the above

Funding MechanismsFunding MechanismsFunding Mechanisms

TERRORISM FINANCING

MECHANISMS

TERRORISM TERRORISM FINANCING FINANCING

MECHANISMSMECHANISMS

Earning, Moving and Storing Assets

Earning, Moving and Earning, Moving and Storing AssetsStoring Assets

Who’s Moving the MoneyWhoWho’’s Moving the Moneys Moving the Money

LCNDTOs

Middle EasternersEurasian OC

Asian OCIllegal Aliens

Human Traffickers

LCNLCNDTOsDTOs

Middle EasternersMiddle EasternersEurasian OCEurasian OC

Asian OCAsian OCIllegal AliensIllegal Aliens

Human TraffickersHuman Traffickers

Financing MechanismsFinancing MechanismsFinancing Mechanisms

Earn AssetsEarn Assetsthrough highly through highly profitable crimes.profitable crimes.Move AssetsMove Assetsthrough nonthrough non--transparent trade transparent trade or financial or financial transactions.transactions.Store AssetsStore Assets in in relative obscurity.relative obscurity.

Earn AssetsEarn Assetsthrough highly through highly profitable crimes.profitable crimes.Move Assets Move Assets through nonthrough non--transparent trade transparent trade or financial or financial transactions.transactions.Store AssetsStore Assets in in relative obscurity.relative obscurity.

Contraband cigarettes

Counterfeit Goods

Illicit Drugs

Contraband Contraband cigarettescigarettes

Counterfeit Counterfeit GoodsGoods

Illicit DrugsIllicit Drugs




Informal Bank Informal Bank SystemSystem

HawalasHawalas

Bulk CashBulk CashCommoditiesCommodities

Precious MetalsPrecious MetalsJewelryJewelry

CharitiesCharitiesMosques, NGOsMosques, NGOs


Bulk CashBulk Cash

Commodities Commodities which maintain which maintain their value over their value over timetime


Financing MechanismsFinancing MechanismsFinancing MechanismsMethodsMethodsMethods

Financing mechanisms are Financing mechanisms are changing (enforcement successes)changing (enforcement successes)Financiers are exploiting informal Financiers are exploiting informal financial structures in the Middle financial structures in the Middle EastEast•• Hawalas and other trustHawalas and other trust--based financial based financial

systemssystems•• Bulk cash transfers by trusted associatesBulk cash transfers by trusted associates

Increased use of fraudulent Increased use of fraudulent documentsdocuments

Formal• Bank Accounts

• Credit /Debit Cards

• Wire Transfers

• File appropriate forms, (CTR, CMIR, etc.)

Informal• Hawala

• Personal relationships to transfer funds

• Use of couriers

• Shipment of bulk cash

Two tracks of financing:TwoTwo tracks of financingtracks of financing::

Factors Factors FavoringFavoringNo traceable paper No traceable paper trail.trail.No third party No third party involved in the involved in the transaction.transaction.Total control of Total control of the movement of the movement of money by the money by the terrorist.terrorist.Low visibilityLow visibility

Factors AgainstFactors AgainstCost of couriers Cost of couriers and equipmentand equipmentRisk of theft by Risk of theft by couriercourierRisk of courier Risk of courier becoming an becoming an informantinformantLoss of funds from Loss of funds from border searchesborder searches

Physical Movement of MoneyPhysical Movement of MoneyFinancing MechanismsFinancing MechanismsFinancing Mechanisms

TERRORISM FINANCING

INDICATORS


INDICATORSINDICATORS

Patterns, Profiles, and Characteristics

Patterns, Profiles, and Patterns, Profiles, and CharacteristicsCharacteristics

…… an an ““observableobservable”” which must be which must be able to be seen, either by the eye able to be seen, either by the eye or by a computeror by a computerFocus is on banks and other Focus is on banks and other financial institutionsfinancial institutionsOnce an institution is identified, Once an institution is identified, access to account activity for access to account activity for analysis can beginanalysis can begin

Indicators of Terrorist Financial Activity

Indicators of Terrorist Indicators of Terrorist Financial ActivityFinancial Activity

What is an Indicator… ?

Electronic fund transfers Electronic fund transfers to/from a nationto/from a nation known to known to support terrorism;support terrorism;

Large overseas fund transfers from a business entity Large overseas fund transfers from a business entity to an individual;to an individual;

Foreign bank account with multiple affiliated Foreign bank account with multiple affiliated currency accounts;currency accounts;

Fund transfers to a destination inconsistent with Fund transfers to a destination inconsistent with originator's business activity;originator's business activity;

BANKING PATTERNSBANKING PATTERNS

Funding of Funding of accounts dominated by cashaccounts dominated by cash and and overseas overseas wire transfers;wire transfers;

Large overseas fund transfers that originate, or are Large overseas fund transfers that originate, or are withdrawn in cash;withdrawn in cash;

Fund transfers to/from unlicensed or unincorporated Fund transfers to/from unlicensed or unincorporated business entities;business entities;


Fund transfers to/from a business entity Fund transfers to/from a business entity w/o a street w/o a street mailing address;mailing address;

Small retail business entity makes cash Small retail business entity makes cash deposits in deposits in currency only, no coinscurrency only, no coins ;;

Efforts by known terrorism facilitators to transfer Efforts by known terrorism facilitators to transfer money to the U.S.money to the U.S.


ACCOUNT PROFILESACCOUNT PROFILESACCOUNT PROFILES

Opened with cash/cash equivalents in the average Opened with cash/cash equivalents in the average amount of $3,000 to $5,000;amount of $3,000 to $5,000;

OOpened accounts with visaspened accounts with visas issued in suspect issued in suspect countries or areas;countries or areas;

Client provides Client provides vague identification vague identification or documents or documents with with recent issue dates;recent issue dates;

Customer Customer refuses to refuses to provide information required provide information required by the financial institution;by the financial institution;

ACCOUNT PROFILESACCOUNT PROFILESACCOUNT PROFILES

Provides information that is misleading or difficult Provides information that is misleading or difficult to verify;to verify;

Joint accounts are opened with no apparent Joint accounts are opened with no apparent family family or business or business relationship;relationship;

AddressesAddresses may not be permanent, or have changed may not be permanent, or have changed frequently;frequently;

Shared addressesShared addresses which are also business which are also business locations;locations;

Currency transactions do not seem to correspond Currency transactions do not seem to correspond to stated business.to stated business.

ACCOUNT PROFILESACCOUNT PROFILES

Account holders use Account holders use same address/telephone same address/telephone numbernumber on different accounts;on different accounts;

Customer is Customer is unwilling to provide explanationunwilling to provide explanation of of financial activity;financial activity;

Customer Customer overover--justifies, justifies, overover--explainsexplains or presents or presents confusing details; confusing details;

Customer is Customer is nervous, secretivenervous, secretive and reluctant to meet and reluctant to meet in person;in person;

ACCOUNT PROFILESACCOUNT PROFILES

Customer attempts to convince employee not to Customer attempts to convince employee not to complete documentation;complete documentation;

Customer inordinately Customer inordinately delays presenting delays presenting documents;documents;

Account opened in the name of an entity related to Account opened in the name of an entity related to terrorist organizations;terrorist organizations;

Inconsistent timingInconsistent timing of disbursements or depositsof disbursements or deposits

MultipleMultipleidentification and identification and travel documents;travel documents;FalseFalse IDs used to IDs used to obtain financial obtain financial docs;docs;False financial docs False financial docs used as means of used as means of supportingsupporting their their operations.operations.

Patterns in Terrorism Financing

Patterns in Terrorism Patterns in Terrorism Financing Financing

False DocumentationFalse Documentation

Terrorists may engage in Terrorists may engage in frequent/extensivefrequent/extensive travel;travel;

May purchase ticket in May purchase ticket in cashcashprior to travel;prior to travel;

Travel to Travel to ““Hot SpotsHot Spots”” may may indicate indicate training camptraining camptravel. travel.


Patterns in Terrorism Patterns in Terrorism FinancingFinancing

Frequent Travel to “Hot Spots”Frequent Travel to “Hot Spots”

Telephone or ETelephone or E--mail mail communicationscommunications;;Multiple Multiple shipmentsshipmentsof goods;of goods;Multiple financial Multiple financial transactionstransactions..



Extensive Contact with “Hot Spot” AreasExtensive Contact with “Hot Spot” Areas

Storage lockersStorage lockersused to store used to store weapons, weapons, materials;materials;Frequent visitsFrequent visitsto the lockers;to the lockers;Alter vehiclesAlter vehicles to to store and secrete store and secrete weapons, weapons, components, etc.components, etc.



Use of Storage Facilities /Alteration of VehiclesUse of Storage Facilities /Alteration of Vehicles

Lawful entries which Lawful entries which result in result in overstaysoverstays, , fraud, abuse:fraud, abuse:AddressAddress on on application is a hotel, application is a hotel, business, nonbusiness, non--residential;residential;StudentStudent visa fraud;visa fraud;Sham Sham marriagesmarriagesFalseFalse paper paper



Visa Overstays and Immigration FraudVisa Overstays and Immigration Fraud

FrequentFrequent money money transfers;transfers;Frequent Frequent overseas overseas money money transfers;transfers;Large cash Large cash transfers with transfers with no no gainful gainful employmentemployment;;Financial Financial linkslinks to to terrorist NGOs.terrorist NGOs.



Unexplained Financial AssetsUnexplained Financial Assets

TERRORISM FINANCING

MECHANISMS


MECHANISMSMECHANISMS

Hawala:Alternative Remittance

System

Hawala:Hawala:Alternative Remittance Alternative Remittance

SystemSystem

Alternate RemittersAlternate RemittersAlternate RemittersHawala (Used in the Middle East,

Afghanistan, and Pakistan)

• An informal value transfer system that receives money, transfers the funds or an equivalent value of money to a third party in another geographical location

• Based on TRUST – family or regional relationships

• Involves loose groups of participating individuals

Hawala (Used in the Middle East, Hawala (Used in the Middle East, Afghanistan, and Pakistan) Afghanistan, and Pakistan)

•• An informal value transfer system that receives An informal value transfer system that receives money, transfers the funds or an equivalent money, transfers the funds or an equivalent value of money to a third party in another value of money to a third party in another geographical location geographical location

•• Based on TRUST Based on TRUST –– family or regional family or regional relationships relationships

•• Involves loose groups of participating individualsInvolves loose groups of participating individuals

Alternate RemittersAlternate RemittersAlternate Remitters

Allows for the transfer of money around the world

• Minimal use of negotiable instruments

• Transfers can occur via facsimile, telephone or internet

Allows for the transfer of money Allows for the transfer of money around the worldaround the world

•• Minimal use of negotiable Minimal use of negotiable instrumentsinstruments

•• Transfers can occur via facsimile, Transfers can occur via facsimile, telephone or internettelephone or internet

A Hawala TransactionA Hawala Transaction

Sender wants to transmit money to Sender wants to transmit money to another geographical locationanother geographical location

Hawaladar in the US takes the Hawaladar in the US takes the senders money and is the senders money and is the transmitter for an agreed feetransmitter for an agreed fee

Hawaladar in another geographical Hawaladar in another geographical locations agrees to deliver the locations agrees to deliver the money to the recipientmoney to the recipient

HawalasHawalasFunds transmitted through banks, money order Funds transmitted through banks, money order services, and cash couriersservices, and cash couriers

Transactions can be done anonymouslyTransactions can be done anonymously

Hawalas do not require bank accounts or Hawalas do not require bank accounts or personal identification to send or receive moneypersonal identification to send or receive money

Hawalas can transmit money to countries that Hawalas can transmit money to countries that lack formal banking systems or are prohibited by lack formal banking systems or are prohibited by US law from carrying out transactions with US US law from carrying out transactions with US banksbanks

Hawalas are faster and more reliable than Hawalas are faster and more reliable than traditional banking institutionstraditional banking institutions

Unclassified

$

$Verbal Interchange


Broker

Receiver

Sender

·Paperless

·Untraceable

·Moves in Both Directions

·Trust-based

Broker

Hawala is the best known Hawala is the best known Informal Funds Informal Funds TransferTransfer (IFT) system. Interpol estimates (IFT) system. Interpol estimates India alone to have $680 Billion in India alone to have $680 Billion in transactions annually.transactions annually.

The process uses both legal and illegal The process uses both legal and illegal means to move money in a way that avoids:means to move money in a way that avoids:-- Record keeping of transmitters and Record keeping of transmitters and

receiversreceivers-- TaxesTaxes-- Customs dutiesCustoms duties

It is secure, trustIt is secure, trust--based, paperless and based, paperless and generally untraceable.generally untraceable. Western Union Ad Warning

Potential Hawala Users


Hawala came into public interest after the Hawala came into public interest after the 2001 attacks on the US when it was 2001 attacks on the US when it was revealed that much of the money funding revealed that much of the money funding the attackers was transferred by Hawala. the attackers was transferred by Hawala.

It has no formal limitations on amounts It has no formal limitations on amounts but does have practical limits. It is well but does have practical limits. It is well suited for terror operations that cost $50suited for terror operations that cost $50--$70K to fund and complete in a short $70K to fund and complete in a short period of time.period of time.

It is illegal in many countries including the It is illegal in many countries including the US, yet many banks in both Islamic and US, yet many banks in both Islamic and Western countries utilize this system.Western countries utilize this system.

Western Union Ad WarningPotential Hawala Users


Directly guided and funded major Directly guided and funded major terrorist attacks/operationsterrorist attacks/operations•• 9/11 attacks9/11 attacks•• USS Cole bombingUSS Cole bombing•• East Africa embassy bombingsEast Africa embassy bombings

Used the formal banking system Used the formal banking system themselves when necessary to themselves when necessary to fund terrorist cellsfund terrorist cells•• Ramzi Bin AlRamzi Bin Al--ShibhShibh•• Khalid Sheikh MohammedKhalid Sheikh Mohammed•• Mustapha AlMustapha Al--HawsawiHawsawi

Al Qaeda and Financing Al Qaeda and Financing

Prior to committing certain terrorist Prior to committing certain terrorist acts, unused money was sent back acts, unused money was sent back to Al Qaeda facilitatorsto Al Qaeda facilitators

•• Individuals carrying out the bombing Individuals carrying out the bombing of the USS Cole in Yemen sent of the USS Cole in Yemen sent money back to the UAEmoney back to the UAE

•• Mohamad Atta and other 9/11 Mohamad Atta and other 9/11 hijackers sent money back to UAEhijackers sent money back to UAE

Al Qaeda and FinancingAl Qaeda and Financing

Al Qaeda and FinancingAl Qaeda and Financing

Pre 9/11, the US Government Pre 9/11, the US Government examined financial records after examined financial records after the terrorist act occurredthe terrorist act occurred

However, since 9/11 there is a However, since 9/11 there is a renewed focus on tracking renewed focus on tracking terrorist financingterrorist financing in order to in order to disrupt and dismantle terrorists disrupt and dismantle terrorists and their funding mechanismsand their funding mechanisms

MONEY TRANSFERS from the UAE to the USMONEY TRANSFERS from the UAE to the US

Mohamed Atta AA Flight 11

Pilot

Marwan Al-Shehhi AA Flight 175

Pilot

Citibank New York, NY

SunTrust Bank Gulf Coast, FL

Account Owner Account Owner

Fedwire Cr Trn #12345 from: Support Network

07/19/00 08/07/00 08/30/00 09/18/00




$9,985$9,985 $9,485$9,485 $19,985$19,985 $69,985$69,985

Marwan AlMarwan Al--ShehriShehri

09/10/01 $5,400 Wired from

Greyhound Station, Boston, MA

Mohamed AttaMohamed Atta

09/08/01$2,860 and $5,000

Wired from two Laurel, MD grocery

stores

Waleed AlWaleed Al--ShehriShehri

09/09/01 $5,215 Wired from

Logan Airport, Boston, MA

Al-Ansari Exchange

Receiver: Terrorist Support NetworkReceiver: Terrorist Support NetworkReceiver: Terrorist Support Network

Wall St. Exchange, UAE

MONEY TRANSFERS from the US to the UAEMONEY TRANSFERS from the US to the UAE

Nawaf AlNawaf Al--HazmiHazmi

09/10/01 $10,000 Express

Mail, Baltimore, MD

Fayez BanihammadFayez Banihammad

09/05/01$8,000 Wired from Ft. Lauderdale, FL

P.O. Box

Sharjah, UAE

Receiver: Terrorist Support NetworkReceiver: Terrorist Support Network

Standard Chartered Bank

Sharjah, UAE

Intercepted

MONEY TRANSFERS from the UAE to the USMONEY TRANSFERS from the UAE to the US

Hijackers had Hijackers had no valid social no valid social security numbersecurity numberUsed Saudi Arabian, UAE, German, Used Saudi Arabian, UAE, German, Egyptian and Lebanese Egyptian and Lebanese passports/visas to open accountspassports/visas to open accountsAccounts were Accounts were opened with cashopened with cash, , travelers checks, in amounts of $3,000 travelers checks, in amounts of $3,000 to $5,000to $5,000Traveled to bank Traveled to bank in groupsin groups; opened ; opened some joint accountssome joint accountsAll accounts were All accounts were normal checking normal checking accountsaccounts with debit cardswith debit cards

General CharacteristicsGeneral CharacteristicsGeneral Characteristics

Al Qaeda and Financing 9/11

Al Qaeda and Financing Al Qaeda and Financing 9/11 9/11

Pre 9/11Pre 9/11•• Young malesYoung males•• Traveled as Traveled as

unmarriedunmarried•• Middle EasternMiddle Eastern•• Used true Used true

identitiesidentities

Post 9/11Post 9/11•• Older malesOlder males•• Travel with Travel with

familiesfamilies•• More identifiable More identifiable

with western with western societysociety

•• Use of false Use of false identitiesidentities

General CharacteristicsGeneral CharacteristicsGeneral Characteristics

AHMED RESSAMAHMED RESSAM

Millenium bomberMillenium bomber

Funded through Funded through criminal activitycriminal activity

ZACARIAS MOUSSAOUIZACARIAS MOUSSAOUI

Associated with 9/11Associated with 9/11

Funded by Al QaedaFunded by Al Qaeda

Operational Funding ContrastsOperational Funding ContrastsOperational Funding Contrasts

USA PATRIOT ACTUSA PATRIOT ACT

USA PATRIOT ACTUSA PATRIOT ACT

United and Strengthening United and Strengthening America by Providing Appropriate America by Providing Appropriate

Tools to Intercept and Obstruct Tools to Intercept and Obstruct TerroristsTerrorists

PATRIOT ACTPATRIOT ACT

Removed the Removed the ““WallWall””Facilitates Information SharingFacilitates Information Sharing

Gives CT investigators the same Gives CT investigators the same enforcement tools that criminal enforcement tools that criminal

investigators now possessinvestigators now possess

PATRIOT ACTPATRIOT ACTPATRIOT ACT

Banking and Law Enforcement Provisions

Banking and Law Banking and Law Enforcement ProvisionsEnforcement Provisions

Specific provisions have enhanced Specific provisions have enhanced FBI efforts in Terrorism Finance FBI efforts in Terrorism Finance investigationsinvestigations

•• Banking ProvisionsBanking Provisions

•• Law Enforcement ProvisionsLaw Enforcement Provisions

Passage of USA Patriot ActPassage of USA Patriot Act


Bank ProvisionsBank ProvisionsBank Provisions

•• Established tougher rules for Established tougher rules for correspondent banks;correspondent banks;

•• Requires security brokers to file Requires security brokers to file SARs;SARs;

•• Money transmitters MUST file with Money transmitters MUST file with FinCEN.FinCEN.

T.18, Sec. 1956 enhancements:T.18, Sec. 1956 enhancements:Illegal now to transfer funds to Illegal now to transfer funds to promote terrorism, hostage promote terrorism, hostage taking, and kidnapping (Sami Altaking, and kidnapping (Sami Al--Arian Arian –– PIJ and Rafil Dhafir with PIJ and Rafil Dhafir with ““Help the NeedyHelp the Needy”” charity in charity in Syracuse, NY)Syracuse, NY)


T 18. Sec. 1960T 18. Sec. 1960 –– very effective in very effective in disrupting flows of terror dollarsdisrupting flows of terror dollars

Operating an Unlicensed Money Operating an Unlicensed Money Transmitting Business;Transmitting Business;

Operating an Illegal Money Operating an Illegal Money Transmitting BusinessTransmitting Business

ChargesCharges

Passage of USA Patriot ActPassage of USA Patriot ActLaw Enforcement ProvisionsLaw Enforcement ProvisionsLaw Enforcement Provisions

•• Strengthen existing ban on providing Strengthen existing ban on providing material support to terrorists;material support to terrorists;

•• Provides authority to seize assets;Provides authority to seize assets;

•• Provides authority to seize money in Provides authority to seize money in a foreign bank account by a foreign bank account by authorizing seizure through the US authorizing seizure through the US correspondent account.correspondent account.

Passage of USA Patriot ActPassage of USA Patriot ActPrivacy and ConstitutionalityPrivacy and Constitutionality

--Repeated affirmation by the federal Repeated affirmation by the federal judiciary; judiciary;

--Libraries Libraries -- have been used by have been used by terrorists to do research, preterrorists to do research, pre--operational surveillance and operational surveillance and communicate; communicate;

--Attorney/Client privilege (SDNY and Attorney/Client privilege (SDNY and organized crime cases;organized crime cases;


•• NSLs (used since the NSLs (used since the ‘‘70s) large 70s) large increase proportional to the increase increase proportional to the increase in CT/CI investigationsin CT/CI investigations

•• Gives CT investigators tools already Gives CT investigators tools already possessed by criminal investigatorpossessed by criminal investigator

•• Court Orders (FISC) are still required Court Orders (FISC) are still required to do searches (email, personal to do searches (email, personal property, conversationsproperty, conversations

Title 18 United States Code Section Title 18 United States Code Section 23392339AA•• Prohibits a person within the United States Prohibits a person within the United States

from from providing material support or providing material support or resourcesresources knowing or intending that they are knowing or intending that they are to be used in preparation for or in carrying out to be used in preparation for or in carrying out certain defined terrorist activities.certain defined terrorist activities.

Title 18 United States Code Section Title 18 United States Code Section 23392339BB•• Prohibits a person within the United States or Prohibits a person within the United States or

subject to U.S. Jurisdiction from subject to U.S. Jurisdiction from knowinglyknowinglyproviding material support to a providing material support to a designated foreign terrorist organization.designated foreign terrorist organization.

ChargesCharges

PATRIOT ACTPATRIOT ACT“…“…because we donbecause we don’’t have support. Everybodyt have support. Everybody’’s s scared to give up any money to help us. You scared to give up any money to help us. You know what Iknow what I’’m saying? Because that law that m saying? Because that law that Bush wrote about, you know, supporting Bush wrote about, you know, supporting terrorism, whatever, the whole thingterrorism, whatever, the whole thing……EverybodyEverybody’’s scared s scared …… He made a law that says He made a law that says for instance I left out of the country and I fought, for instance I left out of the country and I fought, right, but I wasnright, but I wasn’’t ale to afford a ticket but you t ale to afford a ticket but you bought my plane ticket, you gave me the money bought my plane ticket, you gave me the money to do itto do it…… By me going and me fighting and doing By me going and me fighting and doing that they can, by this new law, they can come that they can, by this new law, they can come and take you and put you in jail.and take you and put you in jail.””

–– Jeffrey Battle, a member of the Portland Cell Jeffrey Battle, a member of the Portland Cell that was convicted under the PATRIOT Act.that was convicted under the PATRIOT Act.

Terrorism FinancingTerrorism Financing

““Operation SmokescreenOperation Smokescreen””

FBI Charlotte FBI Charlotte

Joint Terrorism Task ForceJoint Terrorism Task Force

BackgroundBackground

--Deputy working partDeputy working part--time at JR Cigarettestime at JR Cigarettes•• OutOut--ofof--state vehicles state vehicles

operated by the same operated by the same individualsindividuals

•• Large purchases of Large purchases of cigarettes (300 cartons)cigarettes (300 cartons)

•• Large wads of cashLarge wads of cash

Deputy contacts local ATFDeputy contacts local ATF•• Active FBI investigation of Active FBI investigation of

LebaneseLebanese--based Hizballah based Hizballah cellcell

•• Law Enforcement agencies Law Enforcement agencies combine effortscombine efforts

•• Joint investigation initiated Joint investigation initiated in Julyin July

North CarolinaNorth Carolina•• Cigarette tax Cigarette tax -- $.65 per carton$.65 per carton•• No tax stamp on cartonNo tax stamp on carton

MichiganMichigan•• Cigarette tax Cigarette tax -- $7.50 per carton$7.50 per carton•• No tax stampsNo tax stamps

HistoryHistory

Method of OperationMethod of Operation

Cigarettes smuggled Cigarettes smuggled from North Carolina from North Carolina to Michigan to Michigan SetSet--up tobacco up tobacco shops as shops as ““frontfront””storesstoresUsed trucks, vans, Used trucks, vans, cars to transport cars to transport cigarettescigarettesPrice difference per Price difference per carton $8.00 carton $8.00 --$10.00$10.00Profit per van load Profit per van load approximately approximately $13,000.00$13,000.00


Cigarettes smuggled Cigarettes smuggled from North Carolina from North Carolina to Michigan to Michigan SetSet--up tobacco up tobacco shops as shops as ““frontfront””storesstoresUsed trucks, vans, Used trucks, vans, cars to transport cars to transport cigarettescigarettesProfit per cartonProfit per carton$8.00 $8.00 -- $10.00$10.00Profit per van load Profit per van load $15,000.00 $15,000.00 --$20,000.00$20,000.00


Search warrants Search warrants executed at executed at residence and residence and businessesbusinesses

Profit over the life of Profit over the life of the scheme:the scheme:

$8,000,000.00$8,000,000.00


Approximately 500 bank, credit card Approximately 500 bank, credit card and other financial accounts were and other financial accounts were obtained and examinedobtained and examinedThe financial document analysis The financial document analysis included the review of the following:included the review of the following:•• Bank accounts for the sources and uses of Bank accounts for the sources and uses of

fundsfunds•• Wire, cash, and money order transactionsWire, cash, and money order transactions•• Checks from coChecks from co--conspirators/othersconspirators/others•• Checks from companies identifying Checks from companies identifying

employeesemployees•• Analysis of inflows and expenditures Analysis of inflows and expenditures

indicated unreported incomeindicated unreported income

Financial InvestigationFinancial Investigation

Bank Account AnalysisBank Account Analysis•• Checks made out to cashChecks made out to cash•• Checks to coChecks to co--conspiratorsconspirators•• Checks to banks and credit card companiesChecks to banks and credit card companies•• Purchase of cashier checksPurchase of cashier checks

Credit Card AnalysisCredit Card Analysis•• Cash and credit cards were used to purchase Cash and credit cards were used to purchase

over $8 million dollars worth of cigarettes from over $8 million dollars worth of cigarettes from JR Tobacco and other outlets.JR Tobacco and other outlets.



Use of Proceeds:Use of Proceeds:•• Purchase real estatePurchase real estate•• Purchase vehiclesPurchase vehicles•• Investment AccountsInvestment Accounts•• Money sent to Lebanon, provided to Money sent to Lebanon, provided to

HizballahHizballah


One subject, Said Harb also committed One subject, Said Harb also committed identity fraudidentity fraudUse fraudulent id to obtained credit Use fraudulent id to obtained credit cards, then maxed the credit cards and cards, then maxed the credit cards and declared bankruptcydeclared bankruptcyChanged identities seven timesChanged identities seven timesHarb later testified that he made at Harb later testified that he made at least $150,000 profit on each least $150,000 profit on each fraudulent identityfraudulent identity

SubjectsSubjects

Three subjects enter the U.S. from Three subjects enter the U.S. from Venezuela using false visas. One was Venezuela using false visas. One was denied a visa in Syria.denied a visa in Syria.

SubjectsSubjects

Three subjects entered the U.S. with Three subjects entered the U.S. with visas issued in Cyprus.visas issued in Cyprus.

SubjectsSubjects

Defendants with their REAL and FAKE spouses, Defendants with their REAL and FAKE spouses, resulting in immigration fraud, bank fraud and resulting in immigration fraud, bank fraud and identity fraud charges.identity fraud charges.

SubjectsSubjects

Trial Chart showing false identities, Trial Chart showing false identities, credit cards, and checkbookscredit cards, and checkbooks

--Weekly prayer meetingsWeekly prayer meetings--Discussed Hizballah operations Discussed Hizballah operations in Lebanon and screen video in Lebanon and screen video tapes tapes --Hizballah violence was Hizballah violence was encouraged and celebrated encouraged and celebrated --Mohammad Hammoud insisted Mohammad Hammoud insisted that a % of illegal profits went to that a % of illegal profits went to support Hizballahsupport Hizballah

Hammound had almost daily Hammound had almost daily contact with individuals in contact with individuals in

Lebanon discussing HizballahLebanon discussing Hizballah’’s s military operations.military operations.

SubjectsSubjects

SubjectsSubjects

Dual Use Items Planned for Dual Use Items Planned for Use by HizballahUse by Hizballah

(purchased with fraudulent (purchased with fraudulent credit cards)credit cards)

Night vision goggles and Night vision goggles and scopesscopesSurveying equipmentSurveying equipmentGlobal Positioning Global Positioning Systems Systems Metal detection Metal detection equipmentequipmentVideo equipmentVideo equipmentAircraft analysis & Aircraft analysis & design softwaredesign softwareMilitary compassesMilitary compassesBinocularsBinocularsNaval equipmentNaval equipmentUltrasonic dog repellersUltrasonic dog repellersLaser range findersLaser range findersDigital cameras, zoom Digital cameras, zoom lenslens

Computer equipment Computer equipment (laptops, high(laptops, high--speed speed modems; processors, modems; processors, joysticks, plotters, joysticks, plotters, scanners, and scanners, and printers)printers)Stun gunsStun gunsHandheld radios & Handheld radios & receiversreceiversCellular telephonesCellular telephonesNitrogen cuttersNitrogen cuttersMining, drilling & Mining, drilling & blasting equipmentblasting equipmentRadarsRadars

ChargesCharges

Material Support or ResourcesMaterial Support or Resources•• Currency, financial securities, financial Currency, financial securities, financial

servicesservices•• Lodging, training, safe housesLodging, training, safe houses•• False documentation or identificationFalse documentation or identification•• Communications equipmentCommunications equipment•• Weapons, lethal substances, explosives, Weapons, lethal substances, explosives,

transportationtransportation•• Other physical assets, except medicine or Other physical assets, except medicine or

religious materialsreligious materials

Designated Terrorist OrganizationDesignated Terrorist Organization•• HizballahHizballah

ResultsResults

25 25 SUBJECTS CHARGED:SUBJECTS CHARGED:•• Trafficking in Illegal Contraband CigarettesTrafficking in Illegal Contraband Cigarettes•• Money LaunderingMoney Laundering•• Bank FraudBank Fraud•• Credit Card FraudCredit Card Fraud•• Visa Entry FraudVisa Entry Fraud•• Material Support to a Terrorist OrganizationMaterial Support to a Terrorist Organization

55 SUBJECTS AT LARGE:SUBJECTS AT LARGE:•• Head of the Hizballah procurement officeHead of the Hizballah procurement office•• Beirut Hizballah military commanderBeirut Hizballah military commander

Promote the filing of Promote the filing of SARsSARs electronicallyelectronicallyVerify where possible, Verify where possible, personal identifierspersonal identifiers and include them on and include them on the SARs and CTRsthe SARs and CTRsCheck ALL violation types that apply and complete each Check ALL violation types that apply and complete each applicable field and narrativeapplicable field and narrativeReport suspected illegal/suspicious money remitters;Report suspected illegal/suspicious money remitters;Report ANY suspicious activity or transactions.Report ANY suspicious activity or transactions.

How Financial InstitutionsCan Help

How Financial InstitutionsHow Financial InstitutionsCan HelpCan Help

How Financial InstitutionsCan Help

How Financial InstitutionsHow Financial InstitutionsCan HelpCan Help

PromotePromote the development of predictive, terrorist and the development of predictive, terrorist and fraud preventionfraud prevention targeting software;targeting software;

Utilize open, public source data to Utilize open, public source data to enhance customer enhance customer information;information;

Maintain dialogueMaintain dialogue with the local JTTF and Terrorist with the local JTTF and Terrorist Financing Coordinator in your region;Financing Coordinator in your region;

Provide law enforcement with Provide law enforcement with 24/7 contacts24/7 contacts for use during for use during emerging threat situations.emerging threat situations.

Terrorists will continue to use multiple means to transfer monieTerrorists will continue to use multiple means to transfer monies to s to operatives, whether the means are legal or illegal, formal or inoperatives, whether the means are legal or illegal, formal or informalformal

Methods will continue to be exploited without effective and meanMethods will continue to be exploited without effective and meaningful ingful regulationregulation

Unlicensed and unregulated money transmitters our a significant Unlicensed and unregulated money transmitters our a significant concern concern for law enforcement for law enforcement –– they can provide an efficient and effective means they can provide an efficient and effective means for terror organizations to finance their attacksfor terror organizations to finance their attacks

We need your help to ferret out these individuals We need your help to ferret out these individuals

CONCLUSIONSCONCLUSIONSCONCLUSIONS

Islamic BankingIslamic Banking must continue to become mainstream in order to be must continue to become mainstream in order to be recognized as trustworthy institutionsrecognized as trustworthy institutions

•• Failing that, they will remain a secretive grouping that raises Failing that, they will remain a secretive grouping that raises suspicions as much as they attract business.suspicions as much as they attract business.

Regulatory efforts will serve to Regulatory efforts will serve to plug more of the financial holesplug more of the financial holes that terror that terror exploitsexploits

However, as with all areas of crime, laws and regulations apply However, as with all areas of crime, laws and regulations apply to all people to all people and entities in a given jurisdiction but are only implemented anand entities in a given jurisdiction but are only implemented and d followed by followed by those willing to be those willing to be regulatedregulated. .

Nations and organizations around the world are Nations and organizations around the world are becoming more involved in becoming more involved in the effortthe effort to track the flow of terrors money through legislation and to track the flow of terrors money through legislation and regulationregulation

CONCLUSIONSCONCLUSIONSCONCLUSIONS

Questions?Questions?

Stephen A. GrimaldiStephen A. GrimaldiSenior Supervisory Resident Senior Supervisory Resident

AgentAgentCharleston Resident AgencyCharleston Resident Agency

Columbia DivisionColumbia Division(843) 722(843) 722--01350135

PATRIOT ACTPATRIOT ACTTwo key provisions of the PATRIOT Act pertain to terror financinTwo key provisions of the PATRIOT Act pertain to terror financing g investigations and involve material support of terrorism:investigations and involve material support of terrorism:

T18, 2339a T18, 2339a –– crime to knowingly provide material support or crime to knowingly provide material support or resources (financial) to a recipient knowing that they are to beresources (financial) to a recipient knowing that they are to beused in preparation for or carrying out a violation of a numberused in preparation for or carrying out a violation of a number of of violent crime or conspiring to do so; the difference from 2239a violent crime or conspiring to do so; the difference from 2239a is is the proving that the material support went directly to a the proving that the material support went directly to a designated terrorist organization, only that the material suppordesignated terrorist organization, only that the material support t would be used to violate specific criminal statutes would be used to violate specific criminal statutes (destroy an (destroy an aircraft; drive by shooting; violence at an airport; arson; aircraft; drive by shooting; violence at an airport; arson; prohibitions to biological weapons; assassinations/kidnappings oprohibitions to biological weapons; assassinations/kidnappings of f congressional, cabinet, supreme court; prohibitions against congressional, cabinet, supreme court; prohibitions against nuclear materials; explosives violations; hostage taking; violennuclear materials; explosives violations; hostage taking; violence ce against maritime shipping or fixed platforms; homicide; use of aagainst maritime shipping or fixed platforms; homicide; use of aweapon of mass destruction; harboring or concealing terrorists)weapon of mass destruction; harboring or concealing terrorists)

T18, 2339b T18, 2339b –– crime to knowingly provide material support or crime to knowingly provide material support or resources (financial) to a designated foreign terrorist organizaresources (financial) to a designated foreign terrorist organization tion or attempt or conspire to do so; same violations as above; or attempt or conspire to do so; same violations as above; Charlotte case is a good exampleCharlotte case is a good example

Documents

Stephen A. Grimaldi Senior Supervisory Resident Agent ... · Charleston Resident Agency Columbia Division (843) 722-0135. The #1 Mission of the FBI Post 9/11: ... FBI used court approved