This was from Feb 2002, so just think of the possibilities 3 years later. (I emphasized a few items I thought relevant to the continuing evolution of investigating US citizens.) Entire testimony at link.
Congressional Testimony
Testimony of Dennis M. Lormel, Chief, Financial Crimes Section, FBI
Before the House Committee on Financial Services, Subcommittee on Oversight and Investigations
February 12, 2002
http://www.fbi.gov/congress/congress02/lormel021202.htm"Financial Review Group
In order to provide a comprehensive analysis of the financial evidence, the DOJ and FBI established an inter-agency Financial Review Group (FRG) operating out of FBI Headquarters. Other participants in the FRG include representatives of the Central Intelligence Agency, National Security Agency, Defense Intelligence Agency, Drug Enforcement Agency, and components of the Treasury Department including the U.S. Customs Service, Internal Revenue Service, Bureau of Alcohol, Tobacco and Firearms, Office of Foreign Asset Control (OFAC), United States Secret Service and Financial Crimes Enforcement Network, U.S. Postal Inspection Service, National Drug Intelligence Center, the Federal Reserve, and the Inspector General Community.
From the initial focus on the events of September 11th, the mission of the FRG has evolved into a broader strategy to investigate, prosecute, disrupt, and dismantle all terrorist-related financial and fund-raising activities. In the days immediately following September 11th, the FRG was formed with a two-fold mission. On one track, a comprehensive financial analysis of the 19 hijackers was conducted to link them together and to identify their financial support structure within the U.S. and abroad. Collateral to this was the development of a template for pro-active, preventive, and predictive terrorist financial investigations.
The FRG has taken a leadership role in coordinating the financial investigative effort, and it is a comprehensive, far reaching effort. To accomplish our mission, the FRG has implemented, and continues to implement, strategies and initiatives to address all aspects of terrorist financing and explore all options. Among these are efforts to organize, catalog, and review vast amounts of personal and business records, develop linkage and time lines concerning terrorist cells and groups, facilitate Mutual Legal Assistance Treaty requests and Letters Rogatory, develop financial and investigative leads in support of terrorism investigations, identify criminally-related fund-raising activities by terrorist organizations, utilize the resources and expertise of the financial services community, develop a centralized financial database, and develop predictive analysis models. By bringing together participating agencies' databases and expertise, the FRG is focusing a powerful array of resources at the financial structure of terrorist organizations. Throughout this process, the FRG has worked closely with the Department of Treasury, which has primary responsibility for the blocking and freezing of terrorist assets.Through the FBI's historical involvement with the intelligence community, the FBI and CIA quickly coordinated and further combined their resources to investigate terrorist funding mechanisms. This relationship facilitates a seamless interaction between the FBI and intelligence community, and is in addition to other key personnel the CIA and FBI each currently have assigned to the other's headquarters. The FBI in its intelligence capacity also obtains considerable intelligence information through Foreign Intelligence Surveillance Act orders. The FRG works closely with this aspect of the FBI's Counterterrorism program in assessing and applying proper utilization of such information, pursuant to Attorney General Guidelines and the orders of the Foreign Intelligence Surveillance Court.
The FRG has created and continues to develop a centralized terrorist financial database in concert with coordinating and assisting in the financial investigation of over 250 individuals and groups who are suspects of FBI terrorist investigations. To date, the FRG has cataloged and reviewed over 321,000 financial documents obtained as a result of numerous financial subpoenas pertaining to over 10,500 individuals and accounts. Over 104,000 of these documents have been verified as being of investigatory interest and have been entered into the terrorist financial database for linkage analysis. The FRG has obtained financial information from 54 FBI Field Divisions and 11 Legal Attache Offices, and has reviewed and documented over 66,000 financial transactions. These records include over 149 foreign bank accounts and over 5,300 foreign wire transfers.
The FRG is both an operational and coordinating entity with pro-active and reactive responsibilities. There are any number of approaches that can be utilized in investigating these networks. Success lays in careful coordination of these approaches. By way of example, various FBI Field Offices have launched criminal financial investigative initiatives geared at fraud schemes with a potential nexus to terrorist financing. The FRG is coordinating these initiatives as I will discuss later in my statement. As an operational body, the FRG conducts national and international investigations from its headquarters in Washington, D.C., while collecting information and directing leads to the JTTFs located in each Judicial District, as well as leads to other FBI Field and Legal Attache Offices around the world.
As a participant on the National Security Council's Policy Coordinating Committee (PCC) on terrorist financing, chaired by Treasury Department General Counsel David Aufhauser, the FRG continues to function in a leadership role in the efforts to target Non-Governmental Organizations (NGOs) believed to provide financial support to known Foreign Terrorist Organizations (FTO) and other affiliated terrorist cells. The FRG is currently actively involved in the coordination of twelve multi-jurisdictional NGO investigations. In order to disrupt the terrorist financing channels, the FRG has coordinated these and other FBI terrorist investigations with the terrorist designation and asset freezing efforts of the Department of Treasury's Office of Foreign Assets Control (OFAC) and Operation Green Quest. These efforts have resulted in the freezing of millions of dollars in foreign and U.S. bank accounts. Specifically, the joint efforts targeting Al-Barakaat, the Holy Land Foundation for Relief and Development, the Global Relief Foundation, and the Benevolence International Foundation have resulted in the execution of numerous search warrants and the disruption of the fund-raising and money remittance operations of these and other NGOs. Financial investigations of these entities have revealed that approximately $200 million in contributions passed through these organizations each year. The FRG will also coordinate with the Department of the Treasury in its other initiatives in order to help ensure their success.
The FRG has conducted an aggressive national and international outreach initiative in an effort to share information regarding terrorist financing methods with the financial community and law enforcement. The review group has built upon long-established relationships with the banking, debit, credit and financial services communities in the United States and abroad. The international outreach initiative is coordinated through the network of FBI Legal Attache Offices located in 44 key cities worldwide, providing coverage for over 200 countries, territories, and islands. The FRG has become an international model for investigating the financial components of terrorism. As a result, the FRG has assisted several foreign countries in their efforts to establish a financial terrorist investigative component that mirrors the structure of the FRG.
A significant focus of the FRG is predictive/preventive analysis. In this capacity, the FRG conducts data mining and financial profiling to identify common characteristics of terrorist financing. The FRG has developed numerous data mining projects in order to provide further predictive abilities and maximize the use of both public and private database information. This information will be used to identify terrorist cells operating in the U.S. and abroad in an effort to prevent further terrorist acts. Through the FRG's aggressive national and international outreach and liaison efforts, appropriate information regarding patterns and profiling is shared and coordinated with appropriate private and public sector entities. For example, the FRG meets regularly with representatives from the banking community and the financial services industry to share such information and to jointly develop and refine methods to detect and identify potential terrorist and/or terrorist activity. The FRG is also reviewing and conducting additional financial analysis of prior terrorist acts in an effort to identify links and patterns that would complement current and future terrorism investigations. The FRG directly supports the FBI's Counterterrorism Division through financial analysis of terrorism investigations. While the FRG plays a key role in the overall Counterterrorism effort, it is but one piece of the big picture. Accordingly, careful coordination at all times is critical to ensure financial investigations complement the overall strategy and do not adversely impact other efforts. Based on the FRG's role in the FBI's Counterterrorism Division, its international investigative abilities, and its close association with the intelligence community, the review group is in a unique position to coordinate anti-terrorism financial investigations domestically and internationally, and to ensure those investigations are in harmony with the overall goals and objectives of the United States' Counterterrorism program.
Anti-terrorism financial investigations represent a comprehensive labor intensive long-term commitment.
It is anticipated that in order to prepare predictive analysis in support of this effort, tens of millions of financial documents (bank records, travel records, credit card, and retail receipts, etc.) will need to be collected, thoroughly analyzed, and placed in a central database for relevant financial evidence. This evidence can then be integrated with other terrorist evidence collected by law enforcement and others. As I previously stated, the FRG has initiated a number of data mining projects in order to fully exploit the growing financial database and pro-actively identify and target potential terrorists and terrorist activity. This includes the use of predictive pattern recognition algorithms.Given the enormity of the task and the long-term nature of the effort, I cannot sit here today or next week and tell you we have all the answers. It will take time to effectively and pro-actively address terrorism financing. This is not to say that progress hasn't been made. In conjunction with pro-active long-term efforts, the FRG continues to aggressively conduct intensive financial investigations as circumstances arise; dedicating necessary resources to react immediately to new information and evolving events. The FRG has made substantial progress in our efforts and I would like to offer this Subcommittee a brief summary of this progress, subject of course to restrictions related to the disclosure of information that might compromise or undermine ongoing criminal investigations.
We have focused our financial investigations in four main areas: (1) mission specific terrorist cells such as the 19 hijackers, (2) so called "sleeper" cells that are more loosely organized but blend into communities easier through legitimate employment, (3) terrorist groups that fund their terrorist activity through fraud schemes, and (4) the funding of terrorist organizations through Non-Governmental Organizations (NGO) and charities. I would like to focus the remainder of my statement on describing what we are doing in these areas and what progress has been made."