Counter Threat Finance (CTF): Grasping the Eel

“Following the money trail” has become a critical cross-cut­ting component for counter-crime, counter-narcotics, and counter-terrorism efforts against illegal networks.[1] While conceptually straightforward, the fluid and varied means of money transfer make counter-threat finance operations dif­ficult to successfully implement. The open nature of modern society and the sheer volume of capital transfers that com­pose the fabric of the global financial system make it almost impossible to identify, trace, and cut off terrorist or cartel funds. [2] Metaphorically like eels, illicit financiers and their monies can slip through the hands of the government organi­zations tasked to interdict and grasp them.

The prevention of money laundering and the financing of ter­ror are today a matter of high priority, both nationally and in­ternationally, because they concern complex phenomena with serious political, economic, and social consequences. These activities generate public insecurity and social destabilization and can severely damage the reputation of financial sectors and entire countries.[3] This informational article seeks to be a threat finance primer by first defining it, and then differ­entiating between its two major sub-components of terror­ist financing and cartel money laundering.[4] While acknowl­edging both the similarities and differences between these sub-elements of threat finance, the article will then discuss four major problem areas in this field – the differing cash flow magnitudes of the threat finance sub-components; the current literature and discourse on the subject; interagency coordination and partner building activities, especially in a peacetime environment; and measuring the success of coun­termeasures. The United States will be the country of focus given its leadership and practitioner role in counter threat fi­nance operations. The article will then offer some ideas for taking this discipline forward from a policy level discussion to a more pragmatic, operational level application.

Definitions

Threat finance is an umbrella term used to encompass vari­ous types of financing employed by rogue nations, terrorist facilitators, weapons of mass destruction (WMD) proliferators, money launderers, drug kingpins, and other national security threats that support activities harmful to national security. [5] Within the U.S. government and the Department of Defense (DoD), for example, no singular, accepted definition of threat financing exists, and often the variance in definition reflects the par­ticular nature of an organization; predominantly military or law enforcement, or an area of focus-strategic, theater stra­tegic, or operational.[6] One reason for the lack of a clear and comprehensive definition may be the complexity of the topic, combined with the diversity of government actors involved. While the term terrorist finance is commonly used in inter­national security literature to mean threat finance, it is too narrow, focusing only on organizations, cells, and individu­als linked to terrorism. Other sources see threat finance as a much broader-based concept that includes proliferation and weapons of mass destruction/effects (WMD/E) funding, ter­rorist financing, narcotics trafficking, organized crime, and human trafficking: all activities that endanger the integrity of financial systems around the world.[7]

The essay supports this broader definition.[8] For simplifi­cation, threat finance divides into the two major subcompo­nents of cartel money laundering (which includes organized crime, narcotics, fraud, corruption, and human trafficking), and terrorist financing (which subsumes WMD/E). Cartel money laundering is the process designed to conceal the origin of money resulting from criminal activities. Criminals exploit economic and financial globalization and the advances made in technology and communications with a view to concealing the origin of funds that they have gained through illegal acti­vities. They make extensive use of a broad array of techni­ques, such as the rapid transfer of money from one country to another or the misuse of corporate vehicles to disguise the true ownership of funds.[9]

Terrorist financing is simply the process of raising, storing, and moving funds, obtained through illegal or legal means, for the purpose of terrorist acts or sustaining the logistical structure of a terrorist organization.[10] Like money launder­ers, those who finance terrorism misuse the financial sys­tem. In order to achieve their objectives, they have to obtain and channel funds in an apparently legitimate way. However, while the money involved in the money laundering process al­ways stems from a crime and is therefore “dirty”, funds chan­neled to terrorist groups or individuals may originate from crime and/or from legitimate sources. Terrorism may therefore be sup­ported by either “dirty” and/or “clean” funds. Regardless of the origin of the funds, terrorists use the financial system in a similar way to criminal organizations in order to obscure both the source and the destination of their funds.[11] For both types of malefactors, the degree of sophistication in illicit financing schemes is infinite and is limited only by the creative imagination and expertise of the criminals or terror­ists involved. [12]

Differences among threat financiers

Variances exist between the two types of threat financiers in the visibility of their overt and covert activities, the scale of their cash flows, and their ultimate goals. In their exer­cise of violence, transnational criminals typically act covertly to avoid exposure, while terrorists prefer to gain notoriety through spectacular acts.[13] Unlike ordinary criminals, ter­rorists tend to avoid living conspicuous lifestyles that would alert authorities to the presence of extra income.[14] An­other distinction between the two activities is in their scale: traditional money launderers deal with large cash flows while terrorists deal with much smaller amounts. [15] Governments are concerned about this latter attribute since terrorist groups can fund and conduct terrorist activities on a shoestring. Fi­nally, unlike organized crime, the terrorist organizations are not concerned with their bottom line and can focus all money efforts on their nefarious activities. Organized crime is con­strained by their desire to earn a profit and avoid extra costs that impinge on the profitability of their business models.[16]

Yet, there are legitimate fears of a nexus emerging between crime groups and particularly Islamist terrorists.

Transnational criminal networks such as organized crime groups, drug traffickers, and weapons dealers at times share convergence points-places, businesses, or people-to convert their illicit profits into legitimate funds. Many of these dispa­rate networks also appear to use the same financial interme­diaries and front companies to plan arms and narcotics deals because they view them as safe partners for doing business. Cash-intensive and high-volume businesses such as casinos are especially attractive, particularly those in jurisdictions that lack the political will and oversight to regulate casino operations or fail to perform due diligence on casino licensees. Illicit networks also abuse some of the same finan­cial intermediaries and front companies in regions where gov­ernment or law enforcement corruption is prevalent, with of­ficials receiving either revenues from the criminal businesses or ownership stakes in the legitimate-appearing commercial entity.[17] The common worry is that jihadists will seek to fi­nance international or antiwestern attacks either by working in tandem with such criminal networks, partnering directly with cash-rich drug cartels, or through generating their own independent narcotics profits. For example, there is consid­erable money to be made through the mark-up sale of drugs like heroin or cocaine. The 2008 wholesale price for a gram of cocaine in Colombia, for instance, was estimated to be around $2.30. That same gram costs $8.10 in Mexico, $27 in the United States (at average purity levels), $60 in Europe, and as much as $148 in the Russian Federation. [18]

Differences in Cash Flow Magnitude

Understanding the total scope of threat finance cash flow in order to define strategies, operations, and tactics, bedev­ils policy-makers and specialists. Criminals, especially drug traffickers, may have laundered around $1.6 trillion, or 2.7 per cent of global GDP, in 2009, according to a new report by United Nations Office on Drugs and Crime (UNODC).[19] This figure is consistent with the two to five percent GDP range first established by the International Monetary Fund to estimate the scale of money-laundering, which it assessed at around $600 billion per year in 2007.[20] Both these figures are ap­proximations. Furthermore, less than 1 per cent of global illicit financial flows is seized and frozen, according to the 2011 report entitled Estimating illicit financial flows resulting from drug trafficking and other transnational organized crime. "Tracking the flows of illicit funds generated by drug traffick­ing and organized crime and analyzing how they are laun­dered through the world's financial systems remain daunt­ing tasks," acknowledged Yury Fedotov, Executive Director of UNODC. [21]

Bulk cash smuggling is a case in point. The U.S. govern­ment established the National Bulk Cash Smuggling Center (BCSC) in 2009 to combat bulk cash smuggling, since threat financiers have moved away from the formal banking sector due to heightened scrutiny, regulatory oversight, and inter­diction. The BCSC is an operations support facility providing real-time investigative assistance to U.S. federal, state, and local officers involved in enforcement and interdiction of bulk cash smuggling and the transportation of illicit proceeds. The BCSC partners with the El Paso Intelligence Center to fur­ther identify and target the financial infrastructure of drug trafficking organizations. These criminal organizations seek to avoid traditional financial institutions by repatriating illicit proceeds through cash in commercial and private aircraft, passenger and commercial vehicles, maritime vessels, and pedestrians crossing at U.S. land borders.[22]

Unfortunately, the interdiction results may be less than ex­pected.[23] According to the U.S. National Drug Intelligence Center (NDIC), bulk cash seizures in the United States to­taled $798 million from January 2008 through August 2010. These seizures were related to drug trafficking cases involving Mexican-based transnational criminal organizations (TCOs). Demonstrating the size and importance of the bulk cash ope­rations related to the illicit drug trade, however, is the negli­gible effect that these seemingly large seizures have had on stemming transnational criminal operations. NDIC stated in their 2011 National Drug Assessment Report that “bulk cash interdiction efforts have not impacted overall TCO operations to a significant extent.”[24]

In contrast, while the amount of money flowing to terrorist organizations is unknown, those with documented finances appear to require less than previously estimated. The Provi­sional Irish Republican Army (PIRA) operated on a budget of some £1.5 million per year. The Real IRA and the Ulster Defence Association required only £500,000 per annum.[25] This smaller scale of demand makes detecting terrorist fi­nancing a more difficult task, leading to assertions from skeptics that tracking money is a marginal strategy in coun­tering terrorism. [26] For example, in a study of 10 Al Qaeda terrorist actions from 1998–2005, the projected costs of funding the operations ranged from $10,000 to $500,000, with 8 of the 10 cases under $50,000.[27] These amounts are small when compared to daily, global financial flows.

Tracking these funds becomes even more problematic. The same study showed that there is no empirical evidence of the use of formal sector financial institutions for cross-border movement of funds by Al Qaeda after 2003. If anything, Al Qaeda Central solicited funds from associated groups, as in­dicated by al-Zawahiri’s infamous letter to al-Zarqawi in Iraq in 2005.[28] Al Qaeda affiliates seem to resort to transfers through cash couriers and barter trade for the cross-border movement of funds.[29] Al Qaeda and its associates have in­creasingly relied on local acts of crime to self-finance their activities. In some cases petty crime, such as welfare fraud and credit card bust-out schemes, raise limited amounts of money for small operations. In others, aspiring terrorists raise significant sums through brazen crimes. One cell in France netted about one million Euros when a member whose job was to restock ATMs enacted robberies on several. [30] Re­gardless of the act, the local approach is hard to detect and interdict for governmental authorities.

While the U.S. and international community continue to dis­rupt the funding streams of terrorist organizations, it remains a challenge to identify terrorist financial activity through the financial sector for a multitude of reasons: the nuanced dif­ficulty in distinguishing suspicious/illicit activity from the routine, the disguises used in hiding illicit financial activity, and the relatively low cost of executing a terrorist act. [31] One telling example is the post 9/11 effort by the private financial sector to develop profiles for terrorist finance. The banking sector invested substantial time and exertions in this exercise, notwithstanding earlier findings from the analysis of the financial background of the 9/11 plotters and their operations, which showed that they were unpredictable and largely ‘normal’. [32]

Current literature and discourse on the subject

A second area of concern is the public knowledge available on threat finance. Open source literature on threat finance is limited for policy-makers. While information on cartel finan­cing receives more transparency because of publically avail­able legal proceedings, the terrorist side is more problematic. In a special report, Professor Thomas Biersteker provided an important critique of current threat finance literature and the so-called “experts” who produce it. Given the relative pau­city of reliable information on the financing of terrorism and the complex nature of the phenomenon, numerous authors have produced a vast literature on the subject. Most of the published work is highly repetitive, with a frequent restate­ment of highly stylized facts and broad generalizations. While these works might be good for producing catchy headlines, their analytical basis generally leaves much to be desired, and the focus on a single dimension or source of financing terrorism is reductionist and trivializes the complexity of the subject. The literature is better on the regulatory regime and policy-side than on the analysis of the actual financing of ter­rorism. This is logical since it is easier to access government and intergovernmental policy practitioners than individuals who engage in real acts of terrorism.[33]

Much of the analysis of general threat finance tends to pro­vide laundry lists of different means to raise funds, move funds, or store value for the benefit of terrorist or criminal or­ganizations. Examples of this categorization exercise include bulk cash smuggling, traditional banking, wire transfers, mo­ney exchange services, trade-based money laundering, storage with value cards/prepaid instruments, mobile and electronic payments, and charity diversion. While these lists are useful for anticipating any or all contingencies, they are not very va­luable for planning and executing operations. [34]

For example, while charities diversion is believed to be a prin­cipal means of financing terrorism, there is very little syste­matic, comparative research on the subject, and this assump­tion while widely shared, is hotly contested. Most of the research involves case-by-case inquiry on different groups or on major acts of terrorism (such as the attacks of 11 Sep­tember 2001), and is therefore anecdotal. Biersteker’s explo­ratory study conducted a systematic analysis of significant Al Qaeda cases, where there is adequate public-source informa­tion available to make a comparative assessment of sources of terrorist attack financing. He assessed visible trends over time, with a focus, in particular, on whether charities diver­sion is a significant or continuing source of financing for the commitment of acts of terrorism by Al Qaeda and its affiliates.

His conclusion was that there is little evidence that charities diversion remains a significant source of financing for core Al Qaeda activities. [35] Overall, a close analysis of the state of threat finance literature shows that there is very little use­ful and original empirical information in the public domain.

Interagency coordination and building partner nation capacity in a peacetime environment

By its nature, CTF is an interagency activity. In the United States, a significant number of agencies and organizations within the government contribute to various dimensions of the counter-threat finance mission. Yet as has been seen in the context of other critical U.S. national security missions-par­ticularly those focused on emerging or ambiguous threats-the proliferation of interagency stakeholders can lead to friction and failures of coordination. The counter-threat finance com­munity has not been immune to these problems. Agencies struggle with information-sharing, timely operational coordi­nation, and at times, divergent perceptions about the relative prioritization of threats. The experiences of the interagency Threat Finance Cells in Iraq and Afghanistan are among the clearest examples in recent years of the dramatic effects that can be achieved in support of wider national security objec­tives through focused and sustained interagency coordina­tion, and all without inordinate resources. [36]

The creation of the Iraq Threat Finance Cell (ITFC) (2005 – 2010) and subsequently the Afghan Threat Finance Cell (ATFC) (2008 – present) represent the successful implemen­tation of an effective organizational model to counter threat finance. These threat finance cells (TFCs) are interagency units, co-led by the Department of Defense and the Depart­ment of the Treasury (and in the case of the ATFC, headed by the Drug Enforcement Administration), wherein several U.S. national security agencies are represented through ana­lysts deployed to combat zones and detailed to support the cells. [37] The Iraq Threat Finance Cell (ITFC), headquartered in Baghdad with liaison officers spread throughout Iraq, was the perfect example of an interagency effort that works. It became a key component of interagency and Multinational Force-Iraq efforts to detect, identify, and disrupt financial networks supporting insurgent and terrorist elements oper­ating in Iraq with its collection, analysis and dissemination of timely financial intelligence on the Iraqi insurgency.[38]

The Afghan Threat Finance Cell builds on the demonstrated success of the ITFC.[39] The ATFC is headquartered in Kabul with similar liaison officers across Afghanistan.[40] The ATFC is comprised of about 30 specialists on loan from the Department of Drug Enforcement, the Department of Treasury, the Department of Justice, the Department of De­fense’s Central Command, the CIA, and the FBI, who try to identify and disrupt sources Taliban funding. They are the ex­perts in interdicting Taliban and Al-Qaeda related funding.[41] The ATFC proceeds “along three general lines of operation in Afghanistan: conducting criminal investigations of high-level narcotics trafficking, implementing intelligence-driven drug flow attack strategy, and participating with the interagency community to develop Afghan capacity.”[42]

International governments, multilateral organizations, and large financial institutions have a critical role to play in set­ting conditions to prevent criminal organizations and other threats from exploiting access to the international financial system. Apart from pursuing close coordination with allied countries that are home to major financial hubs, as well as with international organizations like the Financial Action Task Force (FATF), the United States must also enable partner governments in protecting their vulnerable financial institu­tions against fraud and crime. [43]

Specifically, the U.S. Geographic Combatant Commanders are required to establish a CTF capability that “integrates intelligence and operations; supports interagency partner threat finance efforts in the region as it relates to combating terrorists, insurgents, and narcotics and criminal networks to diminish their operational capabilities; and coordinates and collaborates with the interagency in establishing mecha­nisms with other nations to deny, disrupt or defeat funding and value transfer items to adversaries.”[44]

The challenge for this mission and future interagency con­structs will be the shift from a carte blanche mission and operating environment in a combat zone, to a more con­strained and limiting situation working through a host nation and under the control of the U.S. Embassy country team.

Measuring success

Even as the United States appears in recent years to have ex­panded its ability to disrupt the financial activities of transna­tional criminal networks, narcotics trafficking organizations, and terrorist groups, questions often arise about the systemic impact these efforts have achieved in the case of networks targeted. In short, do government officials understand the scope and nature of the threats faced with sufficient accu­racy so as to measure success in countering them? Many in the counter-threat finance community acknowledge that this is not yet the case. [45]

In order for the United States to evaluate its impact against individual and convergent networks, analysts involved in counter-threat finance missions must first achieve a funda­mental and comprehensive understanding of the how the net­works operate, how they have evolved, and how they adapt when challenged. Only a thorough initial assessment of a network’s normal operating capacity will enable an accurate subsequent determination of whether it has been disrupted or degraded. This daunting but essential analytic task has significant implications for the tools, methodologies, person­nel, and resources dedicated within government agencies to counter-threat finance missions.[46]

More importantly, some consideration must be given to whether the effectiveness of measures against terrorist fi­nancing can be judged. Currently, it remains largely a matter of faith in assertions by those in authority rather than on pub­lished evidence that anti-terror financial intelligence efforts have some impact beyond the immediate operational out­comes. Financial intelligence efforts have had little discernible impact on reducing levels of terrorism or on criminal convic­tions. Lack of open-source research into investigation out­puts does not permit validated claims either of effectiveness or of ineffectiveness. However the poor state of process and outcome data or even of collected case studies suggests low accountability and analytical interest.[47]

A thoughtful review by Bell argues that while cash forfeiture at entry and exit points may be worthwhile as a disruptive strategy, “it has little long-term value unless the cash can be tracked back to its origin and becomes useful in detecting a terrorist or criminal funding source and those who rely upon it.” [48] Therefore, this domain of measuring success is the most immature and least developed dimension of CTF activities.

Measurement deficiencies also reflect the complexity of what one author classifies as multifunctional operations, which in­clude CTF. The most important characteristic of multifunc­tional operations is that they significantly differ from tradi­tional military operations in that the military component is only one of several components that work simultaneously to achieve a comprehensive objective. The challenges for mili­tary organizations with regard to evaluation in these activities are extensive. A large part of these challenges are internal to military organizations and derive from their propensity for task-oriented evaluations, reductionist interpretations of the operational environment, poor documentation of operational designs and the use of junk arithmetic.[49]

Conclusion

While the goal of counter threat finance is to attack the finan­cial underpinnings of the top transnational criminals and ter­rorists, [50] the actual reality of doing so is daunting. Like trying to grasp an eel in water, the responsible agencies struggle to achieve a firm grip. Richard Gordon posited that the current system designed to prevent money laundering and terrorism financing does not work well. It is based on a faulty theoreti­cal construction. The FATF Recommendations require financial institutions to design and implement requirements to moni­tor client transactions and report those that raise suspicion of money laundering or terrorism financing. [51]

These problems can be addressed by turning all analytical work to public sector financial intelligence units and reserv­ing for the private sector only the reporting of certain client profiling data and records of all financial transactions. Finan­cial intelligence should be required to use, to the extent pos­sible, empirical analysis, where results should be far better than the current system. While such a system would be sub­stantially different from the current one, there is considera­ble precedent found in the way in which tax administrations select taxpayers for audit investigations. [52]

For the terrorist side, the best that can probably be achieved by “follow-the-money” methods in countering threat finance is some intelligence that allows for interventions to make ar­rests, build up a broader picture of linkages, permit physi­cal observations, and prevent individuals and groups from obtaining the funds for particular projects beyond the trivial amounts needed for suicide bombings at the local level. [53] For criminals, money that is seized deprives the criminal or­ganizations of the final payoff for their activities, and hurts them more than interdicting their drugs or other products. Targeting cash remains one of the most effective ways of sig­nificantly hurting criminal organizations, so creative and flex­ible approaches to doing so are imperative.[54]

Despite the challenges, a few areas for future research and then operational application would be to develop interagency models and organizations that can work effectively in a part­ner country within the constraints of a peacetime environ­ment; to organize real experts in methodology, assessment, and measurement to identify metrics that can show CTF courses of action that are effective and less effective and to assign resources accordingly; to apply more rigorous empiri­cal analysis on trends, patterns, and networks; and poten­tially reallocate national security assets to focus on criminal threat finance operations given the large differences in cash flow magnitude and potential visibility when compared to ter­rorist threat finance. With such measures, the generic threat financier could then be caught in a tighter interagency net that does not allow an eel-like escape.

Notes:

[1] Danielle Camner Lindholm and Celina Realuyo, “Threat Finance: A Critical Enabler for Illicit Networks,” in Illicit Networks and National Security in the Age of Globalization, eds. Michael Miklaucic and Jacqueline Brewer (Washington, DC: NDU Press, 2012).

[2] Sidney Weintraub, “Disrupting the Financing of Terrorism,” Washington Quarterly 25.1, 2002, 53–60.

[3] See Douglas Farah. “Money Laundering and Bulk Cash Smuggling: Challenges for the Merida Initiative,” Working Paper Series on US-Mexico Security Cooperation (Washington, DC: Woodrow Wilson Center for Scholars, 2010).

[4] Kevin D. Stringer, "Tackling Threat Finance: A Labor for Hercules or Sisyphus?" Parameters 41, no. 1 (Spring 2011), 101–119.

[5] See for example Danielle Camner Lindholm and Celina Realuyo, “Threat Finance: A Critical Enabler for Illicit Networks,” in Illicit Networks and National Security in the Age of Globalization, eds. Michael Miklaucic and Jacqueline Brewer (Washington, DC: NDU Press, 2012).

[6] Deputy Secretary of Defense, Directive-Type Memorandum (DTM) 08-034, DoD counterthreat finance (CTF) Policy (December 2, 2008).

[7] Acting Deputy Assistant Secretary of Defense for Special Operations and Combating Terrorism James Q. Roberts, Statement on Terrorist and Insurgent Financing, House Armed Services Committee, Subcommit­tee on Terrorism, Unconventional Threats, and Capabilities and House Financial Services Subcommittee on Oversight and Investigations, 28 July 2005, http://www.dod.mil/dodgc/olc/docs/Test05-07-28Rob­erts.doc ( accessed October 18, 2010); Thomas W. O’ Connell, ASD/SOLIC, Defense Perspectives: The War on Terrorism, PowerPoint Pre­sentation, 2006, http://www.dtic.mil/ndia/2006solic/oconnel.pdf (ac­cessed October 18, 2010).

[8] Major Clarence W. Bowman III. Countering Threat Finance as a Critical Subset of Irregular Warfare: An Interpretive Case Study of Northern Nigeria (Ft. Leavenworth, KS: United States Command and General Staff College, 2009).

[9] See Danielle Camner Lindholm and Celina Realuyo, “Threat Finance: A Critical Enabler for Illicit Networks,” in Illicit Networks and Na­tional Security in the Age of Globalization, eds. Michael Miklaucic and Jacqueline Brewer (Washington, DC: NDU Press, 2012); Kevin D. Stringer, "Tackling Threat Finance: A Labor for Hercules or Sisyphus?" Parameters 41, no. 1 (Spring 2011), 101–119; and Model legisla­tion on money laundering and financing of terrorism. (Vienna: United Nations Office on Drugs and Crime (UNODC) and the International Monetary Fund (IMF), 2005).

[10] Kevin D. Stringer, "Tackling Threat Finance: A Labor for Hercules or Sisyphus?" Parameters 41, no. 1 (Spring 2011), 101–119.

[11] Model legislation on money laundering and financing of terrorism (Vienna: United Nations Office on Drugs and Crime (UNODC) and the International Monetary Fund (IMF), 2005).

[12] See for example Switzerland and the Fight Against Money Laundering (Basel: Swiss Bankers Association, 2001); author has private copies of the original internal documents from several banks in the Wolfsberg Group; and Article 305bis of the Swiss Criminal Code, 21 Decem­ber 1937, status as of 1 January 2010, http://www.admin.ch/ch/e/rs/3/311.0.en.pdf (accessed November 10, 2010).

[13] Jahangir Arasli, “The Rising Wind: Is the Caucasus Emerging as a Hub for Terrorism, Smuggling, and Trafficking?” Connections: The Quarterly Journal 6, no. 1 (Spring 2007): 5–26.

[14] Laura K. Donohue, “Anti-Terrorist Finance in the United Kingdom and United States,” Michigan Journal of International Law 27, no. 2 (Winter 2006): 396.

[15] Kevin D. Stringer, "Tackling Threat Finance: A Labor for Hercules or Sisyphus?" Parameters 41, no. 1 (Spring 2011), 101–119.

[16] Finance and Money Laundering of terrorism, Powerpoint presenta­tion, University of Western Ontario, n.d., at http://instruct.uwo.ca/economics/164b-570/Assignment%20Samples/Money%20Lauder­ing%20and%20Terrorism.ppt#256,1,Financing and Money Launde­ring of Terrorism, accessed April 12, 2013.

[17] U.S. Strategy to Combat Transnational Organized Crime 2011 (Washington, DC: White House, July 2011), 8.

[18] See Colleen W. Cook, Mexico’s Drug Cartels, Washington, D.C.: Con­gressional Research Service, Library of Congress, RL34215, October 16, 2007 and Peter Chalk. The Latin American Drug Trade: Scope, Dimen­sions, Impact, and Response (Santa Monica, CA: RAND, 2011,) 56–57.

[19] Estimating Illicit Financial Flows Resulting from Drug Trafficking and other Transnational Organized Crimes, Research Report (Vienna: United Nations Office on Drugs and Crime, October 2011).

[20] Kathryn L. Gardner, “Fighting Terrorism the FATF Way,” Global Gover­nance 13, No. 3 (July-September 2007), 325–345.

[21] Estimating Illicit Financial Flows Resulting from Drug Trafficking and other Transnational Organized Crimes, Research Report (Vienna: United Nations Office on Drugs and Crime, October 2011).

[22] U.S. Strategy to Combat Transnational Organized Crime 2011 (Washington, DC: White House, July 2011),19.

[23] U.S. Strategy to Combat Transnational Organized Crime 2011 (Washington, DC: White House, July 2011),19.

[24] US Department of Justice National Drug Intelligence Center. National Drug Threat Assessment 2011 (Johnstown, PA: National Drug Intelli­gence Center, 2011).

[25] Uniting and Strengthening America by Providing Appropriate Tools Re­quired to Intercept and Obstruct Terrorism (USA PATRIOT Act) Act of 2001, Title III, § 302(a)(1), Public Law 107-56, 107th Congress; H.C. 978-1, Table 1:18. Select Committee on Northern Ireland Affairs, The Financing of Terrorism in Northern Ireland, Fourth Report of Session 2001–2.

[26] Kathryn L. Gardner, “Fighting Terrorism the FATF Way,” Global Gover­nance 13, No. 3 (July-September 2007), 325–345.

[27] Thomas J. Biersteker, Proprietary Research Report, Table of Results, 2013, and HM Treasury. Public consultation: draft terrorist asset-free­zing bill (London: The Controller of Her Majesty’s Stationery Office, 2010), 5.

[28] Thomas J Biersteker and Sue E. Eckert. Countering the Financing of Terrorism (London: Routledge, 2008).

[29] Thomas J. Biersteker, Proprietary Research Report, Table of Results, 2013.

[30] Matthew Levitt, “Terror Finance: The Imperative of Interagency Synergy,” Testimony before the House Committee on Armed Services Subcom­mittee on Terrorism and Unconventional Threats and Capabilities, March 11, 2009.

[31] Jennifer E. Carter. Emerging DoD Role in the Interagency Counter Threat Finance Mission: Strategy Research Project (Carlisle, PA: US Army War College, 2012).

[32] Roth, J., Greenburg, D. and Wille, S. (2004) Monograph on Terrorist Financing, Staff Report to the Commission, Washington, DC: National Commission on Terrorist Attacks Upon the United States, http://www.9-11commission.gov/staff_statements/911_TerrFin_Monograph.pdf.

[33] Thomas J. Biersteker, Trends in Terrorist Financing – A Review of the Literature, Report Prepared for Booz, Allen, & Hamilton Consultants, Washington, DC, August 2011.

[34] Thomas J. Biersteker, Trends in Terrorist Financing – A Review of the Literature, Report Prepared for Booz, Allen, & Hamilton Consultants, Washington, DC, August 2011.

[35] See Thomas J. Biersteker, Sources of Terrorist Financing: Placing Charities Diversion in Perspective, Report prepared for the Islamic Charities Project, Centre on Development, Conflict, and Peacebuilding, The Graduate Institute, Geneva, July 2011.

[36] Knowlton Project Analysis Memo: Challenges and Opportunities in Countering Threat Finance (Praescient Analytics, Alexandria VA, October 2012).

[37] J. Edward Conway, “Analysis in Combat: The Deployed Threat Finance Analyst,” Small Wars Journal, July 5, 2012, at http://smallwarsjournal.com/jrnl/art/analysis-in-combat-the-deployed-threat-finance-analyst, accessed April 17, 2013.

[38] Matthew Levitt, “Terror Finance: The Imperative of Interagency Synergy,” Testimony before the House Committee on Armed Services Subcom­mittee on Terrorism and Unconventional Threats and Capabilities, March 11, 2009.

[39] Matthew Levitt, “Terror Finance: The Imperative of Interagency Synergy,” Testimony before the House Committee on Armed Services Subcom­mittee on Terrorism and Unconventional Threats and Capabilities, March 11, 2009.

[40] J. Edward Conway, “Analysis in Combat: The Deployed Threat Finance Analyst,” Small Wars Journal, July 5, 2012, at http://smallwarsjournal.com/jrnl/art/analysis-in-combat-the-deployed-threat-finance-analyst, accessed April 17, 2013.

[41] Mark Thompson, “Afghanistan: A Bleak Report from the Front,” Time, April 2, 2012 at http://nation.time.com/2012/04/02/afghanistan-a-bleak-report-from-the-front/#ixzz2QkC5wqHj, accessed April 17, 2013.

[42] Thomas A. Schrettner and Travis W. Norvell, “DEA in Afghanistan, Understanding and Utilizing a Unique Asset,” Marine Corps Gazette (March 2010).

[43] Knowlton Project Analysis Memo: Challenges and Opportunities in Countering Threat Finance (Praescient Analytics, Alexandria VA, October 2012).

[44] Department of Defense, DoD Counter Threat Finance (CTF) Policy, DoD Directive 5205.14 (Washington DC: Department of Defense, August 19, 2010), Enclose 2, 7-8.

[45] Knowlton Project Analysis Memo: Challenges and Opportunities in Countering Threat Finance (Praescient Analytics, Alexandria VA, October 2012).

[46] Knowlton Project Analysis Memo: Challenges and Opportunities in Countering Threat Finance (Praescient Analytics, Alexandria VA, October 2012).

[47] Michael Levi, "Combating the Financing of Terrorism." British Journal of Criminology 50, no. 4, 2010, 650–669.

[48] E. Bell, “The Confiscation, Forfeiture and Disruption of Terrorist Finan­ces,” Journal of Money Laundering Control, 7 (2), 2003, 105–125.

[49] See David Harriman, “Monitoring and evaluation in Multifunctional operations: A critical examination of key challenges for military or­ganizations in measuring what matters,” Baltic Security and Defence Review, Vol. 14, Issue 2, 2012, 77–101.

[50] U.S. Strategy to Combat Transnational Organized Crime 2011 (Washing­ton, DC: White House, July 2011), 14.

[51] Richard K. Gordon, “Losing the war against Dirty Money: Rethinking Global Standards on Preventing Money Laundering and Terrorism Financing,” 21 Duke Journal of Comparative and International Law, Vol. 21, Spring 2011, 503–565.

[52] Richard K. Gordon, “Losing the war against Dirty Money: Rethinking Global Standards on Preventing Money Laundering and Terrorism Financing,” 21 Duke Journal of Comparative and International Law, Vol 21, Spring 2011, 503–565.

[53] Michael Levi, "Combating the Financing of Terrorism." British Journal of Criminology 50, no. 4, 2010, 650–669.

[54] See Douglas Farah. “Money Laundering and Bulk Cash Smuggling: Challenges for the Merida Initiative,” Working Paper Series on US-Mexico Security Cooperation (Washington, DC: Woodrow Wilson Center for Scholars, 2010).