Joint Enquiry into Intelligence Community Activities Part One Section III C part 2

10. Finding
Serious problems in information sharing also persisted, prior to September 11, between the Intelligence Community and relevant non-Intelligence Community agencies. This included other federal agencies as well as state and local authorities. This lack of communication and collaboration deprived those other entities, as well as the Intelligence Community, of access to potentially valuable information in the “war” against Bin Ladin. The Inquiry’s focus on the Intelligence Community limited the extent to which it explored these issues, and this is an area that should be reviewed further. Discussion: This Inquiry confirmed that, prior to September 11, problems in information sharing reached beyond the boundaries of the Intelligence Community to encumber the flow of information to and from various other entities. At each level, communications with potentially valuable partners in the war against terrorism – other TOP SECRET 84 TOP SECRET federal agencies, state and local authorities -- were restricted. Witnesses testified that these restrictions on information flow occurred at great cost to the counterterrorism effort. Officials in the Departments of Treasury, Transportation, and State told the Joint Inquiry that, although they receive threat information from the Intelligence Community, they do not always receive the information that adds context to the threat warnings. In many instances, officials told the Joint Inquiry, this lack of context prevents them from properly estimating the value of the threat information and taking preventive actions. The Joint Inquiry was also told that not all threat information in the possession of the Intelligence Community is shared with non-Intelligence Community entities that need it the most in order to counter the threats. For example, DCI Tenet testified that: “The documents we’ve provided show some 12 reports spread over seven years which pertain to possible use of aircraft as terrorist weapons. We disseminated those reports to the appropriate agencies, such as the [page 90] FAA, the Department of Transportation and the FBI as they came in.” Subsequently, the Transportation Security Intelligence Service (TSIS) -- which formerly was the Intelligence Office at FAA -- researched the 12 reports mentioned by DCI Tenet to determine what actions had been taken as a result. TSIS reported to the Joint Inquiry that it had no record of having received three of those reports, two others had been derived from State Department cables, and one report was not received at all by FAA until after September 11, 2001. A TSIS official also testified that, despite its clear relevance to civil aviation, the FAA was not provided a copy of the FBI's July 1, 2001 Phoenix communication until its existence was made known to officials there by the Joint Inquiry in early 2002. In a similar vein, the FAA had certain intelligence information in its possession prior to September 11 regarding the terrorist who was apprehended on his way from Canada to the Los Angeles Airport at the time of the Millennium. It also had conducted a detailed analysis of the bomb materials that were seized with him, and connected them to the Bojinka Plot to blow up commercial airliners over the Pacific that had been discovered in the Philippines in 1995. In testimony to the Joint Inquiry, a TSIS official TOP SECRET 85 TOP SECRET indicated uncertainty regarding whether or not these findings had been formally communicated to the CIA. The CIA and NSA had sufficient information available concerning future hijackers al-Mihdhar and al-Hazmi to connect them to Usama Bin Ladin, the East Africa embassy bombings, and the USS Cole attack by late 2000, and there were at least three different occasions when these individuals should have been placed on the State Department’s TIPOFF watchlist and the INS and Customs watchlists. Nonetheless, this was not done, nor was the FBI notified of their potential presence in the United States until late August 2001. The CIA also did not provide the Department of State with almost 1500 terrorismrelated intelligence reports until shortly after September 11, 2001. These reports led to the addition of almost 60 names of terrorist suspects to the State watchlist. Also, due to a [page 91] lack of awareness of watchlisting policies and procedures among CIA personnel before September 11, this information was not provided to the watchlists at INS, and Customs. Intelligence officers at the Departments of Energy and Transportation also did not have access to FBI data, CIA reports, and names on the watchlists. The FBI did not advise the Department of State’s Diplomatic Security Service of the reasons for its inquiries regarding al-Mihdhar and al-Hazmi’s visa information in August 2001 when it was engaged in efforts to find the two individuals in the United States. Neither was INS asked by the FBI to use means available to it, including a search of the Law Enforcement Support Center’s database, to locate al-Mihdhar and al-Hazmi when the FBI was looking for them in the United States in August 2001. INS and FAA officials who testified at the Joint Inquiry’s October 1, 2002 hearing asserted that their agencies might have been able to assist the FBI in locating the two if the FBI had told them of the purpose and importance of the search. Officials from the Departments of Transportation, State, Energy, Defense, and Treasury stated to the Joint Inquiry that, unless information is shared by the Intelligence Community on a timely basis, they are unable to include dangerous individuals on various watchlists to either deny them entry into the United States or apprehend them in TOP SECRET 86 TOP SECRET the United States. The Transportation Security Administration Assistant Under Secretary of Intelligence testified that, had he received the July 2001 FBI Phoenix field office agent’s Electronic Communication, for example, he would have “…started to ask a lot more probing questions of the FBI as to what this was all about…what connections these people may have had to flight schools, by going back to the Airmen Registry in Oklahoma City that is maintained by the FAA to try to identify additional people.” The INS also was not privy to the presence of two known terrorists inside the United States. The INS Deputy Executive Associate Commissioner testified to the Joint Inquiry hearing on October 1, 2002 that “there is a likelihood” that INS agents would have been able to stop al-Mihdhar and al-Hazmi in August 2001. The INS Law Enforcement Support Center (LESC) has been in operation for more than ten years. It is [page 92] capable of querying every INS database and is available on a 24 hour per day, seven-day per week basis. The LESC reportedly can provide information in about seven minutes on the legal status of individuals in the United States. In their testimony before the Joint Inquiry hearing, state and local government witnesses were adamant about the necessity of the intelligence and law enforcement agencies sharing terrorist information with state and local authorities. Former Virginia Governor James Gilmore stated that, in his entire four-year term, he never received any intelligence or law enforcement information regarding terrorists. Governor Gilmore also testified that: . . . to the extent that there has been intelligence sharing, it has been ad hoc. It has been without a real systematic approach. And what would you expect. With the Intelligence Comnunity, it is not within the culture if not within the statute that you don't share information. If you do, you are even subject to criminal penalties not to mention the danger of sharing information and to the danger of people who provide it. And the capacities of the United States in order to gather it. In addition, he explained that he was not even given a security clearance while he was Governor that would have allowed him to be briefed on possible terrorist plots. The Police Commissioner of Baltimore stated at the same hearing that he does not receive intelligence information about suspected terrorists living in his jurisdiction even TOP SECRET 87 TOP SECRET though some may have been associated with the September 11 hijackers. He also cited the fact that there are 650,000 law enforcement officers nationwide and they should be viewed by the federal intelligence and law enforcement agencies as force-multipliers. However, this can only happen if information flows in both directions. The Police Commissioner also testified that, domestically, the local police force is the “biggest collector” of information, not the federal government. To illustrate his point that information must flow in both directions, he added, “we can tell when people move from one cave to another in Afghanistan, but we can’t tell when they move from one row house to another in Baltimore.” By contrast, former FBI Director Louis Freeh testified that information sharing with federal, state and local authorities was a priority for the FBI. In his Joint Inquiry testimony on October 8, 2002, he said: [page 93] We doubled and tripled the number of Joint Terrorism Task Forces [JTTFs] around the United States so we could multiply our forces and coordinate intelligence and counterterrorism operations with the FBI's federal, state, and local law enforcement partners. Thirty-four of these JTTFs were in operation by 2001. . . . We were also tasked to set up the National Domestic Preparedness Office to counter terrorist threats and to enhance homeland security. Mr. Freeh added that counterterrorism was such a high priority that the FBI instituted a national threat warning system in order to disseminate terrorism related information to state and local authorities around the country and organized national, regional and local practice exercises to help the country prepare for terrorist attacks. Further, FBI Director Mueller explained in his October 17, 2002 testimony before the Joint Inquiry the changes that had been made in this regard by the FBI since September 11, and added that: As a result of these initiatives and despite some of the testimony that this [Inquiry] has heard, we have received numerous letters of support and gratitude from state and local officials and most particularly from the International Association of Chiefs of Police [IACP]. . . . Our agents must work closely with our local and state law enforcement partners. . . . I don't believe that [the testimony of the Baltimore Police Commissioner] is representative of the feeling in the field. Does his testimony surprise me? I would say probably not. But I will tell you every time that I have. . . TOP SECRET 88 TOP SECRET .seen, either publicly or in testimony before this committee or another committee, that there is a police chief who is not getting what he or she wants, I have called, picked up the phone and called them to try to address those concerns. . . . . [A] letter from William Berger, the President of the IACP. . . . praises us for the changes we have made to address this particular problem. I will just read one paragraph: It is my belief that the steps you have taken have been very responsive to these concerns and clearly demonstrate the FBI's commitment to enhancing its relationship with State and local law enforcement in improving our ability to combat not only terrorism, but all crime. I was at the IACP two weeks ago. I talked to the hierarchy, and I believe that they are supportive. There are isolated individuals throughout the United States who do not believe we are doing enough, and there are areas where we still have a ways to go, getting clearances for chiefs of police, exchange of information all the [page 94] way down and getting it back up. We have a number of [JTTFs] that are working exceptionally well around the country. I think if you went to 9 or 10, or 99 out of 100, or 55 out of 56 you will find that State and local police are very supportive of the relationship. There will always be one, there will always be two, and we try to address them as we come along. Following the events of September 11, 2001, the IACP President did indeed write to FBI Director Mueller to express his appreciation for the steps the FBI has taken, including the creation of the State and Local Law Enforcement Advisory Panel and the Office of Law Enforcement Coordination. Subsequently, however, the IACP President was quoted on September 19, 2002 that: [Federal communications with state and local police] didn’t work again…Most local police in New England were informed by the FBI office in that area…about an hour before the public, but police in other regions didn’t know about the change until Attorney General John Ashcroft and Homeland Security Director Tom Ridge announced it at a press conference. The Inquiry found that the FBI’s establishment of JTTFs in many FBI field offices had begun to correct some information sharing problems by encouraging coordination between federal, state, and local agencies prior to September 11. These efforts did result in some successes. For example, in the Moussaoui investigation, the INS representative on the Minneapolis JTTF was able to use the INS database to TOP SECRET 89 TOP SECRET determine Moussaoui’s immigration status quickly. The INS and FBI representatives then approached Moussaoui together and he was taken into INS custody at an INS facility and questioned by the FBI. However, a variety of shortcomings in the JTTF program limited its effectiveness prior to September 11. First, not all of the FBI field office had JTTFs. Further, some of the JTTFs were hampered by a lack of analytic personnel, limited participation by local law enforcement organizations, incomplete access to information by some of the participants, and the absence of CIA detailees. Prior to September 11, only 35 FBI field offices had JTTFs and only six JTTFs had CIA representatives. This might help explain why [page 95] the CIA did not receive a copy of the July 2001 Phoenix communication until well after September 11. The Gilmore Advisory Panel reported anecdotal evidence suggesting that the JTTF and other similar efforts, while well intentioned, continue to be confusing, duplicative, non-routine, and bifurcated in both structure and implementation.

11. Finding
Prior to September 11, 2001, the Intelligence Community did not effectively develop and use human sources to penetrate the al-Qa’ida inner circle. This lack of reliable and knowledgeable human sources significantly limited the Community’s ability to acquire intelligence that could be acted upon before the September 11 attacks. In part, at least, the lack of unilateral (i.e., U.S. –recruited) counterterrorism sources was a product of an excessive reliance on foreign liaison services. Discussion: The U.S. Intelligence Community was not able to penetrate al- Qa’ida’s inner circle successfully before September 11, despite the fact that human penetration of that organization was considered a priority. Richard Clarke, the former National Counterterrorism Coordinator, described the problem as well as the impact that it had on policymakers: [It was not until 1999 that the Counterterrorism Center began to have some success in developing penetrations of al-Qa’ida. A new Director. . .took over the Counterterrorism Center and was instructed by George Tenet to get human penetrations of al-Qa’ida, and they did have some success in the succeeding years, although none of them very high level. TOP SECRET 90 TOP SECRET . . . . . . . . [ ] never had anyone in position to tell us what was going to happen in advance, or even where Bin Ladin was going to be in advance [ ] we never knew where he was going to be in advance, And usually we were only informed about his – where he was after the fact. . . . And [ ] where they were able to tell us where they thought he was at the moment, [ ] the CIA itself recommended against action, because they said their sources were not very good, or not good enough to recommend military action]. [Page 96] Former Director Louis Freeh emphasized the critical difference that human sources and adequate “infiltration” of terrorist organizations could have made in the context of the September 11 attacks: If one of those 19 hijackers had spoken – maybe they did, maybe we don’t know about it yet – incautiously or imprudently to someone in some place where that information could have been captured, we could have had a day of terror prevented instead of September 11th. There’s all kinds of possibilities there. So, infiltration. We need to have our agents sitting around wherever they were sitting around in Hamburg and the U.A.E. and other places, as well as in the caves over in Afghanistan so we can know what is going on. [Lacking access to senior, high level al-Qa’ida leadership, the Community relied on secondhand, fragmented and often questionable human intelligence information, a great deal of which was obtained from volunteers or sources obtained through the efforts of foreign liaison]. [According to senior CTC officials, CIA had no penetrations of al-Qa’ida’s leadership and never obtained intelligence that was sufficient for action against Usama Bin Ladin from anyone. A large number of current and former CTC officers indicated that CTC had numerous unilateral sources outside the leadership who were reporting on al-Qa’ida, and a larger number who were being developed for recruitment, prior to September 11. The best source was handled jointly by CIA and the FBI. In addition, CIA managed a network of [ ] in Afghanistan that often reported information regarding Bin Ladin issues and relations with the Taliban. They occasionally provided threat information as well, but had no access to al-Qa’ida’s leadership]. TOP SECRET 91 TOP SECRET [Especially after the East Africa U.S. embassy bombings in 1998, CIA also tried many avenues in an effort to obtain access to Bin Ladin and his inner circle. [ ] [page 97] [ ]. Despite these creative attempts, according to former senior officials of CTC, CIA had no penetrations of al-Qa’ida’s leadership, and the Agency never acquired intelligence from anyone that could be acted upon, prior to September 11]. [Numerous sources were being handled by foreign intelligence services. Most disruptions of al-Qa’ida activities abroad before September 11 were the result of joint initiatives with foreign governments. However, relying on foreign services [ ] meant that very little counterterrorism intelligence was obtained by CIA in some parts of the world [ ]. [There was a surge in volunteer sources after the 1998 East African embassy bombings, another surge on the anniversary of those bombings in 1999, and a third after the December 1999 disruption of the Jordanian Millennium plot. [ ]. One of these was very good and provided information that was used to thwart attacks on U.S. interests in Europe. Several of these volunteers continue to act as CIA sources. [ ]. The negative considerations were that most volunteer information was considered bogus by CTC, some volunteers were suspected of being al-Qa’ida provocations, and some were believed to have cooperated with terrorist groups]. TOP SECRET 92 TOP SECRET The inability to develop reliable human sources effectively stemmed, in part, from the difficult nature of the target. Members of Usama Bin Ladin’s inner circle have close bonds established by kinship, wartime experience, and long-term association. [Page 99] Information about major terrorist plots was not widely shared within al-Qa’ida, and many of Bin Ladin’s closest associates lived in war-torn Afghanistan. The United States had no official presence in that country and did not formally recognize the Taliban regime, which viewed foreigners with suspicion. Pakistan is the principal access point to southern Afghanistan, where al-Qa’ida was particularly active, but U.S.-Pakistani relations were strained by Pakistani nuclear tests in 1998 and a military coup in 1999. While attempts to penetrate al-Qa’ida cells outside Afghanistan may have presented fewer obstacles, other factors limited CIA efforts to do so. [ ]. This meant as a practical matter that CIA did not focus as heavily as would otherwise have been the case on recruiting human sources of counterterrorism intelligence in other locations such as [ ]. CTC personnel said they did not view guidelines issued by former DCI John Deutch in 1996 concerning CIA recruitment of human sources with poor human rights records as an impediment to the pursuit of terrorist recruitments in al-Qa’ida, and none of the CTC officers interviewed by the Joint Inquiry attributed the lack of penetration of the al-Qa’ida inner circle to the Deutch guidelines. In fact, the effort to recruit such penetrations became increasingly aggressive with respect to Bin Ladin's network beginning in 1999. These responses should be balanced against the examination of the effect of the Deutch guidelines that was conducted by the House Permanent Select Committee on Intelligence (HPSCI) Subcommittee on Terrorism and Homeland Security. Its July 2002 report stated in this regard: [page 99] TOP SECRET 93 TOP SECRET . . . Many CIA managers at headquarters posited that the guidelines did not present a problem and that no extra labor [was] required on the part of field officers as a result of the guidelines. Many others, including CIA officers in the field who brought their concerns to the attention of HPSCI members and staff, had a different view. . . . Their concerns were not that waivers were denied, but that they were not career enhancing and that the process by which requests were brought forward was cumbersome and resulted in disincentive to work to recruit anyone who might have been involved in proscribed acts. . . . Prior to September 11, the FBI also attempted, but with only limited success, to develop human sources regarding the activities of al-Qa’ida and other terrorist groups within the United States. Again, the difficult nature of the target, as well as FBI and Department of Justice policies and practices, may have hampered the FBI’s coverage of the radical fundamentalist community in this country. Recruiting sources in fundamentalist communities within the United States may have been more difficult than such recruitments abroad. The FBI advised the Joint Inquiry that, for example, only 21 FBI agents possess the Arabic language skills that would be expected to be important in pursuing such recruitments. However, even those FBI agents who were skilled at developing such sources faced a number of difficulties that may have hampered the FBI’s ability to gather intelligence on terrorist activities in the United States. According to several FBI agents, for example, FBI Headquarters and field managers were often unwilling to approve potentially controversial activity involving human sources who were in a position to provide counterterrorism intelligence. The 1996 Antiterrorism and Effective Death Penalty Act specifically outlawed providing material support to terrorism. If an FBI source was involved in illegal funding or in terrorist training, the agent responsible for the source had to obtain approval from FBI Headquarters and the Department of Justice to allow the source to engage in the illegal activity. According to FBI personnel, this was a difficult process that sometimes took as long as six months. Because terrorist sources frequently engaged in activity that violated the 1996 Act, the cumbersome approval process often discouraged aggressive recruitment of these sources in the field. [page 100] TOP SECRET 94 TOP SECRET FBI agents also cited to the Joint Inquiry the requirement for prior DCI approval of FBI source travel abroad as a roadblock to sending sources overseas for operational purposes. Several FBI agents expressed the opinion to the Joint Inquiry that the CIA took advantage of this requirement to prevent FBI sources from operating overseas. Another FBI agent complained that FBI Headquarters management did not readily approve overseas travel for sources because of its belief that the FBI should focus on activity within the United States. When FBI management did approve overseas travel for assets, it often declined to allow the responsible agents to accompany the sources during such travel. These decisions, according to FBI agents in Joint Inquiry interviews, significantly diminished the quality of the operations The FBI also apparently did not use those counterterrorism sources that had been identified in the most effective and coordinated manner. The FBI generally focused source reporting on cases and subjects within the jurisdiction of specific field offices and did not adequately use sources to support a national counterterrorism intelligence program. For example, the FBI received intelligence in 1999 that a terrorist organization was planning to send students to the United States for aviation training. While an operational unit at FBI Headquarters instructed twenty-four field offices to “task sources” for information, it appears that no FBI sources were in fact asked about the matter. In addition, when the Phoenix FBI agent reported to FBI Headquarters in July 2001 his concern that Middle Eastern students were coming to the United States for civil aviation-related training, there was no effort by either FBI Headquarters or the field office that was advised of his concern by FBI Headquarters to task counterterrorism sources for any relevant information. Similarly, when Minneapolis FBI field office agents detained Zacarias Moussaoui in August 2001, they were concerned that he might be part of a larger conspiracy. Nonetheless, neither the Minneapolis field office nor FBI Headquarters asked any FBI sources whether they knew anything about Moussaoui or the existence of any larger plot. [Page 101] [Finally, in August 2001, the FBI learned from the CIA that terrorist suspects Nawaf al-Hazmi and Khalid al-Mihdhar were in the United States. Neither the FBI field offices that were involved in the search nor FBI Headquarters thought to ask FBI field TOP SECRET 95 TOP SECRET offices to ask their sources whether they were aware of the whereabouts of the two individuals, who later took part in the September 11 attacks. As one result, the San Diego counterterrorism informant who had numerous contacts with those two individuals during 2000 was never asked to help the FBI locate them in the last weeks before September 11].

12. Finding
During the summer of 2001, when the Intelligence Community was bracing for an imminent al-Qa’ida attack, difficulties with FBI applications for Foreign Intelligence Surveillance Act (FISA) surveillance and the FISA process led to a diminished level of coverage of suspected al-Qa’ida operatives in the United States. The effect of these difficulties was compounded by the perception that spread among FBI personnel at Headquarters and the field offices that the FISA process was lengthy and fraught with peril. Discussion: In the summer of 2000, during preparation for the trial in New York of those involved in the bombing of the U.S. embassies in East Africa, prosecutors discovered factual errors in applications for FISA orders sanctioning electronic surveillance. The FISA Court found that these errors included an erroneous statement that a FISA target was not under criminal investigation, erroneous statements concerning overlapping intelligence and criminal investigations, and unauthorized sharing of FISA information with criminal investigators and prosecutors. The FISA Court also determined that these errors called into question the certifications that had been made by senior officials that the FISA surveillances requested by the applications had as their purpose the gathering of foreign intelligence, rather than criminal-related information, as required by FISA. After being informed of additional errors in subsequent months, the FISA Court barred an FBI agent who had prepared one of the erroneous applications from appearing before the Court again. The FBI and the Department of Justice’s Office of Intelligence Policy and Review (OIPR) began a systematic review of the FISA application process in September 2000 to [page 102] ensure the accuracy of FISA Court filings. Some FISA surveillances targeting al-Qa’ida agents were allowed to expire while OIPR and the FBI investigated how the errors had occurred. These orders were not renewed until after the attack on USS Cole in October 2000. In April 2001, the Bureau promulgated procedures for the review of draft TOP SECRET 96 TOP SECRET FISA declarations and the submission of FISA applications to the Court. OIPR also revised the standard al-Qa’ida FISA application to reduce the amount of extraneous information that was required and that increased the likelihood of factual errors. During this process, many FISA surveillances of suspected al-Qa’ida agents expired because the FBI and OIPR were not willing to apply for application renewals when they were not completely confident of their accuracy. Most of the FISA orders targeting al-Qa’ida that expired after March 2001 were not renewed before September 11. The Joint Inquiry received inconsistent figures regarding the specific number of FISA orders that were allowed to expire during the summer of 2001. One FBI manager stated that no FISA orders targeted against al-Qa’ida existed in 2001, others interviewed said there were up to [ ] al-Qa’ida orders at that time, and an OIPR official explained that approximately two-thirds of the number of FISA orders targeted against al-Qa’ida had expired in 2001. Several organizations played a role in the breakdown of the FISA process in the year before the September 11 attacks. According to FBI personnel, OIPR and the FISA Court erred by requiring much extraneous information in FISA applications, thus increasing the likelihood of mistakes. Bureau agents frequently could not or did not verify the accuracy of information in the FISA applications. The FISA Court’s order prohibiting an FBI agent from appearing before the Court also apparently had a chilling effect on FBI agents, and they became increasingly unwilling to confirm the veracity of FISA applications.

13. Finding
[ [page 103] ]. TOP SECRET 97 TOP SECRET Discussion: [During his tenure, President Clinton signed documents authorizing CIA covert action against Usama Bin Ladin and his principal lieutenants. [ ]. [ ]: • [ ]. • [ ]. [ ] [page 104] [ ]. [Former National Security Advisor Sandy Berger testified to the Joint Inquiry on September 19, 2002 that, from the time of the East Africa U. S. Embassy bombings in 1998, the U. S. Government was: . . . embarked [on] an very intense effort to get Bin Ladin, to get his lieutenants, through both overt and covert means. . . . We were involved – at that point, our intense focus was to get Bin Ladin, to get his key lieutenants. The President conferred a number of authorities on the Intelligence Community for that purpose. TOP SECRET 98 TOP SECRET Senator Shelby: By “get him,” that meant kill him if you had to, capture him or kill him? Mr. Berger: I don’t know what I can say in this hearing, but capture and kill. . . . There was no question that the cruise missiles were not trying to capture him. They were not law enforcement techniques. . . .”] [ ]. [ ].” As former National Security Advisor Berger noted in his Joint Inquiry interview, “We do not have a rogue CIA.” [ ].” In his June 11, 2002 briefing to the Joint Inquiry, Mr. Clarke reiterated this point when he said: [page 105] I think if you look at the 1980s and 1970s, the individuals who held the job of [DDO], one after another of them was either fired or indicted or TOP SECRET 99 TOP SECRET condemned by a Senate committee. I think under those circumstances, if you become Director of Operations, you would want to be a little careful not to launch off on covert operations that will get you personally in trouble and will also hurt the institution. The history of covert operations in the 1950s and 1960s and 1970s was not a happy one, and I think that lesson got over-learned by people who at the time were probably in their twenties and thirties, but by the time they became in their fifties, and they were managers in the [Directorate of Operations], I think that they institutionalized a sense of covert action is risky and is likely to blow up in your face. And the wise guys at the White House who are pushing you to do covert action will be nowhere to be found when the Senate Select Committee on Intelligence calls you up to explain the mess that the covert action became. Mr. Clarke went on to say: “I think it is changed because of 9/11. I think it is changed because George Tenet has been pushing them to change it.” In a July 26, 2002 Joint Inquiry interview, a former Chief of CTC made a similar point when he implicitly acknowledged that he pushed whenever possible for clarity in the covert action authorities [ ].” The policy makers’ reluctance [ ] limited the scope of CIA operations against Bin Ladin. [ ] [Page 106] [ TOP SECRET 100 TOP SECRET ].” [ ]: [ ]. In any event, the differing perceptions about the scope of the authorizations shaped the types of covert action the CIA was willing to direct against Bin Ladin prior to September 11, 2001 and, therefore, its ultimate effectiveness. [ ]. [ ] [Page 107] [ ]. TOP SECRET 101 TOP SECRET The CIA’s actual efforts to carry out covert action against Bin Ladin in Afghanistan prior to September 11, 2001 were limited and do not appear to have significantly hindered al-Qa’ida’s ability to operate. [ ]: • [ ]; • [ ];” • [ ]; • [ ];” [Page 108] • [ TOP SECRET 102 TOP SECRET ]; • [ ]; and, • [ ]. Many of these efforts were key elements in “the Plan” – initially developed in 1999 and subsequently modified -- that the DCI described in his testimony before the Joint Inquiry on October 17, 2002. “The Plan” did not, however, feature elements commonly associated with war plans or contingency plans, such as a mission statement, strategic goals or objectives, a statement of commander’s intent, a delineation of the resources that would be required or are available for the operation, or the measures by which operational success might be measured. Although a covert action plan might not be expected to contain all of the elements of a war plan, the absence of all these elements suggests an absence of rigor in the planning process. [ ] [Page 109] [ ]. The Joint Inquiry heard testimony on September 12 and September 19, 2002 that, between March 2001 and September 2001, the Bush Administration was engaged in a TOP SECRET 103 TOP SECRET review of counterterrorism policy. ]. [ ]. [Deputy Secretary of State Armitage testified that the Bush Administration was considering, among other things, “increased authorities for the Central Intelligence Agency” in the summer of 2001 and was close to final agreement on a more aggressive strategy against Bin Ladin and his followers by September 11, 2001: The National Security Council. . . called for new proposals [in March 2001] on a strategy that would be more aggressive against al-Qa’ida. The first deputies meeting, which is the first decision making body in the administration, met on the 30th of April and set off on a trail of initiatives to include financing, getting at financing, to get at increased authorities for the Central Intelligence Agency, sharp end things that the military was asked to do. . . . So, from March through about August, we were preparing a national security Presidential directive, and it was distributed on August 13 to the principals for their final comments. And then, of course, we had the events of September 11. . . .]

14. Finding
[Senior U.S. military officials were reluctant to use U.S. military assets to conduct offensive counterterrorism efforts in Afghanistan, or to support or participate in CIA operations directed against al-Qa’ida prior to September 11. At least part of this reluctance was driven by the military’s view that the Intelligence Community was unable to provide the intelligence needed to support military operations. Although the U.S. military did participate in [ ] counterterrorism efforts to counter Usama Bin Ladin’s terrorist network prior to September 11, 2001, most of the military’s focus was on force protection]. Discussion: National Security Council officials, CIA officers in the CTC, and senior U.S. military officers differ regarding the U.S. military’s willingness to conduct operations against Usama Bin Ladin prior to September 11, 2001. In general, however, [page 110] these officials indicate that senior military leaders were reluctant to have the military play a major role in offensive counterterrorism operations in Afghanistan prior to September 11: TOP SECRET 104 TOP SECRET • In his June 11, 2002 remarks, former National Coordinator for Counterterrorism Richard Clarke said, “the overwhelming message to the White House from the uniformed military leadership was ‘we don’t want to do this,’ [ ]. Later in that same briefing, he said: “The military repeatedly came back with recommendations that their capability not be utilized [ ] in Afghanistan.” • In a written response to the Joint Inquiry, former National Security Advisor Sandy Berger said: President Clinton’s top military advisers examined [military options]. They advised us that there would be a low probability of success for such operations in Afghanistan (before 9/11 when we did not have the cooperation of Pakistan and other bordering nations) in the absence of substantial lead-time actionable intelligence (i.e., specific advanced knowledge of where bin Ladin would be at a specific time and place). There were many obstacles to deploying ground troops into Afghanistan from staging areas at some distance, including a serious possibility of detection, difficulty of basing back-up forces nearby and logistical difficulties. • Interviews of officials at the CTC and a review of CTC documents support the finding that the military did not seek an active role in offensive counterterrorism operations. For example, ].” In the CTC’s view, although there was “lots of desire at the working level,” there was “reluctance at the political level,” and it was “unlikely that JSOC will ever deploy under current circumstances.” [Page 111] • On September 12, 2002, a former Chief of CTC said: “You know, [the U.S. military] – they have their own views on their willingness to take casualties and take risky operations… For them to go, they are more exacting in their requirements, in terms of intelligence certainly, before they engage.” TOP SECRET 105 TOP SECRET • Another former Chief of CTC testified: Actually it was discussed… turning the ball over to [the military], but having them do it themselves. They declined, as I recall, as best I recall, because they lacked the covert action authorities to work in that environment. Since there wasn’t an official declaration of war, there wasn’t fighting, they didn’t think they had the authorities to go in and do it themselves. They were willing to help… but they couldn’t put boots on the ground themselves. • The former Chairman of the Joint Chiefs of Staff stated that the U.S. military primarily thought about the threat posed by Usama Bin Ladin's network in terms of protecting U.S. forces deployed overseas from terrorist attack. He also stated his belief that the CIA and FBI should have the lead roles in countering terrorism, and that military tools should be viewed as an extension and supplement to the leading roles played by the CIA and FBI. In discussing offensive counterterrorism operations in Afghanistan, the former Chairman cited the lack of actionable intelligence, noting “Look at the risk associated with swooping in.” With regard to using U.S. military forces in clandestine operations, the former Chairman said: “you don’t put U.S. armed forces in another country if the President doesn’t declare war, unless you declare war on the Taliban.” He said he never received a tasker to put boots on the ground to obtain actionable intelligence, noting "the military does what it is told to do." • The Joint Chief of Staff’s Director of Operations indicated that options developed by the military for the White House in 2000 were in part aimed at “educating” the National Security Advisor on the complexities of operations in Afghanistan involving “U.S. boots on the ground.” [Page 112] In Joint Inquiry interviews, senior and retired U.S. military officers cited the lack of precise, actionable intelligence as a primary obstacle to the military conducting its own operations against Bin Ladin. The former Chairman of the Joint Chiefs of Staff stated, for example: “. . . you can develop military operations until hell freezes over, but they are worthless without intelligence.” TOP SECRET 106 TOP SECRET However, according to CIA officers in the CTC who testified before the Joint Inquiry on September 12, 2002, the U.S. military often levied so many requirements for highly detailed, actionable intelligence prior to conducting an operation – far beyond what the Intelligence Community was ever likely to obtain – that U.S. military units were effectively precluded from conducting operations against Bin Ladin’s organization on the ground in Afghanistan or elsewhere prior to September 11. A former Chief of CTC's special Bin Ladin unit said: [the military's] requirements, before they operate, are absolutely impossible for us to collect in most instances. [ ]. And the requirements they sent us included items like, which side of the door are the hinges on, do the windows open out or go up and down. And it is just not the kind of intelligence we can provide on anything resembling a regular basis. The Department of Defense did ask the Defense HUMINT [Human Intelligence] Service to determine whether it could obtain information regarding Bin Ladin’s whereabouts. However, the former Chairman of the Joint Chiefs of Staff indicated that the U.S. military did not undertake any independent efforts, utilizing U.S. military forces, to determine Bin Ladin’s location. Lower-level military officers appeared to be more enthusiastic than senior military officials about active military participation in counterterrorism efforts. Senior CIA officers, CIA documents, and at least one former special operations forces [page 113] commander indicated, in interviews and testimony, that military operators were both capable and interested in conducting a special operations mission against Bin Ladin in Afghanistan prior to September 11. A former JSOC commander told the Joint Inquiry that his units did have the ability to put small teams into Afghanistan. A CIA document commenting on the prospects of Joint Special Operations Command units participating in an operation to capture Bin Ladin said: “lots of desire at the [military] working level,” but there was “reluctance at the political level.” Despite senior officers’ reluctance to play a major role, military personnel and assets did contribute to several counterterrorism efforts in addition to force protection. TOP SECRET 107 TOP SECRET The Joint Inquiry has identified [ ] major types of military participation in, or support for, operations to counter Usama Bin Ladin’s terrorist network prior to September 11: • On August 20, 1998, following the bombings of two U.S. embassies in East Africa, the U.S. military, acting on President Clinton’s orders, launched cruise missiles at Usama Bin Ladin-related targets in Sudan and Afghanistan. One of the objectives of those strikes was to kill Usama Bin Ladin. As former National Security Advisor Sandy Berger testified: “we [were] trying to kill Bin Ladin, we dropped cruise missiles on him;” • Between 1999 and 2001, the U.S. military positioned a number of Navy ships and submarines armed with cruise missiles in the North Arabian Sea to launch additional cruise missile strikes at Bin Ladin in the event the Intelligence Community was able to obtain precise information on his whereabouts in Afghanistan; and • [In 2000 and 2001, the Joint Staff and U.S. Air Force provided technical assistance in the development of the Predator unmanned aerial vehicle as a [Page 114] second source of intelligence on Usama Bin Ladin’s precise whereabouts in Afghanistan. Former National Security Advisor Sandy Berger told the Joint Inquiry that: The Clinton Administration was engaged in an active strategy against Bin Ladin and was continuously examining new initiatives for defeating Bin Ladin and al-Qa’ida, given what was known and the allies available at the time. For example, in 2000, we developed the Predator program, which was successfully tested in late 2000 and was available to be operationalized as a critical intelligence platform to confirm intelligence on his whereabouts when the weather cleared in the Spring of 2001]. In general, however, the CIA and U.S. military did not engage in joint operations, pool their assets, or develop joint plans against Usama Bin Ladin in Afghanistan prior to September 11, 2001 – despite interest in such joint operations at the CIA. Commenting on the idea of the CIA and U.S. military engaging in joint operations, a former Chief of CTC testified: TOP SECRET 108 TOP SECRET I think it is absolutely great [idea]. This is something we have been advocating for a long time. If you want to go to war, you take the CIA, its clandestinity, its authorities, and you match it up with special operations forces of the U.S. military, you can really – you can really do some damage.… This is something that we have tried to advocate at the working level, and we haven’t made much progress. But, if this is something that [the Congress] would like to look into, it would be great for the United States. Similarly, a former Chief of CTC's special Bin Ladin unit said: “As someone who served [ ] and worked with special forces, they want to work with us and we want to work with them. History was made between the CIA and special forces. We need to do that.” However, the former Chairman of the Joint Chiefs of Staff told the Joint Inquiry that he did not believe in joint operations with the CIA. He said, “I want to make sure the military piece of the plan is under military control, and not predicated on the CIA’s piece being successful.”

15. Finding
The Intelligence Community depended heavily on foreign intelligence and law enforcement services for the collection of counterterrorism intelligence and the conduct of other counterterrorism activities. The results were mixed in terms of productive intelligence, reflecting vast differences in the ability and willingness of the various foreign services to target the Bin Ladin and al-Qa’ida network. Intelligence Community agencies sometimes failed to coordinate their relationships with foreign services adequately, either within the Intelligence Community or with broader U.S. Government liaison and foreign policy efforts. This reliance on foreign liaison services also resulted in a lack of focus on the development of unilateral human sources. [Page 115] Discussion: [In the mid-1990s, CIA counterterrorism officials decided that unilateral operations alone were of limited value in penetrating al-Qa’ida and that foreign liaison services could serve as a force multiplier. Foreign intelligence and security services often had excellent local knowledge and capabilities; [ ]. Therefore, CIA, FBI, NSA, and other Intelligence Community agencies strengthened their liaison relationships with existing foreign partners and forged new relationships to fight al-Qa’ida and other radical groups. For example, the CIA [ TOP SECRET 109 TOP SECRET ]. The FBI expanded its Legal Attache (Legat) program]. [Despite those efforts, many weaknesses in foreign liaison relationships were apparent before the September 11 attacks. These weaknesses limited the amount and quality of the counterterrorism intelligence received as a result of those relationships. For example, individuals in some liaison services organization are believed to have cooperated with terrorist groups]. [Regarding Saudi Arabia, former FBI Director Louis Freeh testified that, following the 1996 Khobar Towers bombing, the FBI “was able to forge an effective working relationship with the Saudi police and Interior Ministry.” A considerable amount of personal effort by Director Freeh helped to secure what he described as “unprecedented and invaluable” assistance in the Khobar Towers bombing investigation from the Saudi Ambassador to the United States and the Saudi Interior Minister. By contrast, the Committees heard testimony from U.S. Government personnel that Saudi officials had been uncooperative and often did not act on information implicating Saudi nationals]. [Page 116] [According to a U. S. Government official, it was clear from about 1996 that the Saudi Government would not cooperate with the United States on matters relating to Usama Bin Ladin. [ ], reemphasized the lack of Saudi cooperation and stated that there was little prospect of future cooperation regarding Bin Ladin. [ ] told the Joint Inquiry that he believed the U.S. Government’s hope of eventually obtaining Saudi cooperation was unrealistic because Saudi assistance to the U.S. Government on this matter is contrary to Saudi national interests]. [A U. S. Government official testified to the Joint Inquiry on this issue [ ] as follows: TOP SECRET 110 TOP SECRET [ ]….[F]or the most part it was a very troubled relationship where the Saudis were not providing us quickly or very vigorously with response to it. Sometimes they did, many times they didn’t. It was just very slow in coming. The Treasury Department General Counsel testified at the July 23, 2002 hearing about the lack of Saudi cooperation: There is an almost intuitive sense, however, that things are not being volunteered. So I want to fully inform you about it, that we have to ask and we have to seek and we have to strive. I will give you one-and-a-half examples. The first is, after some period, the Saudis have agreed to the designation of a man named Julaydin, who is notoriously involved in all of this; and his designation will be public within the next 10 days. They came forward to us two weeks ago and said, okay, we think we should go forward with the designation and a freeze order against Mr. Julaydin. We asked, what do you have on him? Because they certainly know what we have on him, because we shared it as we tried to convince them that they ought to join us. The answer back was, nothing new. . . . . . . . I think that taxes credulity, or there is another motive we are not being told. [Page 117] [A number of U. S. Government officials complained to the Joint Inquiry about a lack of Saudi cooperation in terrorism investigations both before and after the September 11 attacks. ]. A high-level U. S. Government officer cited greater Saudi cooperation when asked how the September 11 attacks might have been prevented. In May 2001, the U.S. Government became aware that an individual in Saudi Arabia was in contact with a senior al-Qa’ida operative and was most likely aware of an upcoming al- Qa’ida operation. [ ]. [ TOP SECRET 111 TOP SECRET ]. Several other Arab governments hesitated to share information gleaned from arrests of suspects in the USS Cole bombing and other attacks. Even several European governments were described to the Joint Inquiry as indifferent to the threat al-Qa’ida posed prior to September 11, while others faced legal restrictions that impeded their ability to share intelligence with the United States or to disrupt terrorist cells. Prior to September 11, for example, [ ], despite repeated requests from CIA, [Page 118] provided little helpful information [ ]. A CIA representative described the situation in his testimony before the Joint Inquiry: We had passed [ ] a great number of leads about al-Qa’ida members. We passed [them] a great deal of leads on al-Qa’ida members, including some of the people you see in the press now, like [ ], and we had really given them a lot of names to track after September 11. The arrests they made [after September 11, 2001] showed that they had in fact been following them and monitoring them to some extent. But the CIA did not get information back [ ] on it to any measurable extent that would help us with our efforts. [CIA’s liaison partners vary in competence and commitment. [ ]. However, the Agency still had to rely heavily on liaison partners in several countries in order to acquire counterterrorism intelligence for the conduct of other counterterrorism activities]. There were also missteps in the efforts of various Intelligence Community agencies to develop foreign liaison relationships. [ ]. However, significant problems arose because liaison on counterterrorism was not always well integrated into overall U.S. regional goals and TOP SECRET 112 TOP SECRET liaison relations. As a result, other issues, albeit important, sometimes diverted attention from counterterrorism. The many channels for contact between U.S. and foreign intelligence services also led to a lack of coordination at times. Former National Security Advisor Sandy Berger noted that many U.S. agencies, ranging from the CIA and FBI to the Agriculture Department, develop liaison service relations and that, in some countries, there are now a dozen or more of these kinds of relationships. Often, U.S. ambassadors were not able to control these interactions, and, as a result, the U.S. Government did not always place [page 119] proper priorities on what it asked of foreign governments. In his testimony, Mr. Berger recommended giving “the DCI authority to coordinate all intelligence cooperation with other countries.” Finally, the capabilities of FBI Legats were not always incorporated within the overall intelligence relationship with a foreign country. Thus, other members of the U.S. Intelligence Community did not always utilize relationships developed by the Legats to their full advantage.

16. Finding
[The activities of the September 11 hijackers in the United States appear to have been financed, in large part, from monies sent to them from abroad and also brought in on their persons. Prior to September 11, there was no coordinated U.S. Government-wide strategy to track terrorist funding and close down their financial support networks. There was also a reluctance in some parts of the U.S. Government to track terrorist funding and close down their financial support networks. As a result, the U.S. Government was unable to disrupt financial support for Usama Bin Ladin’s terrorist activities effectively]. Discussion: [Tracking terrorist funds can be an especially effective means of identifying terrorists and terrorist organizations, unraveling and disrupting terrorist plots, and targeting terrorist financial assets for sanctions, seizures, and account closures. As with organized criminal activity, financial support is critically important to terrorist networks like al-Qa’ida. Prior to September 11, 2001, however, no single U.S. Government agency was responsible for tracking terrorist funds, prioritizing and coordinating government-wide efforts, and seeking international collaboration in that effort. Some tracking of terrorist funds was undertaken before September 11. For the TOP SECRET 113 TOP SECRET most part, however, these efforts were unorganized and ad-hoc, and there was a reluctance to take actions such as seizures of assets and bank accounts and arrests of those involved in the funding. A U.S. Government official testified before the Joint Inquiry, for example, that this reluctance hindered counterterrorist efforts against Bin Ladin: “Treasury was concerned about any activity that could adversely affect the international financial system. . . ].” Treasury Department General Counsel David Aufhauser testified to the Joint inquiry on July 23, 2002 that, prior to September 11, the financial war on terrorism was “ad-hoc-ism”, episodic, and informal without any orthodox mechanism for the exchange [page 120] of information or setting of priorities. He stated that, prior to September 11, the DCI never asked Treasury to perform an analysis of Bin Ladin, al-Qa’ida, or associated terrorist financing. At the same hearing, the Chief of the FBI’s Financial Review Group also testified to the lack of an overall financial strategy against terrorist funding. He stated that the FBI’s financial investigations prior to September 11 were inconsistent, done on a caseby- case basis, and not supervised by a specialized unit at FBI Headquarters. Given this lack of focus on terrorist financing, the Intelligence Community was unable, prior to September 11, to identify and attack the full range of Bin Ladin’s financial support network. Former National Counterterrorism Coordinator Richard Clarke described for the Joint Inquiry his pre-September 11 frustration with the Intelligence Community’s lack of focus in this regard: [ ]. . . . . Whenever we pressed the various agencies to do more on finding Bin Ladin’s money, we would hear that they didn’t consider it as important as the White House did for the reason you specified, that you were able to TOP SECRET 114 TOP SECRET stage an operation for a small amount of money. My view was that it may have been true that you could stage an operation for a small amount of money, but you couldn’t run al-Qa’ida for a small amount of money. Al- Qa’ida was a vast worldwide organization that was creating terrorist groups in various countries that would not be called a-Qa’ida, but would be called names associated with that particular country. But they were creating terrorist groups, they were funding them from the start. They were taking preexisting terrorist groups and buying their allegiance and buying them additional capability. It seemed to me it must have cost a great deal of money to be al-Qa’ida, but I was never able to get the Intelligence Community to tell me within any range of magnitude how much money the annual operating budget of al-Qa’ida may have been. [Page 121] Prior to September 11, there was also some reluctance to use available financial databases to track suspected terrorists. The Chief of the FBI’s Financial Review Group – which had been only a section in the FBI’s White Collar Crime Unit before September 11 -- and the Director of the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) both testified before the Joint Inquiry that, prior to September 11, they had capabilities to develop leads on terrorist suspects and link them to other terrorists and to terrorist funding sources. They both agreed that they would have been able to locate Nawaf al-Hazmi and Khalid al-Mihdhar in the United States in August 2001, if asked, through credit card and bank information. The use of these capabilities in the first weeks after September 11 enabled the FBI, with assistance from the Secret Service, to connect almost all of the 19 hijackers to each other very quickly by linking bank accounts, credit cards, debit cards, address checks, and telephones. Despite the existence of those capabilities, the FBI did not seek their assistance in the search for al-Hazmi and al- Mihdhar in late August 2001. FinCEN was involved in tracking terrorist funds prior to September 11 and experienced some success. FinCEN began doing linkage analysis of terrorist financing in October 1999 and first identified a specific account with a direct link to al-Qa’ida in February 2001. It has the advantage of being able to work with both law enforcement and intelligence information, and to combine that information with Bank Secrecy Act and commercial data to assist the Treasury Department’s Office of Foreign Assets Control (OFAC) and others in the seizure, blocking, and freezing of terrorist assets. FinCEN’s capabilities have been made available to federal, state, and local law enforcement agencies for lead purposes since before September 11. TOP SECRET 115 TOP SECRET The FBI did some tracking of terrorist funds prior to September 11, but this was mostly done on an episodic basis, primarily directed at money laundering activity, in the context of field office investigations with no national or international coordination, and with very limited cooperation with the Treasury Department. The Joint Inquiry was informed that the FBI’s newly-formed Financial Review Group is developing what did not exist pre-September 11, a national strategy for a coordinated U.S. Government-wide [page 122] effort to track terrorist funds, mine financial data from a common database, investigate, disrupt, arrest, and prosecute. International cooperation in tracking terrorist funds was also not easy to achieve prior to September 11. For example, the Director of OFAC at the Treasury Department testified that he made two trips to Saudi Arabia, Bahrain, the United Arab Emirates, and Kuwait in 1999 and 2000 to request their cooperation in tracking and restricting Bin Ladin and al-Qa’ida funds, but only achieved limited results. Pre-September 11, OFAC did take some actions, such as trade sanctions and an asset freeze against the Taliban for harboring Bin Ladin, that achieved a modicum of success. On September 24, 2001, President Bush gave a new priority to the tracking of terrorist funds when he stated: “We will direct every resource at our command to win the war against terrorists, every means of diplomacy, every tool of intelligence, every instrument of law enforcement, every financial influence. We will starve the terrorists of funding.” (Emphasis added.) The President made this statement four days after signing an executive order to block the funds of terrorists and their associates. Substantial actions have been taken by the U.S. Government in this area since September 11, including blocking terrorist-related assets; seizing assets and smuggled bulk cash; arresting terrorist financiers and indicting them; and, shutting down front companies, charities, banks, and hawala conglomerates that served as financial support networks for al-Qa’ida and Bin Ladin. New authorities that have been granted since September 11 have also been instrumental in making these seizure and arrest actions successful. For example, OFAC at Treasury requested and received in the October 2001 USA PATRIOT Act explicit TOP SECRET 116 TOP SECRET authorities to block assets while an investigation is in progress and to use classified information as evidence in order to place additional names on the list for freezing and blocking assets. The challenge facing the Intelligence Community is to maintain, expand and adapt the use of these capabilities to combat future terrorist threats effectively. Despite improvements since September 11, former National Counterterrorism [page 123] Coordinator Richard Clarke told the Joint Inquiry that, as of June 2002, there were still many unanswered questions about Bin Ladin’s finances: We asked [CIA] in particular [ ], because initially – because he was said to be a financier. They were unable to do that, [ ].CIA was [ ] unable to tell us what it cost to be Bin Ladin, what it cost to be al-Qa’ida, how much was their annual operating budget within some parameters, where did the money come from, where did it stay when it wasn’t being used, how it was transmitted. They were unable to find answers to those questions. Part of the challenge for the Intelligence Community, and particularly the FBI, is the difference between terrorist financing and other forms of organized criminal money laundering. Strategies and tactics that were effective in countering money laundering must be reexamined in order to assure their effectiveness in regard to terrorist financing. The Treasury Department’s General Counsel was in England at a money laundering conference on September 11, 2001 and explained to the Joint Inquiry how his perception of the problem shifted as he watched the two World Trade Center towers disintegrate: It was as if we had been looking at the world through the wrong end of a telescope. . . . Money had been spirited around the globe by means and measures and in denominations that mocked all of our detection. . . . The most serious threat to our well being was now clean money intended to kill, not dirty money seeking to be rinsed in a place of hiding.