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mental appropriation "a lifesaver." See, for example, the request for supplemental appropriations in CIA briefing
materials,"Targeting the Terrorists: Next Steps and New Initiatives," Feb. 1, 2000 (for the President).
75. Richard Clarke interview (Feb. 3, 2004).
76. James Pavitt interview (Jan. 8, 2004).
77. Richard Clarke interviews (Dec. 18, 2003; Feb. 3, 2004).
78. CIA memos, summary of weekly Berger/Tenet meeting, Apr. 5, 12, 2000; NSC memo, "April 19, 2000
Agenda for Deputies Committee Meeting on CT:The Millennium Threat FY00 and FY01 Budget Review;" NSC
memo, "Summary of Conclusions of April 18, 2000 CSG Meeting," Apr. 26, 2000. On May 2, 2000, Berger was
updated on budget issues relating to the CIA and other agencies; there was agreement on the most critical items
to be funded, but not on the source of that funding. In CIA's case, it had already reprogrammed over $90 million,
but Tenet wanted to use most of this money on non-counterterrorism programs. NSC memo, Kurtz to Berger,
"Budget Issues," May 2, 2000. On June 29, 2000, the President authorized raising the CIA's covert action funding
ceiling. NSC memo, McCarthy to CSG, "DCI Wants to Raise Funding Ceiling," May 8, 2000; NSC memo,
McCarthy to others July 7, 2000 (appendix on authorities). But funding issues in other agencies remained unre-
solved. Clarke complained that neither Treasury nor Justice would identify offsets. Clarke encouraged OMB to tell
both departments that if they would not identify offsets then OMB would. NSC email, Clarke to Rudman and
Mitchell, May 9, 2000. On August 1, 2000, Clarke wrote Berger that one of five goals by the end of the Clinton
administration was to secure appropriations for cybersecurity and millennium after-action review projects. NSC
memo, Clarke to Berger,"Goals and Wildcards,"Aug. 1, 2000.As late as September 2000, Clarke was advising Berger
that unfunded counterterrorism requests continued to be his number one priority. NSC note, Clarke to Berger,
Sept. 9, 2000.
79. Executive Order 13099 (Aug. 20, 1998); Rick Newcomb interview (Feb. 4, 2004); Robert McBride inter-
view (Nov. 19­20, 2003); NSC memo, Kurtz to Berger, June 28, 2000. OFAC did freeze accounts belonging to
Salah Idris, the owner of the al Shifa facility bombed in response to the East Africa embassy bombings. Idris filed
suit against his bank and OFAC. OFAC subsequently authorized the unfreezing of those accounts. James Risen,
"To Bomb Sudan Plant, or Not: A Year Later, Debates Rankle," New York Times, Oct. 27, 1999, p. A1.The inability
to freeze funds is attributed in part to a lack of intelligence on the location of Bin Ladin's money, OFAC's reluc-
tance or inability to rely on what classified information there may have been, and Bin Ladin's transfer of assets into
the hands of trusted third parties or out of the formal financial system by 1998. Even if OFAC had received bet-
ter intelligence from the intelligence community, it would have been powerless to stop the bulk of the problem.Al
Qaeda money flows depended on an informal network of hawalas and Islamic institutions moving money from
Gulf supporters to Afghanistan. These funds would not therefore have touched the U.S. formal financial system.
OFAC's authorities are only against U.S. persons, financial institutions, and businesses. Frank G. and Mary S. brief-
ing (July 15, 2003); Rick Newcomb interview (Feb. 4, 2003).
80. Executive Order 13129;Treasury memo, Newcomb to Johnson, "Blocking of Taliban-Controlled Assets,"
undated (probably Oct. 18, 1999).
81. DOS cable, State 184471, Sept. 30, 1999; 18 U.S.C. § 2339B.
82. The Financial Action Task Force, a multilateral government organization dedicated to standard setting,
focused on money laundering, particularly as it related to crimes such as drug trafficking and large-scale fraud that
involved vast amounts of illegally procured money.Although the UN General Assembly adopted the International
Convention for the Suppression of Financing Terrorism in December 1999, the convention did not enter into force
until April 2002.
83. Doug M. interview (Dec. 16, 2003); Frank G. interview (Mar. 2, 2004). See also Mike interview (Dec. 11,
2003), setting forth the goals of the UBL station; none relate specifically to terrorist financing. Another witness
recalled that the UBL station made some effort to gather intelligence on al Qaeda financing, but it proved to be
too hard a target, the CIA had too few sources and, as a result, little quality intelligence was produced. Ed G. inter-
view (Feb. 3, 2004). Some attributed the problem to the CIA's separation of terrorist-financing analysis from other
counterterrorism activities.Within the Directorate of Intelligence, a group was devoted to the analysis of all finan-
cial issues, including terrorist financing. Called the Office of Transnational Issues (OTI), Illicit Transaction Groups
(ITG), it dealt with an array of issues besides terrorist financing, including drug trafficking, drug money launder-
ing, alien smuggling, sanctions, and corruption. ITG was not part of the CTC, although it rotated a single analyst
to CTC. Moreover, OTI analysts were separated from the operational side of terrorist financing at CTC, which
planned operations against banks and financial facilitators.William Wechsler interview (Jan. 7, 2004); Frank G. and
Mary S. briefing (July 15, 2003).
84. CIA analytic report,"Funding Islamic Extremist Movements:The Role of Islamic Financial Institutions,"
OTI 97-10035CX, Dec. 1997.
85. Mike interview (Dec. 11, 2003).
86. CIA analytic reports,"Usama Bin Ladin: Some Saudi Financial Ties Probably Intact," OTI IR 99-005CX,
Jan. 11, 1999; "How Bin Ladin Commands a Global Terrorist Network," CTC 99-40003, Jan. 27, 1999; "Islamic
Terrorists: Using Nongovernmental Organizations Extensively," CTC 99-40007, Apr. 9, 1999.
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