Last September the Office of Foreign Assets Control (OFAC) in the Treasury Department added ISIL terrorist officials and financial facilitators Hasan al-Salahayn Salih al-Sha'ari, Ali Musa al-Shawakh, Tarad Mohammad, and several others to the burgeoning list of Specially Designated Nationals (SDN) whose funds are to be frozen and otherwise financially sanctioned. What is not common knowledge is the aggressive campaign headed by the U.S. Treasury Department to collect and analyze intelligence on terrorists as well as drug traffickers so the adversaries can be subjected to stiff punitive financial sanctions.
The intelligence component of the Treasury's counterterrorism initiative relies on the production of quality intelligence by OFAC’s peer, the Office of Intelligence and Analysis (OIA). Created following 9/11 through the Intelligence Authorization Act to provide Treasury with an anti-terrorism financial capability, OIA has grown from a small core of counterterrorism analysts to a multi-disciplinary operation supported by subject-matter experts fulfilling the Treasury Department's national security mandate. Soon, OIA was recruiting intelligence specialists with over half functioning as analysts, economists, and an added complement of policy and legal advisors. Collectively, OIA has produced a broad range of highly classified intelligence products, but the proliferation of terrorist groups and fundraising options was outstripping OIA’s resources—it had one of the smallest overall operations in the entire intelligence community.
In 2009, the Government Accounting Office found that the OIA program on terrorist finance was not fully integrated and lacked the strategy and resources to fulfill its mission. In 2010, Treasury sought additional resources and—perhaps as a response to GAO criticism—elevated its intelligence program by establishing the Assistant Secretary for Intelligence and Analysis. Overall coordination is provided by the Under Secretary for Terrorist Finance, a position created in 2004.
OIA generates analytic products and high specific Intelligence Information Reports (IIRs) that are used by customers in the White House, NSC, and across the Defense, Justice, Homeland Security, and Intelligence Community. OIA analyses have been essential to the Treasury Department’s role in choking off the flow of funding to terrorist organizations like ISIL and al Qaeda. The broad national security OIA mandate also has led to tactical plans to degrade adversaries’ plans for weapons proliferation and sustenance for illicit networks that promote violence as well as narcotics trafficking and other forms of transnational crime.
Relying on OIA’s analysts, Treasury has added hundreds of individuals and organizations to OFAC Specially Designated Nationals (SDN) lists—e.g. under the Narcotics Kingpin Designation Act—and others for providing material support to al Qaeda and other terrorist groups. Specifically, OIA’s support to the U.S. Special Operations Command (SOCOM) has resulted in enhanced generation of terrorist finance leads, which has enabled decisive U.S. and foreign government actions. OIA has also been pivotal to Treasury’s role in pressuring Iran to curtail its nuclear fuel production. North Korea is another state actor building covert financial networks enabling it to acquire nuclear weapons. As U.S. and allied preoccupation with ISIL grows more intense in coming weeks, the OIA role in constraining the terror group’s access to funding will likewise rise to a top national security priority.