The Political Conundrum!

MercyHurst College has a new exhibit on virtual worlds, which is well worth visiting.

The project is called Maleperduys and the website can be linked to here. The project examines virtual worlds from a wide variety of angles including terrorism, espionage and crime.

In its own words the site is a "... a custom intelligence analysis produced by graduate students at the Mercyhurst College Institute for Intelligence Studies. The goal of this analysis is to illuminate the implications of the emergence and evolution of virtual worlds (VWs) to US national security. "

The exhibit also runs in its own custom browser based virtual world on the Just Leap In platform, which can be linked to via the website. This neatly demonstrates the value of virtual worlds in presenting information in a cogent virtual fashion.

Today, in a speech at the Council on Foreign Relations, FBI Director Robert Mueller gave official credence to the warnings voiced here by Michael Cutler and Bill West of the Visa Waiver Program. While discussing the threat of Mumbai-like attacks in the U.S., Director Mueller told the crowd, "Today, we still face threats from al Qaeda. But we must also focus on less well-known terrorist groups, as well as homegrown terrorists. And we must consider extremists from visa-waiver countries, who are merely an e-ticket away from the United States."

I should give Director Mueller credit; today isn't not the first time he's warned that the Visa Waiver Program is a giant security hole - it's actually the second. Last August, at the 5th Annual Border Security Conference in El Paso, he said, "It is sobering to realize that a terrorist in a visa-waiver country may be just a plane ticket away from the United States—or that a violent gang member may cross the border from Mexico and end up in Michigan. Yet this is today’s reality."

Yes, it is. But it's been a reality to us on this site, especially to our two former senior federal agents who worked customs and immigration cases, for four years. In fact, four years ago yesterday, Michael posted this when discussing homegrown terrorist Ahmed Omar Abu Ali: "It is safe to assume that there are other individuals living in other countries who are similarly related to Al Qaeda but who acquired citizenship in countries that participate in the Visa Waiver program, either by being born in those countries or by having been naturalized. There are 27 such countries plus Canada. This is why, given the on-going "War on terror" the Visa Waiver program needs to be terminated to provide our officials better opportunities to more effectively screen aliens who seek admission into the United States." You can read all of Michael's posts and Bill's posts on this topic.

Now if Director Mueller would only go further by admitting that the only "good" Visa Waiver Program is a "dead" Visa Waiver Program.

By the way, here are more comments by Michael on immigration fraud, sent in response to the news of the arrest in California of another homegrown terrorist suspect:

Since Bank Secrecy Act (BSA) reporting requirements were enhanced by passage of the U.S.A. PATRIOT Act following the 9/11 terrorist attacks, there has been an ongoing debate about their usefulness. In essence, are the benefits of reporting requirements to the law enforcement community outweighed by the burdens placed on financial institutions? The more important question is: are such measures effective or ineffective? The reality is, reporting requirements are here to stay. Therefore, we must continuously strive to develop, implement, improve and modify mechanisms to make reporting requirements as effective as possible.

Another reality is that terrorist and criminal organizations require funding in order to operate and succeed. Invariably, their funding sources will flow through financial institutions. This is why BSA reporting requirements are critically important to our National Security. This fact becomes more compelling in view of the actuality that finance is one of the two most significant vulnerabilities to terrorist and criminal organizations.

Regardless of how limited, there is a level of effectiveness with respect to BSA reporting requirements in identifying terrorist financing. The bottom line is, it is possible for financial institutions to identify terrorist financing, but it is highly improbable. We must take continual actions that increase the probability factor, and thereby increasing the possibility. The challenge confronting the government and banking community is to improve the effectiveness of the process.

Each side of the issue presents persuasive arguments supporting their respective positions. Starting with the burden side, many in the financial sector are frustrated by the fact that, unlike money laundering, terrorist financing is extremely difficult and challenging to detect. Many will argue it is virtually impossible to identify. This sense of frustration is exacerbated by the fact that industry experts frequently opine that law enforcement does not provide the intelligence information or guidance to enable financial institutions to effectively focus their monitoring and search capabilities to improve the probability of uncovering terrorist financing. These are the primary reasons they believe the BSA reporting requirements to identify terrorist financing are ineffective.

On the other side of the debate, law enforcement has been the direct beneficiary of BSA reporting requirements. There have been numerous law enforcement successes, and from a broader perspective, government wide terrorist financing successes, that were achieved because law enforcement was able to have legal access to BSA documents, such as Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs). The government considers many of these successes to be extremely significant in disrupting or denying terrorists the access to funding. Hence, law enforcement considers the reporting requirements beneficial.

In this context, the banking sector is generally not cognizant of the benefit to law enforcement. Instead, they consider the reporting requirements to be burdensome, cost prohibitive and ineffective. On the other hand, law enforcement is generally satisfied by the benefits they derive and therefore do not consider the reporting requirements to be ineffective. Consequently, they are not necessarily sensitive to the cost burden or sense of ineffectiveness felt by the financial sector. Likewise, the financial sector not being mindful of the true benefit, does not appreciate the significance of how law enforcement has benefited from BSA information. This is where the government and banking sector must come together to establish a middle ground where they can balance the benefits and burdens of BSA reporting requirements.

The first step moving forward is for government to understand why the banking sector considers BSA reporting requirements to be burdensome and ineffective and simultaneously, for the banking sector to understand why law enforcement considers the reporting requirements to be beneficial. The two sides need to work together both collectively and unilaterally to identify, develop, implement and improve mechanisms to effectively identify terrorist financing.

Collective measures would include working together to establish mechanisms to legally share information, finding meaningful feedback mechanisms and delineating red flags through case typologies. Unilateral measures would include the government enhancing mechanisms to identify emerging trends and developing methodologies to deal with such emerging trends. Likewise, financial institutions should take steps to better recognize risk within their institutions and to enhance their internal monitoring capabilities to identify terrorist and criminal exploitation threats.

There are six steps the government and industry should take to collectively and unilaterally increase the probability of identifying terrorist financing. They are:

1. The government and financial sector must recognize the importance of terrorist financing specific training. This is a dimension that is lacking on both sides. Without specific training, the ability to understand and disrupt terrorist financing is more difficult to achieve.

2. The government must develop a means to legally provide security clearances to select personnel in financial institutions in order to share limited intelligence information that could be scrubbed against bank monitoring systems to identify account or transactional information associated with terrorists. The FBI has been discussing this challenging issue since 9/11, in concert with select industry compliance leaders and experts.

3. A consistent and comprehensive feedback mechanism from law enforcement must be developed that demonstrates the importance of BSA reporting, especially the significance of SARs. FinCEN’s SAR Activity Review is a good mechanism that provides insightful information. In addition, specific feedback from law enforcement to financial institutions concerning the value and benefit of BSA data, including SAR filings, would have a dramatic impact on the morale of individuals responsible for SAR reporting. The FBI is currently in the process of initiating publication of a periodic newsletter, which will provide such feedback to the financial community. The FBI plans to disseminate this newsletter through FinCEN.

4. There must be an assessment by the government of all SARs related to or identifiable with terrorism cases. Such a review would identify specific red flags that could be used as a training mechanism and more importantly, could be factored into the monitoring/surveillance capabilities of financial institutions. In addition, a determination could be made as to why the financial institution filed a SAR. In many instances, the SAR was filed for violations other than terrorist financing. Understanding what triggered the SAR filing; in tandem with how the SAR ultimately was linked to terrorist interests would be insightful. The FBI’s Investigative Data Warehouse (IDW) is a powerful data mining tool. IDW’s implementation magnifies the importance of BSA data. Based on its capability, the FBI has determined that 41.7 percent of all terrorism investigations have BSA data identifiable with the case. In addition, this type of assessment would enable financial institutions to use their monitoring systems more effectively and increase the probability factor.

5. In addition to assessing SARs, the government and industry should collectively identify and assess as many case studies, of terrorist financing related investigations, as can be identified and legally publically accessed. The case studies should be compared to determine what types of commonalities and patterns of activity exist. In addition, common red flags should be easily discernable. This type of case study assessment, coupled with the SAR analysis, would provide more meaningful information to consider in identifying terrorist financing characteristics. This would enable financial institutions to more effectively surveille and monitor transactional information. There is at least one informal grassroots working group comprised of government, former government and industry experts who are identifying hundreds of case studies for analysis.

6. A combination of BSA data, particularly SARs, combined with empirical and anecdotal information would enable the government and financial sector to collectively and unilaterally conduct trend analyses. This would be a significant factor in identifying emerging trends. On a government level, this would contribute to implementing investigative and enforcement strategies. On the institutional level, this would enable the financial sector to implement strategies to mitigate risk.

As noted earlier, it is possible for financial institutions to identify terrorist financing, but it is highly improbable. The six steps set forth above would clearly increase the probability, and thereby, the possibility of detecting terrorist financing. These measures would not only enable financial institutions to better meet their BSA reporting requirements, they would improve the effectiveness of the process. In so doing, financial institutions would be taking steps to enhance our National Security by diminishing necessary funding streams to terrorists.

When Dana Canedy put her fiancé on a plane bound for Iraq in 2005, she gave him a journal to jot down a few thoughts for their newborn son. Unfortunately King was never able to deliver his advice to Jordan in person. King was killed by a roadside bomb in October 2006.

U.S. and Iraqi forces have begun a new military offensive in northern Iraq aimed at rooting out al-Qaida and other Sunni insurgents, American and Iraqi officials said Sunday.

A former British resident who claims he was brutally tortured at a covert CIA site in Morocco has been freed from Guantanamo after nearly seven years in U.S. captivity - an ordeal that could come back to haunt the U.S. and British governments.

Iraq's restored National Museum is reopening Tuesday, nearly six years after looters carried away antiquities and treasures as U.S. troops stood by in the chaos of Saddam Hussein's fall from power.

My colleague Zachary Abuza wrote an interesting look at the Tamil Tigers, now in demise. As he notes, the LTTE pioneered many innovations in the use of terrorism that spread to other terrorist groups around the world.

Among the strategies the LTTE innovated are the use of suicide bombings and fund raising outside of state sponsorship. One of the most adaptive groups using some the LTTE model has been the FARC in Colombia, while suicide bombing have been taken up by Islamist groups around the globe.

This is, to me, one of the biggest changes that the new world order has brought in the past 15 years among non-state armed groups-the ability to rapidly exchange "best practices" and experiences across the globe.

In years past, Marxists would train Marxists, (the Cubans, Sandinistas and FMLN for example, in the Central American conflicts) and U.S. sponsored groups would receive instruction, but there was no real way, except direct meetings in camps and under state sponsorship, to exchange experiences.

The internet has changed that, and the end of the Cold War has helped erase many of the lines that once existed in who will deal with whom. At the same time, state sponsorship for many organizations was being reined in or cut off.

The shifting lines was largely lost on the intelligence community looking at radical Islamist groups, who believed Sunni groups like al Qaeda would not deal with Shiite groups like Hezbollah, although the documented cross-training between the two groups began at least in the ealry 1990s, while bin Laden was in Sudan.

As LTTE pioneered certain tactics, so did ETA in Spain (the use of explosives and LNG bombs), the IRA and IRA-P in Ireland (also explosives and cell structures) and others. The FARC, in turn, picked them up, improved on them, and taught new techniques. My full blog is here.

“The report of my death is an exaggeration” – Mark Twain

While I would love to eulogize about the death of the Tamil Tigers, it is of course premature. However, I offer this “appreciation” of the Tamil Tigers, an organization that has been, bar none, the most cutting-edge, adaptive and creative terrorist organization in the world. There is not a terrorist organization in the world that has not adopted LTTE tactics or at least aspired to do so. As the LTTE has never targeted the United States, it has been a low priority for law enforcement, military and the intelligence services. Yet, the Tamil Tigers merit study.

Founded in May 1976, by Villupilai Prabhakaran, the Tamil Tigers – formerly the Liberation Tigers of Tamil Eelam (LTTE) – grew from being a several thousand man guerilla force to being at its height a conventional force with some 10,000 combatants. Though their military collapse since mid 2006, has been surprisingly swift, one cannot forget that for years, they fought the Sri Lankan military to a standstill and controlled a significant amount of territory. Their nearly forty-year struggle is highlighted by firsts and superlatives:

U.S. military advisers, mostly Army Special Forces Soldiers, are training Pakistani troops in their fight against al-Qaida and the Taliban, The New York Times reported Sunday.