Letter to Treasury

September 14, 2010

Dear Under Secretary Levey,

You have an important job.  It’s challenging work.  And most people agree that you do it well, or you probably wouldn’t have retained your position during both the Bush administration and the Obama administration.  Treasury has, by its own account at least, succeeded in restricting the financial activities of al Qaeda and has cracked down on entities that help Iran evade sanctions.

But we can all use an outsider perspective from time to time.  If you won’t invite anti-terror finance bloggers in for a rap session with you, sir, please at least consider the following constructive criticism and recommendations: 

  1. Stop letting the Saudis get away with lying to us about the continued transfer of funds overseas without SAMA approval.  The Hialeah, Florida, office of the International Islamic Relief Organization was incorporated under Saudi auspices without disclosing that information to the GAO.  As such, the feds should raid the office and seize its records for review by TFI.  All TFI assistant secretaries should be instructed to refrain immediately from painting a rosy picture of Saudi cooperation in the war against terror financing.
  2. Stop behaving like a charitable facilitator.  Every state in the U.S. has an authority to regulate charities.  A common thread among charity regulators is to urge transparency among charities and to empower citizens to do proper research to give wisely.  Treasury too followed this approach during the Bush administration, but has abandoned it under Pres. Obama.  Now they just say they’re “working with” charities to help prevent them from being abused.  Personal responsibility over one’s own giving had gone out the window.  Understand that your responsibility is to enforce the law including the BSA and sanctions against terrorists, not to enforce the applause lines of a presidential speech in Cairo.  When questionable Islamic charities request to meet with your top officials, turn them down.
  3. What’s the hold up with terrorist designations and asset freezes?  Of course it’s government, and you have to coordinate with the sluggish State Department, so the most routine tasks can take months to accomplish.  But why do we wait years before the Pakistani Taliban is designated, drag our feet with the Haqqani Network, and we’re still waiting for a designation of Hizbul Islam in Africa?
  4. Why is your website so hard to use?  Depending on what you’re researching, it can be challenging to find what organization and which of its members have been designated under which authority and which agency.  Why not have a single-stop shop that allows users to search by country, by organization name, by terrorist name, etc., which shows whether the entity has been designated by Treasury or State, what sanctions they currently face, and whether there is a Department of Justice reward available for information about that entity?  It takes a lot of agencies to make these decisions happen, but American businesses, banks, customers, and donors would be able to conduct business, charitable, and academic research with better information if it were available through one online database.  Timmy, Hillary, & Holder—there are more searching & indexing website services available now than ever before, so it’s time to step it up a notch.
  5. Where’s Szubin?  We hear plenty from Stuart Levey about international sanctions.  David Cohen mouths off a lot.  But as central as OFAC is to the Obama administration’s policy on Iran, one would think that we’d hear more often from Adam Szubin, a Bush-era appointee and current director of OFAC.  He rarely seems to testify before Congress or make speeches on CSPAN or get interviewed by the print media very often.  Maybe he’s media shy.  Or is he muzzled?

Congress and the President will set overall policy, and journalists will ask tough questions sometimes, but it would probably help Treasury out to hear from ordinary citizens who are concerned about terrorist financing.


Money Jihad

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