Former Michigan Congressman Indicted for Terrorism Support

Former Michigan congressman and delegate to the United Nations, Mark Deli Siljander, was indicted Wednesday on charges of being part of a terrorist fundraising ring that allegedly sent more than $130,000 to a supporter of al-Qaida and the Taliban.^[1]

Siljander is charged with money laundering, conspiracy and obstructing justice for allegedly lying about lobbying senators on behalf of an Islamic charity that authorities said was secretly sending funds to terrorists.^[2] The 42-count indictment, unsealed in U.S. District Court in Kansas City, Mo., accuses the Islamic American Relief Agency(IARA) of paying Siljander $50,000 for the lobbying — money that turned out to be stolen from the U.S. Agency for International Development.^[3]

The government asserts that IARA employed a man who had served as a fundraising aide to Osama bin Laden, the al-Qaida leader and mastermind of the Sept. 11 attacks.^[4]

The indictment accuses IARA of sending approximately $130,000 to help Gulbuddin Hekmatyar, whom the United States has designated a global terrorist.^[5] The money, sent to bank accounts in Peshawar, Pakistan, in 2003 and 2004, was masked as donations to an orphanage located in buildings that Hekmatyar owned.^[6]

The indictment says Siljander was hired by IARA in March 2004 to lobby the Senate Finance Committee in an effort to remove the charity from the panel's list of suspected terror fundraisers.^[7] For his work, IARA allegedly paid Siljander with money that had come from U.S. government funding.^[8] The charity was awarded the money years earlier for relief work it promised to perform in Africa, and IARA was supposed to return any unused funds after the relief project ended in 1999.^[9]

Instead it is asserted that Siljander and three IARA officers agreed to cover up the money's origins and use it on the lobbying effort.^[10]

Obstruction of Justice
Under 18 U.S.C. § 1503(a), it is a crime for a person to corruptly influence, obstruct, or impede the due administration of justice. The punishment for a violation of section 1503(a) is a fine, imprisonment for up to 10 years, or both.Federal criminal attorney Douglas McNabb has also previously discussed obstruction of justice in his blog, here; and money laundering, here.

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^[1] Lara Jakes Jordan, Ex-Lawmaker Charged in Terror Conspiracy, Associated Press Newswire, January 16, 2008, available at LEXIS, News Library, Wire News Services.
^[2] Id.
^[3] Id.
^[4] Id.
^[5] Id.
^[6] Id.
^[7] Id.
^[8] Id.
^[9] Id.
^[10] Id.

Abdul Tawala Ibn Ali Alishtari Asserts that He Was Not Trying to Support Terror, Just Himself

Abdul Tawala Ibn Ali Alishtari has been accused of trying to funnel money to a terrorist training camp in Afghanistan told a judge his dealings with an undercover operative were to enrich himself, not to help the enemy.^[1]

Alishtari is charged with accepting an unspecified amount of money to transfer $152,000 that he believed was being sent to Pakistan and Afghanistan to support the camp.^[2] He has fervently pleaded not guilty in the U.S. District Court in Manhattan to charges of terrorism financing, material support of terrorism and money laundering.^[3] The charges carried a potential penalty of 95 years in prison.^[4]

Recordings secretly made by federal agents show that Alishtari "was interested more in the profit potential of the undercover's supposed money backers and himself than he was to their 'cause,'" his lawyers wrote in a letter this week to the judge.^[5]

Alishtari was allegedly hoping the undercover agent, who passed himself off as a wealthy Middle Easterner, would invest in Flat Electronic Data Interchange, a loan investment program he was running; federal prosecutors have called it a fraud.^[6]

Contributing or supplying services to designated terrorist groups (or conspiring to contribute or supply services to these entities), is a violation of regulations issued under the International Economic Emergency Powers Act,^[7] we have previously discussed IEEPA in this blog, here.

Providing material support to a terrorist organization is covered under 18 U.S.C. § 2339B underwhich it states that it is a crime to knowingly provide, attempt to provide, or conspirer to provide material support or resources to a foreign terrorist organization. The penalty for this is a fine or imprisonment for not more than 15 years, or both, and, if the death of any person results, shall be imprisonment for any term of years or for life.^[8]

“Material support” is defined as any property, tangible or intangible, or service, including currency or monetary instruments or financial securities, financial services, lodging, training, expert advice or assistance, safehouses, false documentation or identification, communications equipment, facilities, weapons, lethal substances, explosives, personnel (1 or more individuals who may be or include oneself), and transportation, except medicine or religious materials.^[9]

Federal criminal defense attorney Douglas McNabb has discussed the terrorism crime of providing support to terrorists extensively in this blog; these posts can be accessed here. He has also written extensively on terrorist financing.

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^[1] AP Staff, Man Says He Didn't Try to Fund Terrorism, Associated Press Newswire, January 4, 2008, available at LEXIS, News Library, Wire News Services.
^[2] Id.
^[3] Id.
^[4] Id.
^[5] Id.
^[6] Id.
^[7] 50 U.S.C. §§ 1701-07 (2007).
^[8] 18 U.S.C. § 2339B (2007).
^[9] 18 U.S.C. § 2339A(b)(1)(2005).

Holy Land Charity Waits for Jury Deliberations

A federal court jury will begin deciding this week whether President Bush was correct when he declared that a Texas-based Muslim charity was an important cog in financing international terrorism.^[1] Federal prosecutors and defense attorneys are scheduled to make closing arguments Monday in the trial of Holy Land Foundation for Relief and Development and five of its leaders, all of which are being held on charges of aiding terrorists, conspiracy and money laundering. ^[2]

Holy Land was the largest Muslim charity in the United States. In December 2001, President Bush appeared at a Rose Garden news conference to announce that its assets had been seized and said, ''[t]he net is closing'' on those who finance terrorists.^[3] The government is asserting that Holy Land funneled more than $12 million to Palestinian schools and charities controlled by Hamas after the U.S. government had already declared Hamas a terrorist group, thus making the asserted support illegal.^[4]

The government's case relies heavily on thousands of pages of documents such as bank records and on video and audio tapes that showed some of the defendants meeting with Hamas members and supporters.^[5]

A letter sent to Shukri Abu Baker, Holy Land's chief executive, assessed whether leaders of the Palestinian charities were friend or foe. But the letter, and much of the other evidence in the case, is dated to the early 1990s or before.^[6] A key witness was an Israeli official who was allowed to testify without being identified and he acknowledged that none of the groups appeared on U.S. government terrorist lists, at that time.^[7]

Testimony in the trial lasted nearly two months. On Thursday, Judge A. Joe Fish gave each side six hours for closing arguments and hinted the presentations could last more than two days.^[8] The jury could begin deliberations Wednesday where the verdict may hinge on whether a jury of 12 ordinary Texans believes that Hamas controlled Palestinian charities that received Holy Land money.^[9]

Prosecutors declined to call many of the people on their witness list, including Mohamed Shorbagi who is a former Holy Land representative who pleaded guilty last year to supporting Hamas; he was supposed to testify about the relationship between Holy Land and Hamas.^[10] Laurie L. Levenson, a former federal prosecutor, believes Dallas prosecutors didn't want to expose Shorbagi to cross-examination by Holy Land's lawyers.^[11] “A witness who looks untrustworthy on cross-examination can do more harm than good to the government's case,” she said.^[12]

Federal criminal defense attorney Douglas McNabb has previously written about the trial of Holy Land Foundation for Relief and Development terrorism crimes blog, these posts can be found here.

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^[1] David Koenig, Muslim charity trial enters closing stages, Associated Press Newswire, September 17, 2007, available at LEXIS, News Library, Wire News Services.
^[2] Id.
^[3] Id.
^[4] Id.
^[5] Id.
^[6] Id.
^[7] Id.
^[8] Id.
^[9] Id.
^[10] Id.
^[11] Id.
^[12] Id.

Shukri Abu Baker Charged with Supporting Terror

An FBI agent testified Monday, July 30, that leaders of a local Muslim charity helped to plot a disruption aimed at derailing a Middle East peace accord.^[1] The FBI asserted that the charity, the Holy Land Foundation for Relief and Development, was motivated by the fear that the accord would prevent the elimination of Israel.^[2] The group allegedly met to discuss a way for Hamas to block the Oslo accords, a deal which would have led to Palestinian self-rule but also coexistence with Israel.^[3]

The agent said leaders of the Holy Land Foundation for Relief and Development were among U.S.-based supporters of the Palestinian militant group Hamas who met at a Philadelphia hotel in 1993.^[4] The agent said the FBI bugged the conference room, capturing conversations in which Holy Land Chief Executive Shukri Abu Baker repeatedly told attendees to refer to Hamas as ''Samah,'' or Hamas spelled backwards.^[5]

The Philadelphia meeting was highlighted in the 2004 indictment against the leaders of Holy Land, which was the nation's largest Muslim charity until federal agents shut it down in December 2001.^[6] The testimony of FBI agent Lara Burns provided additional details about the event, including the participation of leaders of the Council on American-Islamic Relations, a leading U.S. Muslim-rights group.^[7]

Baker and four other former Holy Land officials are charged with aiding a terrorist group, conspiracy and money laundering for allegedly funneling millions of dollars to Hamas through charities controlled by the militants.^[8]

Contributing or supplying services to designated terrorist groups (or conspiring to contribute or supply services to these entities), is a violation of regulations issued under the International Economic Emergency Powers Act,^[9] we have previously discussed IEEPA in this blog, here.

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^[1] David Koenig, Feds Build Case Against Muslim Charity, Associated Press Newswire, August 4, 2007, available at LEXIS, News Library, Wire News Services File.
^[2] Id.
^[3] Id.
^[4] Id.
^[5] Id.
^[6] Id.
^[7] Id.
^[8] Id.
^[9] 50 U.S.C. §§ 1701-07 (2007).

EU-US Close to SWIFT Deal

The Society for Worldwide Interbank Financial Telecommunication (SWIFT) is a Belgian company that maintains the central interfaces that 8,000 banks worldwide rely on when trading currency and securities; its operations are essential to the operation of the European banking system.^[1] Because it is a Belgian company it is subject to Belgian laws on data privacy, however it is also subject to lawfully-issued U.S. jurisdiction because of its contacts, with the U.S.^[2] We have previously discussed SWIFT in this blog, here.

Last year, an E.U. panel of data protection experts conducted an inquiry into the sharing and concluded SWIFT's transfer of banking data violated European privacy laws because it did not give enough guarantees that the data was properly protected.^[3] The issue became a major legal and political clash between the E.U. and the United States over anti-terrorism measures and the lengths to which lengths governments should go in trying to prevent terror attacks.^[4]

However now, European Union nations have reached a tentative deal with Washington clarifying how American investigators can use bank transfer data provided for anti-terrorism probes, diplomats said Wednesday.^[5] The deal is aimed at ending a trans-Atlantic fight over privacy rights brought on by the sharing of information on money movements by the Belgian-based SWIFT bank transfer consortium since Sept. 11, 2001.^[6]

The draft agreement would bind the U.S. to use SWIFT data only in anti-terror investigations, and the U.S. Treasury Department would have to certify that data would be handled under its program to track financing of terrorism.^[7] The department would be able to keep the data only for a specified number of years. Diplomats said the draft was approved Wednesday by E.U. nations and was expected to receive final approval by both sides Thursday.^[8]

We have previously discussed the problems of monitoring terrorist financing here.

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^[1] Nate Anderson, Terrorist financing: What's illegal in Belgium is required in the US, ARS Technica, February 16, 2007.
^[2] Id.
^[3] Constant Brand, U.S.-EU agree on using terror probe data, Associated Press Newswire, June 27, 2007, available at LEXIS, News Library, Wire News Services File.
^[4] Id.
^[5] Id.
^[6] Id.
^[7] Id.
^[8] Id.

Members of Missouri Organization Indicted for Aiding Terrorists

Four associates of a local Islamic charity and a fifth man in the Middle East have been charged that they illicitly sent money to Iraq and lied about an associate of Osama Bin Laden's who worked with the charity; they are charged in a 33-count indictment that alleges they stole government and public money and falsely represented their fundraising goals to the public.^[1]

''Today's indictment paints an alarming picture of theft, money laundering, and fraud by the U.S. branch of an international charitable organization………[t]hese charges demonstrate our resolve to thoroughly investigate and prosecute any charities that abuse their tax-exempt status to engage in wide-ranging criminal activity.'' Assistant Attorney General Kenneth L. Wainstein said.^[2]

While the charity has denied financing terrorism, and the Islamic American Relief Agency-USA, based in Columbia, Missouri, has continually tried to distinguish itself from the Islamic African Relief Agency, a federal court of appeals in Washington ruled last month that the two organizations were linked.^[3]

Four of the men are associated with the IARA in Columbia , the fifth is associated with Islamic African Relief Agency, a Sudanese group suspected of financing al-Qaida; Mubarak Hamed, 50, served as executive director of the agency; Ali Mohamed Bagegni, 53, a former board member; Ahmad Mustafa, 54, a former fundraiser; Khalid Al-Sudanee, 55, regional director of the Middle East office of the Islamic African Relief Agency; and Abdel Azim El-Siddiq, 50, former IARA vice president.^[4]

The men also are accused of lying about an associate of Osama Bin Laden not having been an employee of the IARA when, in fact, he was.^[5] Those allegations stem from a 2001 television interview in which ''a person acting on behalf of IARA'' lied about the organization's affiliation with Ziyad Khaleel, deceased, whom U.S. authorities allege helped obtain the satellite phones that al-Qaida used to coordinate the attacks on the U.S. embassies in Kenya and Tanzania.^[6]

The men are charged with, among other things, money laundering,^[7] conspiracy to commit money laundering, conspiracy to violate the International Emergency Economic Powers Act and the Iraqi Sanctions Resolutions,^[8] and theft of public money.

Theft of public money is covered by 18 U.S.C. § 641, which states that it is a crime for a person to steal or purloin money or any thing of value from the United States. The punishment for a violation of this statute is a fine, imprisonment for up to 10 years or both. Some cases have suggested that “it is an essential element of a violation of [section] 641 that the government suffer some actual property loss.”^[9] However, in recent years, that requirement seems to have been dropped. A number of courts have decided that “no one…has explained why Congress would have made property loss an element of a section 641 offense when, historically, there was no such element.”^[10] In short, in some circuits, “proof of the government’s loss is unnecessary in a section 641 prosecution.”^[11] However, since the matter is not completely settled, it is still an argument that should be made, even if it is difficult to do so.

We have previously discussed the crime of money laundering, here.

We have previously discussed the Missouri based IARA, here.

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^[1] Maria Sudekum Fisher, Mo. Indictment: 5 Sent Money to Iraq, AP (via the Guardian), March 8, 2007
^[2] Id.
^[3] Id.
^[4] Id.
^[5] Id.
^[6] Id.
^[7] 18 U.S.C. § 1956 (2007).
^[8] 18 U.S.C. § 371(2007).
^[9] See United States v. Evans, 572 F.2d 455, 471 (5th Cir. 1978); United States v. Collins, 464 F.2d 1163, 1165 (9th Cir. 1972).
^[10] See United States v. Milton, 8 F.3d 39, 44 (D.C. Cir. 1993); United States v. Barnes, 761 F.2d 1026, 1032-36 (5th Cir. 1985).
^[11] Id.

Imam from Georgia Sentenced for Providing Material Support to Hamas

Mohamed Shorbagi, the imam of a Georgia mosque, pleaded guilty to providing support to the militant group Hamas. He was sentenced, Tuesday, February 27, to more than seven years in prison, although he could have faced up to 15 years in prison.^[1]

At the sentencing, Shorbagi said he realized that some of his actions were wrong.^[2] He pleaded guilty in August to a charge of providing material support to Hamas and also testified in a Chicago case against a man identified by authorities as a Hamas operative.^[3]

Prosecutors asserted that between 1997 and 2001, Shorbagi provided financial support to Hamas through donations made to a charity called the Holy Land Foundation for Relief and Development.^[4] Hamas was designated by the United States as a foreign terrorist organization on Oct. 8, 1997.^[5] After that, and continuing until Dec. 4, 2001, Shorbagi provided financial support to Hamas and conspired with unnamed others to provide such support.^[6] The government asserts that Shorbagi knew some or all of the money was going to Hamas, because he was a Georgia representative for Hamas.^[7]

We have previously discussed the crime of providing material support for terrorism here.

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^[1] Daniel Yee, Ga. Imam Sentenced For Aiding Hamas, AP (via Houston Chronicle), February 28, 2007.
^[2] Id.
^[3] Id.
^[4] Id.
^[5] Dept. of Justice, Georgia Man Sentenced to Federal Prison For Material Support of Foreign Terrorist Group, PRNewswire-USNewswire, February 28, 2007.
^[6] Id.
^[7] Id.

U.S. Data Demands Anger E.U., Put SWIFT in a Bind

When reports surfaced about the secret U.S. program that examines international banking transactions, the debate in the U.S. was not about the program, but whether the news outlets were justified in revealing such information.^[1] Europeans had a different take on the program, where it raised security questions about whether European financial transactions were being illegally scrutinized by U.S. authorities.^[2]

The Society for Worldwide Interbank Financial Telecommunication (SWIFT) is a Belgian company that maintains the central interfaces that 8,000 banks worldwide rely on when trading currency and securities; its operations are essential to the operation of the European banking system.^[3] Because it is a Belgian company it is subject to Belgian laws on data privacy, however it is also subject to lawfully-issued U.S. jurisdiction because of its contacts, with the U.S.^[4]

After September 11, 2001, the U.S. Department of the Treasury issued subpoenas to SWIFT to find and shut down any money transfers that were going to terrorist groups.^[5] SWIFT complied, using data from its U.S. mirror, but not before being assured that the information is for the "exclusive purpose of terrorism investigations."^[6] However the E.U. saw things in a different light. “[This case]….has breached the trust and private lives of many millions of [Europeans;]…secret, routine and massive access [by U.S. authorities of banking data is] “unacceptable,” top European financial watchdog Peter Hustinx said in a report issued by the European Data Protection Supervisor.

Hustinx’s report puts pressure on the E.U. to rectify what has become an increasingly troublesome problem in how European nations cooperate with the U.S. on anti-terror measures. Strict E.U. data privacy laws have already posed problems in the past with the transfer of air passenger data^[7] from trans-Atlantic flights to the United States, which also violated E.U. rules.^[8]

SWIFT argues that it had no choice but to abide by U.S. subpoenas for bank data, and that if it had refused give information, it would have faced fines and possible criminal penalties such as jail time.^[9] However, in-so-doing SWIFT violated Belgian law.^[10] Last year the Belgian Data Privacy Commission (BDPC) looked into the situation and issued a report which found SWIFT in breach of Belgian law, The BDPC concluded that while the company did all it could to live up to Belgian, E.U. and U.S. regulations, it finds itself in a legal black hole.^[11] Fortunately, on December 13, 2006, the Belgian public prosecutor decided not to prosecute.^[12]

To make matters worse for the individuals caught in the legal morass, the European Parliament voted for a resolution Wednesday, February 14, that could make it even more difficult for European firms to store data in the U.S.^[13] Some European authorities, including the U.K.'s Information Commissioner, have declared the U.S. operation "illegal" and have begun to insist that financial institutions stop the warrant-less and unprotected transfers of private banking data to the U.S. authorities.^[14] The European Parliament seems to agree with him and has recommended that the only logical way to stop U.S. anti-terrorist investigators from illegally probing European financial transactions is to get the firm that handles the transfers(SWIFT) to remove its data from U.S. shores.^[15]

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^[1] Nate Anderson, Terrorist financing: What's illegal in Belgium is required in the US, ARS Technica, February 16, 2007.
^[2] Id.
^[3] Id.
^[4] Id.
^[5] Id.
^[6] Id.
^[7] EU expects tough talks with U.S. on air passenger data agreement, AP (via San Diego Union Tribune), January 31, 2007.
^[8] Watchdog calls on European Central Bank to end transfer of SWIFT bank data to U.S., AP (via CantonRep.com), February 2, 2007
^[9] Id.
^[10] Id.
^[11] Id.
^[12] Id.
^[13] Anderson, supra note 1.
^[14] Mark Ballard, UK Treasury Knew of US Hunt Through British Bank Data, The Register, February 16, 2007.
^[15] 'Pull European data from the US', The Register (via ElectricNews.net), February 15, 2007.

Missouri Based Charity has Assets Frozen

A federal appeals court on Tuesday upheld the government's decision to freeze the assets of a Missouri-based Islamic charity with alleged links to a foreign group that supports terrorism.^[1] The Treasury Department claims the Islamic American Relief Agency-USA, of Columbia, Mo., is an affiliate of a Sudanese charity - Islamic African Relief Agency- which is accused of financing al-Qaida and other terrorist organizations.^[2] The U.S. Court of Appeals for the District of Columbia Circuit upheld the lower court's 2005 decision finding that the charity is a branch of the Sudanese-based agency.^[3]

Records describe the Missouri charity as an ''affiliate'' and a ''partner'' of the Sudanese group, and the charity sought permission to transfer funds to the group.^[4] While the Missouri charity did not contest the terrorist designation of the Sudanese group, they claim that the two charities have independent leadership and bank accounts.^[5] In 2004, federal agents raided the group's headquarters in Columbia, Mo., as part of a criminal investigation; however, no criminal charges have been filed against the charity or any of its employees.^[6]

While the court found the unclassified evidence was ''not overwhelming,'' the three-judge panel noted that in its review of national security cases it is ''extremely deferential'' to the government.^[7] Furthermore the appeals court rejected the charity's argument that freezing its assets violated its rights under the Constitution.^[8] The law is clear that ''there is no constitutional right to fund terrorism……where an organization is found to have supported terrorism, government actions to suspend that support are not unconstitutional,'' the court said.^[9]

One of the more controversial aspects of the United States on terrorism is the designation of some charitable organizations as terrorist organizations.^[10] By designating these charities as terrorist organizations, the United States is able to freeze any assets held by those entities in the United States.^[11] Section 219 of the Immigration and Nationality Act states that the Secretary of State “is authorized to designate an organization as a foreign terrorist organization … if the Secretary finds that:”

• the organization is foreign
• the organization engages in terrorist activity, in terrorism, or retains the capability and intent to engage in terrorist activity or terrorism; and
• the terrorist activity or terrorism of the organization threatens the security of the US nationals or the national security of the US. ^[12]

The effect of the terrorist organization designation also has criminal ramifications under 18 U.S.C. § 2339B, which makes it a crime for a person to provide material support or resources to a terrorist organization.^[13] Although in order to violate this law, the person “must have knowledge that the organization is a designated terrorist organization.”^[14]

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^[1] Sam Hananel, Appeals Court Upholds Terrorist Designation for Islamic Charity, AP (Examiner.com), February 13, 2007.
^[2] Id.
^[3] Id.
^[4] Id.
^[5] Id.
^[6] Id.
^[7] Id.
^[8] Id
^[9] Id.
^[10] See James Dobbins, America Needs to Pick its Fights Carefully, Int’l Herald Tribune, May 2, 2006.
^[11] Pakistan Permits Charities US Calls Terrorist, Reuters (via Yahoo!). May 2, 2006.
^[12] 8 U.S.C. § 1189(a)(1) (2006).
^[13] 18 U.S.C. § 2339B(a)(1).
^[14] Id.

Computer System to Monitor Terrorist Financing

In 2004 the Intelligence Reform and Terrorism Prevention Act was passed requiring the U.S. Treasury Department to look into the feasibility of creating a computer system to assist in the against fight terrorist financing. ^[1] The Treasury Department released a report on Wednesday, January 17, and said the program is feasible; however it is also going to be a difficult undertaking.^[2] "On a technical level, development of information technology systems capable of receiving, storing, analyzing and disseminating an estimated 350 to 500 million records a year is a daunting task," the report said.^[3]

The computer system will be used to combat money laundering, terrorist financing, and other financial crimes. It is expected to take 3 1/2 years to build, and won't be finished by the end of this year as originally planned.^[4] The system will work to give authorities information on as many as 500 million electronic transfers of money in and out of the U.S.^[5]

Ideally, data on cross-border electronic money transfers would be technologically protected, secured, and would only be available to the Treasury Department's Financial Crimes Enforcement Network and the law enforcement and regulatory agencies authorized by law to assess the information.^[6]

At the very least, the information on these transfers will include the name and address of the sender, the amount of the transfer, any payment instructions, the name and address of the beneficiary and the beneficiary's financial institution.^[7]

The Intelligence Reform and Terrorism Prevention Act of 2004 established both the position of Director of National Intelligence and the National Counterterrorism Center.^[8] The Senate approved the bill 89-2, and President George W. Bush signed the Act into law on 17 December 2004.^[9] The Act is divided into eight Titles, as follows:^[10]
I. Reform of the intelligence community
II. Federal Bureau of Investigation
III. Security clearances
IV. Transportation security
V. Border protection, immigration, and visa matters
VI. Terrorism prevention
VII. Implementation of 9/11 Commission recommendations
VIII. Other matters

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^[1] Jeannine Aversa, Finance Tracking system ‘Daunting Task’, AP (FoxNews), January 17, 2007.
^[2] Id.
^[3] Id.
^[4] Id.
^[5] Id.
^[6] 31 U.S.C. § 310 (The Financial Crimes Enforcement Network is a bureau of the United States Department of the Treasury that combats money laundering, terrorist financing, and other financial crimes by compiling and analyzing information about financial transactions.)
^[7] Id.
^[8] Intelligence Reform and Terrorism Prevention Act of 2004, Pub. L. No. 108-458, 118 Stat. 3638
^[9] Id.
^[10] Id.