James Martin Center for Nonproliferation Studies
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Special Report: Financial Controls Emerge As Powerful Nonproliferation Tool; North Korea and Iran Targeted

Patrick Murphy - Independent Consultant, and Leonard S. Spector and Leah R. Kuchinsky - Monterey Institute Center for Nonproliferation Studies

Copyright © WMD Insights. All rights reserved

May 2007.

Acting under a series of U.S. laws and through a network of Western banks and international arrangements, the United States is making restrictive financial controls – including bans on financial assistance, the seizure of assets, the freezing of accounts, and denials of access to the international banking system – an important new component of efforts to combat the proliferation of weapons of mass destruction (WMD) and advanced delivery systems. The initiative has been reinforced by a series of UN Security Council Resolutions adopted in 2006 and early 2007, imposing financial sanctions on North Korea and Iran because of their nuclear- and missile-related activities, and by UN Security Council Resolution 1540, adopted in April 2004, which requires all states to implement financial, export, and other controls in order to curb illicit trafficking in WMD and related delivery systems. [1]

This Special Report is intended to familiarize readers with this emerging component of the nonproliferation regime, including key legal elements, enforcement practices, and relevant international arrangements, with particular attention to their use to curtail nuclear activities of concern in North Korea and Iran.

Introduction

The use of financial controls to bring pressure on states of proliferation concern made headline news in early April 2007, as North Korea and China, Japan, Russia, South Korea, and the United States began to implement their February 13, 2007, agreement under which Pyongyang agreed to eliminate its nuclear weapons program in return for a package of economic and diplomatic incentives. [2] As a precondition to taking the first step towards denuclearization, namely, the closure of a key nuclear reactor at Yongbyon, North Korea insisted on the release of $25 million in assets that had been frozen by a Macau bank under U.S. pressure. The United States had demanded the asset freeze in September 2005, after formally declaring the bank involved, Macau-based Banco Delta Asia (BDA), to be of “primary money laundering concern” because of its dealings with North Korean counterfeiting, drug trafficking, and other activities. [3] The U.S. declaration caused Western financial institutions to curtail business with the Macau bank and triggered a run on BDA by its customers that subsequently led Chinese authorities to take it over and freeze the accounts at issue. (Macau, a former Portuguese colony, is now a Special Administrative Region within China.) The fact that Pyongyang placed such high priority on regaining access to these assets suggests that the sanction may have been particularly effective in penalizing North Korea.

However, delays in making the resources available to North Korea until after the March 13 deadline, as provided in the February six-party agreement, led Pyongyang to postpone the shutdown of the Yongbyon reactor beyond the April 14 date specified in that understanding. [4] This left prospects for the agreement’s implementation uncertain as of late April. BDA’s future was also uncertain: in mid-March, even as the United States readied the release of the frozen assets to North Korea, it ordered all U.S. banks to cut ties with BDA, a move that may effectively put it out of business. [5]

Also in mid-March, the UN Security Council imposed a second round of sanctions against Iran after that country failed to respond substantively to Resolution 1737, adopted on December 23, 2006, which imposed an initial set of sanctions on Tehran in an effort to persuade it to halt certain sensitive nuclear activities, including the enrichment of uranium. [6] The December resolution banned states from providing financial assistance, investment, brokering, or other financial services, and the transfer of financial resources or services related to the supply, sale, transfer, manufacture, or use of nuclear- and missile-related items. It also required all UN member states to freeze the funds, other financial assets, and economic resources on their territories belonging to 22 listed entities or persons directly responsible for these Iranian programs. The second set of sanctions of March 24, 2007, which were imposed under Resolution 1747, extended the asset freeze to eight additional Iranian entities and ten additional persons involved in proliferation activities, among other measures.

As of late April 2007, by engaging the global banking community, utilizing U.S. legal authority controlling U.S. banks, and invoking the requirements imposed on UN member states under Resolution 1737, Washington had persuaded some 40 Western financial institutions to terminate or reduce business with the Iranian government and private sector. [7] By this point, however, these and other sanctions implemented under Resolutions 1737 and 1747 had yet to achieve their desired goal of persuading Iran to curtail its nuclear program and, indeed, on April 9, Iran announced it had achieved the ability to enrich uranium on an industrial scale for the first time. [8] Although inspectors from the International Atomic Energy Agency (IAEA) later declared this to be an exaggeration, they confirmed that Iran had significantly expanded its uranium enrichment activities. [9]

Nonproliferation-Specific Financial Controls

Executive Order 13382

Revelations of the extensive nuclear smuggling network operated by Pakistani nuclear scientist A.Q. Khan from the late 1980s until it was uprooted in 2003 led the U.S. government to adapt its pre-existing financial controls enforcement effort to focus on the proliferation threat. Since 1998, U.S. financial law enforcement agencies had had the ability to act against proliferators like Khan for the specific crime of money laundering. On June 29, 2005, however, President Bush issued Executive Order (E.O.) 13382, authorizing U.S. agencies to block the assets of any person (a term including individuals and corporate entities) materially assisting in the proliferation of WMD or missile delivery systems. [10] Specifically, the 2005 executive order authorized the blocking of the assets of “any foreign person”

… determined by the Secretary of State, in consultation with the Secretary of the Treasury, the Attorney General, and other relevant agencies, to have engaged, or attempted to engage, in activities or transactions that have materially contributed to, or pose a risk of materially contributing to, the proliferation of weapons of mass destruction or their means of delivery (including missiles capable of delivering such weapons), including any efforts to manufacture, acquire, possess, develop, transport, transfer or use such items, by any person or foreign country of proliferation concern…. [11]

The executive order also authorized the asset freeze to be imposed on any person (foreign or domestic) determined by the Secretary of the Treasury, in consultation with the Secretary of State, the Attorney General, and other relevant officials, to have provided, or attempted to provide, financial, material, technological, or other support for, or goods or services in support of, any activity or transaction materially contributing to proliferation. An annex at the end of the order listed one Syrian, three North Korean, and four Iranian entities as immediately subject to the asset freeze, including the widely known Atomic Energy Organization of Iran. [12]

The new focus was highlighted in the budget for the U.S. Treasury Department for fiscal year 2007, submitted by President George W. Bush to Congress on February 8, 2006, which declared, “The President’s Budget places a priority on funding [the Department of the] Treasury’s efforts to detect and disrupt . . . the proliferation of weapons of mass destruction . . . .” [13] By early January 2007, 23 entities and two individuals had been sanctioned under E.O. 13382. [14]

Egmont Group Initiative

E.O. 13382 is implemented as part of the U.S. government’s financial law enforcement effort, which is overseen by the Department of the Treasury’s Office of Terrorism and Financial Intelligence. Additional agencies, such as the Department of State and the Federal Bureau of Investigation, also contribute to the effort. The Office of Terrorism and Financial Intelligence has several subdivisions, including the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC). [15] FinCEN, founded in 1990, is the lead U.S. agency in the anti-money laundering effort and serves as the “financial intelligence unit” of the United States government. It is one of 100 such financial intelligence units in governments around the world that are members of the Egmont Group, an international body created in 1995 for the purpose of financial intelligence-sharing (and named for the Egmont-Arenberg palace in Belgium where it was established). [16]

Although originally created to fight money laundering, in the fall of 2005, the group broadened its mandate to include “tracking and freezing assets and blocking transactions of entities and persons engaged in proliferation activities and support,” a step that complemented the U.S. issuance of E.O. 13382 in June of that year. [17] No information is available regarding specific actions taken by the Egmont Group in support of its new mandate, but there is little doubt that it contributed to the coordination of international implementation of the Security Council sanctions against North Korea and Iran. [18]

Related Financial Controls

In the 1990s, the United States and like-minded partners created an elaborate network of financial controls focused on curbing money laundering and other transactions supporting criminal use of the international financial system. The network was significantly expanded after September 11, 2001, to focus also on blocking the financing of terrorist activities. In the United States, a key addition was enactment of the USA PATRIOT Act. As explained by the Treasury Department:

Title III of the USA PATRIOT Act amends the anti-money laundering provisions of the Bank Secrecy Act (BSA) to promote the prevention, detection and prosecution of international money laundering and the financing of terrorism. Section 311 authorizes the Secretary of the Treasury – in consultation with the Departments of Justice and State and appropriate Federal financial regulators – to find that reasonable grounds exist for concluding that a foreign jurisdiction, institution, class of transactions or type of account is of “primary money laundering concern” and to require U.S. financial institutions to take certain “special measures” against those jurisdictions, institutions, accounts or transactions. [19]

The PATRIOT Act provides for six increasingly punitive levels of “special measures,” up to and including:

. . . requiring U.S. financial institutions to terminate correspondent relationships with the designated entity. Such a defensive measure effectively cuts that entity off from the U.S. financial system. It has a profound effect, not only in insulating the U.S. financial system from abuse, but also in notifying financial institutions and jurisdictions globally of an illicit finance risk. [20]

Internationally, these counter-criminal and counter-terrorist activities are reinforced and coordinated by the 33-member Paris-based Financial Action Task Force (FATF) on Money Laundering, founded in 1989. The development of standards to combat terrorist financing was added to the mission of the organization in 2001. [21] UN Security Council Resolution 1617 of July 2005 effectively recognized the importance of the task force and “[s]trongly urge[d] all Member States to implement the comprehensive, international standards” embodied in the FATF’s Forty Recommendations on money laundering and its Nine Special Recommendations on Terrorist Financing.” [22]

Enforcement Practices: Different U.S. Tactics for North Korea and Iran

In the United States, the financial law enforcement process begins with information gathering. Domestic tools include the requirement that financial institutions provide FinCEN currency transaction reports (CTRs) for cash transactions of $10,000 or more (required by the Bank Secrecy Act of 1970, as amended), and suspicious activity reports (SARs), provided if a customer’s actions appear questionable. [23] Under U.S. law, the “financial institutions” obligated to report include securities brokers, money services businesses (money transmitters, sellers and redeemers of travelers’ checks, and currency exchanges), dealers in precious metals and stones, certain insurance companies, mutual fund companies, and casinos, as well as banks. [24]

FinCEN and OFAC use both overt and covert intelligence gathering when dealing with events taking place outside of the United States. In a program implemented shortly after September 11, 2001, for example, U.S. authorities monitor data from the Society for Worldwide Interbank Financial Telecommunication (SWIFT), the Belgian-based international network which transmits financial transactions and banking information around the world. [25]

After Treasury reviews the information it receives, it makes a determination as to whether the behavior of a specific foreign financial institution, entity, or country violates the standards of any of the legal authorities it administers. Thereafter, Treasury can impose appropriate sanctions, usually administered by FinCEN or OFAC.

In September 2005, for example, the Treasury Department used Section 311 of the USA PATRIOT Act to designate Banco Delta Asia as being of “primary money laundering concern” for its facilitation of illegal activities of the government of North Korea. Among other measures, the designation stated that FinCEN would act to “prohibit U.S. financial institutions from directly or indirectly establishing, maintaining, administering or managing any correspondent account in the United States for or on behalf of Banco Delta Asia.” [26] Even though this amounted to a mere blacklisting, without an explicit financial penalty (since BDA had no assets in the United States), the effect of Treasury’s action was significant, leading, as noted, to a run on the bank and to its takeover by Chinese banking authorities. Perhaps even more important was the “ripple effect,” as described by Treasury Under Secretary for Terrorism and Financial Intelligence (TFI) Stuart Levey in April 2006:

Press reports indicate that some two dozen financial institutions across the globe have cut back or terminated their financial dealings with North Korea, constricting the flow of dirty cash into Kim Jong Il’s regime. . . . TFI officials continue international outreach efforts to raise awareness of North Korea’s illicit conduct . . . . By all accounts, that outreach is working. [27]

These impacts apparently proved highly disagreeable to Pyongyang, and as highlighted earlier, it made release of the BDA assets a key precondition to implementation of the February 2007 six-party agreement on North Korea’s denuclearization.

In the case of North Korea, the United States used financial controls targeted on money laundering, rather than on proliferation per se, seeking, in the first instance, to halt BDA’s support for North Korean counterfeiting and drug trafficking. However, because the imposition of these sanctions occurred in parallel with negotiations over the North Korean nuclear program, the U.S. sanctions became a central element in this bargaining process, where U.S. diplomats exploited the promise to lift the sanctions as one of a number of important bargaining chips.

In the case of Iran, Washington has taken a different tack. It has used the proliferation-specific authority provided under E.O 13382, in conjunction with the parallel mandate of paragraph 6 of UN Security Council Resolution 1737 – requiring states to deny Iran any financial assistance, or the transfer of any financial resources or services related to Iran’s nuclear and missile programs – to apply pressure on the Iranian government to curtail its sensitive nuclear and missile activities.

Among other measures, the United States has focused these sanctions on Iran’s fifth largest state-owned bank, Bank Sepah. On January 7, two weeks after the adoption of Resolution 1737, the Treasury Department “designat[ed]” Bank Sepah as “a supporter of [Iranian] WMD proliferation” because it was providing direct and extensive financial services to Iranian missile development entities. As the legal basis for its action, the Treasury Department specifically cited “our authority aimed at combating proliferation, Executive Order 13382,” and the requirements of Resolution 1737. [28]

The impacts of the Department’s action and its subsequent efforts to convince European countries and banks to follow suit were quickly observed in Tehran. The January 27 edition of the reformist daily E’temad-e Melli, published in Tehran, quoted an international banker in Tehran as saying that,

“‘Americans are systematically trying to destroy Iran’s reputation. They have waged a kind of economic war.’” [29] Noting that Iranian President Mahmoud Ahmadinejad had belittled the American economic intervention, the newspaper went on to comment that:
Regardless of Ahmadinejad’s position, Iran’s economy is under siege and the situation is deteriorating with each passing day. It seems that the country has some tough days ahead. The EU [European Union] announced that it plans to move forward with sanctions in early February. But while the severity of the sanctions is unknown, one thing is certain and that is the damaging psychological effects of the word ‘sanction,’ the signs of which are already appearing. [30]

In early February 2007 the London Economist echoed this theme, stating:

. . . officials from America’s Treasury Department have been criss-crossing the globe to persuade governments and banks to curb their business with Iran. As a result, Iran is finding it increasingly expensive to borrow money. . .. Even legitimate businesses are suffering, as foreign banks find it hard to be certain that the transactions they handle are not being diverted, for nefarious purposes, through Iran’s network of front companies. All dollar exchanges, including small transfers for private individuals, have become extremely complicated, and it is very hard to use a credit card to buy online from inside Iran. [31]

On February 23, The Washington Post’s David Ignatius quoted a British official as saying, “The financial sanctions [on Iran] have had a real impact. They lead to a general insecurity about economic viability.” [32] A few days later, Ignatius noted, “The new sanctions are toxic because they effectively limit a country’s access to the global ATM. In that sense, they impose – at last – a real price on countries such as North Korea and Iran that have blithely defied U.N. resolutions on proliferation.” He went on to quote Treasury Under Secretary Levey as saying, “What’s the goal? To create an internal debate about whether these policies [of defiance] make sense. And that’s happening in Iran. People with business sense realize that this conduct makes it hard to continue normal business relationships.” [33]

Conclusion

As of late April 2007, there was considerable evidence that the imposition of financial sanctions against North Korea and Iran has been costly for both countries. It remains to be seen, however, whether these sanctions, and related U.S. and international efforts, will ultimately achieve the goal of curtailing dangerous nuclear and associated missile programs in the two states.

Patrick Murphy – Independent Consultant, and Leonard S. Spector and Leah R. Kuchinsky – Monterey Institute Center for Nonproliferation Studies

SOURCES AND NOTES
[1] See UN Security Council Resolution (UNSCR) 1695, July 15, 2006, paragraph 4: “4. [The Council…] Requires all Member States, in accordance with their national legal authorities and legislation and consistent with international law, to exercise vigilance and prevent the procurement of missiles or missile related-items, materials, goods and technology from the DPRK, and the transfer of any financial resources in relation to DPRK’s missile or WMD programs…,” http://www.un.org/Docs/sc/unsc_resolutions06.htm; [View Article] UNSCR 1718, October 14, 2006, paragraph 8 (d): “(d) All Member States shall, in accordance with their respective legal processes, freeze immediately the funds, other financial assets and economic resources which are on their territories at the date of the adoption of this resolution or at any time thereafter, that are owned or controlled, directly or indirectly, by the persons or entities designated by the Committee or by the Security Council as being engaged in or providing support for, including through other illicit means, DPRK’s nuclear-related, other weapons of mass destruction-related and ballistic missile-related programs, or by persons or entities acting on their behalf or at their direction, and ensure that any funds, financial assets or economic resources are prevented from being made available by their nationals or by any persons or entities within their territories, to or for the benefit of such persons or entities…,” http://www.un.org/Docs/sc/unsc_resolutions06.htm; [View Article] UNSCR 1737, December 23, 2006, paragraph 6: “6. [The Council]… Decides that all States shall also take the necessary measures to prevent the provision to Iran of any technical assistance or training, financial assistance, investment, brokering or other services, and the transfer of financial resources or services, related to the supply, sale, transfer, manufacture or use of the prohibited items, materials, equipment, goods and technology specified in paragraphs 3 and 4 above…, ”http://www.un.org/Docs/sc/unsc_resolutions06.htm; [View Article] UNSCR 1737, December 23, 2006, paragraph 12: “12. [The Council] Decides that all States shall freeze the funds, other financial assets and economic resources which are on their territories at the date of adoption of this resolution or at any time thereafter, that are owned or controlled by the persons or entities designated in the Annex, as well as those of additional persons or entities designated by the Security Council or by the Committee as being engaged in, directly associated with or providing support for Iran’s proliferation sensitive nuclear activities or the development of nuclear weapon delivery systems, or by persons or entities acting on their behalf or at their direction, or by entities owned or controlled by them, including through illicit means, and that the measures in this paragraph shall cease to apply in respect of such persons or entities if, and at such time as, the Security Council or the Committee removes them from the Annex, and decides further that all States shall ensure that any funds, financial assets or economic resources are prevented from being made available by their nationals or by any persons or entities within their territories, to or for the benefit of these persons and entities…,” http://www.un.org/Docs/sc/unsc_resolutions06.htm; [View Article] UNSCR 1747, March 24, 2007, paragraph 4: “4. [The Council…] Decides that the measures specified in paragraphs 12, 13, 14 and 15 of resolution 1737 (2006) shall apply also to the persons and entities listed in Annex I to this resolution…,”http://www.un.org/Docs/sc/unsc_resolutions07.htm; [View Article] and UNSCR 1540, April 28, 2004, paragraph 3 (d): “(d) [The Council…decides that all UN member states shall …] Establish, develop, review and maintain appropriate effective national export and trans-shipment controls over such items, including appropriate laws and regulations to control export, transit, trans-shipment and re-export and controls on providing funds and services related to such export and trans-shipment such as financing, and transporting that would contribute to proliferation, as well as establishing end-user controls; and establishing and enforcing appropriate criminal or civil penalties for violations of such export control laws and regulations…,”
http://www.un.org/Docs/sc/unsc_resolutions04.html. [View Article]
[2] “How U.S. Used a Bank to Punish North Korea,” Wall Street Journal, April 12, 2007, Glenn Kessler, “To Prod N. Korea, U.S. Relents in Counterfeiting Case,” Washington Post, April 11, 2007; http://www.washingtonpost.com/wp-dyn/content/article/2007/04/10/AR2007041001805_pf.html; [View Article] Donald Greenlees and David Lague, “Trail Led to Macau as Focus of North Korean Corruption,” New York Times, April 13, 2007, http://www.nytimes.com/2007/04/13/world/asia/13macao.html. [View Article]
[3] See sources in [2]; “Treasury Designates Banco Delta Asia as Primary Money Laundering Concern under USA PATRIOT Act,” Press Room, U.S. Treasury, JS-2720, September 15, 2005, http://www.ustreas.gov/press/releases/js2720.htm. [View Article] See also Daniel Pinkston and Dave Kim, “North Korea’s Financial Network Is the Target of Wide-Ranging Nonproliferation Sanctions,” WMD Insights, December 2006/January 2007, http://wmdinsights.org/I11/I11_EA1_NKFinancial.htm. [View Article]
[4] Kwang-Tae Kim, “South Korea to Send Food Aid to North,” Associated Press, April 22, 2007, http://news.yahoo.com/s/ap/20070422/ap_on_re_as/koreas_nuclear. [View Article]
[5] Demetri Sevastopulo and Tom Mitchell, “U.S. to Finalize Sanctions on Macau Bank,” Financial Times, March 13, 2007, http://www.ft.com/cms/s/2ef9143c-d1ba-11db-b921-000b5df10621.html. [View Article]
[6] “UN Powers Agree to Iran Nuclear Sanctions,” Nuclear Weapons, Global Security Newswire, March 15, 2007, http://www.nti.org/gsn/article/un-powers-agree-to-iran-nuclear-sanctions/. [View Article] See sources in [1].
[7] Robin Wright, “Iran Feels Pinch as Major Banks Curtail Business,” Washington Post, March 26, 2007, http://www.washingtonpost.com/wp-dyn/content/article/2007/03/25/AR2007032501084.html. [View Article]
[8] “Iran Claims to Begin ‘Industrial Scale’ Uranium Enrichment,” Associated Press, April 9, 2007, http://www.foxnews.com/story/0,2933,264864,00.html. [View Article]
[9] “Iran Enrichment ‘In Early Stages,’ ” BBC News, April 12, 2007, http://news.bbc.co.uk/2/hi/middle_east/6549185.stm; [View Article] “Russia Says No Sign Of Iranian Industrial Enrichment,” Reuters, April 10, 2007, http://today.reuters.com/news/articlenews.aspx?type=worldNews&storyid=2007-04-10T100817Z_01_L10365283_RTRUKOC_0_US-IRAN-NUCLEAR-RUSSIA.xml&src=rss&rpc=22. [View Article]
[10] The White House, “Executive Order: Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters [E.O. 13382],” June 29, 2005, http://www.whitehouse.gov/news/releases/2005/06/print/20050629.html. [View Article]
[11] Ibid.
[12] Ibid.
[13] Budget of the United States Government: FY 2007, Department of the Treasury, www.gpoaccess.gov/usbudget/fy07/pdf/budget/treasury.pdf. [View Article]
[14] U.S. Department of Treasury Press Release, “Iran’s Bank Sepah Designated by Treasury-Sepah Facilitating Iran’s Weapons Program,” January 9, 2007, http://www.treas.gov/press/releases/hp219.htm. [View Article]
[15] “Fighting War on Terror a Priority for U.S. Treasury Department,” International Security, U.S. Department of State, http://usinfo.state.gov/is/Archive/2006/Feb/07-249618.html. [View Article]
[16] The Egmont Group website can be found at http://www.egmontgroup.org/. The group’s members are listed at http://www.egmontgroup.org/list_of_fius.pdf. For an introduction to the workings of the group, see, “Egmont: Information Paper on Financial Intelligence Units and the Egmont Group,” p. 3, http://www.fatf-gafi.org/dataoecd/44/56/34345425.pdf. [View Article]
[17] Andrew K. Semmel, “Effective Multilateralism: The U.S. Strategy for Dealing with Global Nuclear Proliferation,” Deputy Assistant Secretary of State for Nonproliferation, Address to the National Strategy Forum, Chicago, Illinois, November 14, 2005, http://www.nti.org/e_research/official_docs/dos/state111405Semmel.pdf.
[18] An informal organization of like-minded nations, the Egmont Group has no secretariat and is supported by a rotating administrative staff.
[19] “Treasury Designates Banco Delta Asia as Primary Money Laundering Concern under USA PATRIOT Act,” see source in [3].
[20] “Testimony of Stuart Levey, Under Secretary, Terrorism and Financial Intelligence, U.S. Department of the Treasury,” Senate Appropriations Subcommittee on Transportation, Treasury, the Judiciary, Housing and Urban Development, and Related Agencies, April 6, 2006, JS-4163, p. 5, http://www.treas.gov/press/releases/js4163.htm.
[View Article]
[21] “About FATF,” Financial Action Task Force Against Money Laundering website, http://www.fatf-gafi.org/pages/0,2966,en_32250379_32236836_1_1_1_1_1,00.html. [View Article]
[22] UN Security Council Resolution 1617, July 29, 2005, http://www.un.org/Docs/sc/unsc_resolutions05.htm.
[View Article]
[23] “Bank Secrecy Act: Comptroller’s Handbook, September 2000,” Comptroller of the Currency, Administrator of National Banks, revised for web publication, December 2000, Consumer Compliance Examination, CCE-BSA pp. 7, 8, http://www.occ.treas.gov/handbook/bsa.pdf. [View Article]
[24] “Prepared Remarks of Robert W. Werner, Director, Financial Crimes Enforcement Network,” before the American Bankers Association/American Bar Association Money Laundering Enforcement Conference, October 9, 2006, Washington, D.C., p. 2, http://www.fincen.gov/werner_statement_10092006.html. [View Article]
[25] This particular intelligence-gathering effort, which was made public by the media in June 2006, has raised issues concerning the privacy of financial transactions. See, Eric Lichtblau and James Risen, “Bank Data Is Sifted by U.S. in Secret to Block Terror,” New York Times, June 23, 2006, and the reply of the U.S. Treasury Department, “Terrorist Finance Tracking Program Fact Sheet,” June 23, 2006, JS-4340, http://www.ustreas.gov/press/releases/js4340.htm.
[View Article]
[26] “Treasury Designates Banco Delta Asia as Primary Money Laundering Concern under USA PATRIOT Act,” see source in [3]; “Testimony of Stuart Levey, Under Secretary, Terrorism and Financial Intelligence, U.S. Department of the Treasury,” see source in [20].
[27] “Testimony of Stuart Levey, Under Secretary, Terrorism and Financial Intelligence, U.S. Department of the Treasury,” see source in [20].
[28] “Prepared Remarks of Stuart Levey, Under Secretary for Terrorism and Financial Intelligence, On the Designation of Bank Sepah for Facilitating Iran’s Weapons Program,” U.S. Treasury Press Room, HP-220, January 9, 2007, p. 1, http://www.ustreas.gov/press/releases/hp220.htm. [View Article]
[29] “Persian Press: EU Joining US in Banning Business with Iranian Banks,” E’temad-e Melli, January 27, 2007, p. 5, OSC document IAP20070205011007.
[30] Ibid.
[31] “Dealing with Iran: a Countdown to Confrontation: Can Anything Deter Iran from its Nuclear Ambitions?” The Economist, February 8, 2007.
[32] David Ignatius, “Signals From Tehran,” The Washington Post, February 23, 2007, p. A19.
[33] David Ignatius, “U.S. Sanctions with Teeth,” The Washington Post, February 28, 2007, http://www.washingtonpost.com/wp-dyn/content/article/2007/02/27/AR2007022701157_pf.html. [View Article]