Counterterrorism: Conventional Tools for Unconventional Warfare

Terrorists seek our annihilation. They conspire by any and all means to obliterate us. Their methods are insidious. They exploit our laws and freedoms, which, when compared to their home countries, offer nearly unfettered movement throughout our society to plot and execute their attacks. Consequently, they see our laws and freedoms as avenues by which to achieve their means.

The purpose of this issue of the United States Attorneys’ Bulletin is to demonstrate how civil laws can be employed through forensic accounting tactics as new weapons in the counterterrorism arsenal. Paraphrasing the FBI's dictum, the United States should use any and all means to “[d]elay, disrupt or dismantle terrorist activities.”


Terrorists cannot function without money. Consequently, disrupting the flow of money disrupts terrorists’ activities is a very effective law enforcement strategy. However, interrupting the money flow is more complex than it would seem.

There are several federal criminal statutes, such as the USA PATRIOT Act, Public Law No. 107-56, Statute 272 (2001), that are designed to disrupt the flow of terrorist money. The USA PATRIOT Act made major changes to the currency reporting laws and the money laundering laws. In addition, the Bank Secrecy Act, 31 U.S.C. §§ 5311-5330, requires many organizations to file suspicious activity reports (SARS) in the event evidence of suspicious transactions ...

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