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Lindholm and Realuyo
When fully pursued by government agencies, it also includes knowledge about industry practices
and trends that can aid in the detection of illicit networks, the identification of vulnerabilities,
and the prediction of future attempts to circumvent the systems’ protections. Further,
the private sector shares best and worst practices in managing business operations, including
human capital, finance and accounting, and program management, which helps public sector
entities to improve the management of their own resources and to better understand the parallel
operational structures used by the illicit networks. Where applicable, the private sector
can impart an understanding of, and sense of preparedness regarding, promising technologies
and services on the horizon that have the potential to be exploited by illicit networks. Finally,
these groups are forums where interested parties can forge trust and partnerships prior to a
crisis—a resource- and time-conserving opportunity that can speed reaction to new threats.
In recognition of these advantages, the U.S. Government–sponsored Financial Intelligence
and Information Sharing (FIIS) Working Group regularly brings together executives
from financial institutions, intelligence agencies, academic institutions, law enforcement
agencies, and the military. Members of the forum informally discuss relevant topics, including
protection of critical financial infrastructure, prevention of fraud, and obstruction of terror
finance and money laundering. FIIS meetings and the relationships formed therein facilitate
information flow from government to industry and vice versa, and help bridge the cultural
gaps often found between the private and public sectors. The FIIS is an outgrowth of the
Financial Industry Committee of the Analyst/Private Sector Pilot Project, a project of the
Office of the Director of National Intelligence’s Office of Private Sector Partnerships. The
6-month pilot project united intelligence analysts with members of industry to facilitate better
information-sharing and protection of this facet of American critical infrastructure. 55
U.S. Special Operations Command’s (USSOCOM) Counter Threat Finance (CTF)
Working Group is another successful example of partnership both among agencies and
between the public and private sectors. In September 2001, USSOCOM was delegated the
responsibility to synchronize U.S. agencies focused on operations within the bounds of the
“War on Terror.” To achieve this goal, several interagency working groups were founded to
bring together action officers and policy leaders from U.S. agencies engaged in a select group
of activities. In 2005, USSOCOM recognized that Department of Defense (DOD) support
aimed at attacking the financial networks of terrorists and associated criminal support networks
represented a tangible opportunity to diminish the adversaries’ power and influence, and
incorporated CTF as one of these working groups. Meeting twice annually, the DOD CTF
Working Group creates personal connections and coordinates the planning and resource capabilities
resident within DOD that are lacking within other agencies and departments. Finding
that expertise from the financial and technology communities would benefit the discussion,
this particular segment of the synchronization mission took what was an unusual step and
declassified many of their meetings to allow experts from industry, think tanks, universities,
nonprofit organizations, and other relevant sectors to join the conversation. 56
On August 19, 2010, DOD Directive 5205.14, “DoD Counter Threat Finance Policy,” 57
formally designated the commander of USSOCOM as the Defense Department Lead
Component for synchronizing counterthreat finance activities across DOD in support of the
broader whole-of-government effort to tackle illicit funding activities. Furthermore, DOD
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