DE RUEHC #1801 3641337
ZNY SSSSS ZZH
O 301328Z DEC 09
FM SECSTATE WASHDC
TO RUEHAD/AMEMBASSY ABU DHABI IMMEDIATE 0000
RUEHIL/AMEMBASSY ISLAMABAD IMMEDIATE 0000
RUEHKU/AMEMBASSY KUWAIT IMMEDIATE 0000
RUEHRH/AMEMBASSY RIYADH IMMEDIATE 0000
INFO RUEHDO/AMEMBASSY DOHA IMMEDIATE 0000
RUEATRS/TREASURY DEPT WASHINGTON DC IMMEDIATE 0000
S E C R E T STATE 131801
EO 12958 DECL: 12/28/2019
TAGS EFIN, KTFN, PTER, PINR, PREL, PK, KU, AE, QA, SA
SUBJECT: TERRORIST FINANCE: ACTION REQUEST FOR SENIOR
LEVEL ENGAGEMENT ON TERRORISM FINANCE
REF: A. (A) STATE 112368 B. (B) RIYADH 1499 C. (C) KUWAIT 1061 D. (D) KUWAIT 1021 E. (E) ABU DHABI 1057 F. (F) DOHA 650
G. (G) ISLAMABAD 2799
Classified By: EEB/ESC Deputy Assistant Secretary Douglas C. Hengel for reasons 1.4 (b) and (d).
1. (U) This is an action request cable. Please see para 3.
2. (S/NF) Summary: In August 2009, Special Representative to the President for Afghanistan and Pakistan (S/SRAP)
Ambassador Richard Holbrooke in coordination with the Department of Treasury established the interagency Illicit Finance
Task Force (IFTF). The IFTF is chaired by Treasury A/S David Cohen. It focuses on disrupting illicit finance activities
in Afghanistan and Pakistan and the external financial/logistical support networks of terrorist groups that operate
there, such as al-Qa’ida, the Taliban, and Lashkar e-Tayyiba (LeT). The IFTF’s activities are a vital component of the
USG’s Afghanistan and Pakistan (Af/Pak) strategy dedicated to disrupting illicit finance flows between the Gulf
countries and Afghanistan and Pakistan. The IFTF has created a diplomatic engagement strategy to assist in the
accomplishment of this objective. The strategy focuses on senior-level USG engagement with Gulf countries and Pakistan
to communicate USG counterterrorism priorities and to generate the political will necessary to address the problem. The
IFTF has drafted talking points for use by all USG officials in their interactions with Gulf and Pakistani
interlocutors. These points focus on funding for terrorist groups threatening stability in Afghanistan and Pakistan and
targeting coalition soldiers. These points have been cleared through the relevant Washington agencies.
3. (SBU) Action request: Drawing on the background materials for respective countries, and in preparation for the
upcoming visits by Ambassador Holbrooke and Treasury U/S Levey in January, the Department requests all action posts
deliver the general talking points in paras 5-6 and country specific talking points contained in the following paras:
(1) Saudi Arabia ) para 8, (2) Kuwait ) para 10, (3) UAE ) para 12, and (4) Pakistan ) para 13. The talking points
should be delivered by Ambassadors/Charge D’Affaires.
4. (C) In response to State 112368, the Department has received responses from Embassies Riyadh, Kuwait, Abu Dhabi,
Doha, and Islamabad regarding the resource capabilities devoted towards these efforts. The Department also received each
Mission’s evaluation of the effectiveness of host country institutions working on combating terrorism financing along
with post’s recommendations on ways forward.
General talking points for all Embassies
5. (SBU) Threat financing:
Cutting off the flow of funds to terrorist organizations and achieving stability in Af/Pak are top U.S. priorities.
These objectives require effective actions against terrorist fundraising in the Gulf by al-Qa’ida, the Taliban, LeT, and
other Af/Pak-based violent extremist groups, all of which undermine the security of the entire international community.
We will not succeed without your cooperation.
Long term success in combating terrorist financing requires a comprehensive, strategic approach that includes the
(1) aggressive action to identify, disrupt and deter terrorist donors, fundraisers and facilitators;
(2) appropriate legal measures, including effective prosecution, to hold terrorist financiers and facilitators publicly
accountable and to send a strong message of deterrence to current and would-be donors that their actions face
significant legal and social repercussions.
(3) strong oversight of charities, including their overseas branches, to ensure that these organizations are not
supporting terrorist and extremist elements;
(4) strict enforcement of UN 1267 sanctions; and
(5) full compliance with international anti-money laundering and combating the financing of terrorism (AML/CFT)
standards, including vigorous enforcement.
6. (SBU) Charities:
The United States strongly supports legitimate charitable activities and is a strong proponent of private charitable
We recognize and admire the emphasis placed on charity within Islam and we seek to work cooperatively with governments
and organizations in the Islamic world to ensure that legitimate charitable activities thrive.
At the same time, we want to increase our cooperative efforts to ensure that extremists and terrorists do not exploit
Country-specific background material and talking points
7. (U) Saudi Arabia background
(S/NF) While the Kingdom of Saudi Arabia (KSA) takes seriously the threat of terrorism within Saudi Arabia, it has been
an ongoing challenge to persuade Saudi officials to treat terrorist financing emanating from Saudi Arabia as a strategic
priority. Due in part to intense focus by the USG over the last several years, Saudi Arabia has begun to make important
progress on this front and has responded to terrorist financing concerns raised by the United States through proactively
investigating and detaining financial facilitators of concern. Still, donors in Saudi Arabia constitute the most
significant source of funding to Sunni terrorist groups worldwide. Continued senior-level USG engagement is needed to
build on initial efforts and encourage the Saudi government to take more steps to stem the flow of funds from Saudi
Arabia-based sources to terrorists and extremists worldwide.
(S/NF) The USG engages regularly with the Saudi Government on terrorist financing. The establishment in 2008 of a
Treasury attache office presence in Riyadh contributes to robust interaction and information sharing on the issue.
Despite this presence, however, more needs to be done since Saudi Arabia remains a critical financial support base for
al-Qa’ida, the Taliban, LeT, and other terrorist groups, including Hamas, which probably raise millions of dollars
annually from Saudi sources, often during Hajj and Ramadan. In contrast to its increasingly aggressive efforts to
disrupt al-Qa’ida’s access to funding from Saudi sources, Riyadh has taken only limited action to disrupt fundraising
for the UN 1267-listed Taliban and LeT-groups that are also aligned with al-Qa’ida and focused on undermining stability
in Afghanistan and Pakistan.
(S/NF) Saudi Arabia has enacted important reforms to criminalize terrorist financing and restrict the overseas flow of
funds from Saudi-based charities. However, these restrictions fail to include organizations8 such as XXXXXXXXXXXX Intelligence suggests that these groups continue to send money overseas and, at
times, fund extremism overseas. In 2002, the Saudi government promised to set up a Committee8 that would address this issue, but has yet to do so. The establishment of such a mechanism, however, is
secondary to the primary U.S. goal of obtaining Saudi acknowledgement of the scope of this problem and a commitment to
take decisive action.
(S/NF) Department note: The Department received post’s comments regarding embassy staffing at Riyadh and recommendations
for enhancing bilateral cooperation (ref B). The Department agrees with post’s recommendation that the U.S. must
reinforce, on a political level, the Saudi Arabia Government’s recent acknowledgement that terrorist groups other than
al-Qa’ida are a threat both to it and to regional stability. The Department also supports post’s assessment that
consistent engagement, including the exchange of actionable intelligence, by senior USG officials is paramount. We plan
to discuss these issues with the SAG during upcoming senior-level USG visits.
8. (U) Saudi Arabia talking points
(S/REL USA, SAU) We recognize your government’s efforts to disrupt al-Qa’ida networks in the Kingdom and we reaffirm our
commitment to support the Saudi government in its actions on terror finance. We encourage your government to continue
efforts against al-Qa’ida and stress the importance of sharing and acting on information related to terrorist financing.
(S/REL USA, SAU) We note your concerns with fundraising in the Kingdom by al-Qa’ida and other terrorist groups and urge
decisive action to enforce the UN 1267-mandated asset freeze against Taliban and LeT fundraising similar to Saudi
efforts to enforce UN 1267 sanctions and take other appropriate action to target al-Qa’ida.
(S/REL USA, SAU) We underscore that the Taliban and LeT are aligned with al-Qa’ida and that your government’s support
for disrupting the financing of these groups is critical to the stability of Afghanistan, Pakistan and the broader
Central and South Asian region. We emphasize the need to prevent the Taliban from using the cover of reconciliation
talks to raise funds.
(S/REL USA, SAU) We urge your government to assume responsibility for the overseas operations of charities and NGOs
headquartered in the Kingdom. We encourage you to prevent terrorists and their supporters from exploiting religious
events (Hajj, Umrah, Ramadan) to raise funds. We acknowledge the recent adoption of stricter financial controls on
charities, but urge greater regulation and oversight of the Saudi charitable sector.
(S/REL USA, SAU) We would like to stress our interest in broadening and deepening this dialogue and information exchange
as we still lack detailed information on the ultimate sources of terrorist financing emanating from the Kingdom. We
commend your government for recent efforts to put terrorists and terrorist financiers on trial, and we encourage you to
publicize details of prosecutions to maximize the deterrent effects.
(S/REL USA, SAU) You have had success in detaining and deterring financial facilitators. However, we encourage your
government also to focus on the long-term and more fundamental goal of dissuading donors from funding violent extremism.
(S/REL USA, SAU) We commend your government’s effort over the past several years to use the media, internet, and other
forms of public outreach to discourage extremism. We emphasize that a critical component in this campaign is cutting off
the flow of funds from Saudi Arabia to foreign religious, charitable, and educational organizations that propagate
violent extremist ideologies to vulnerable populations.
9. (U) Kuwait background
(S/NF) The USG has consistently engaged the Government of Kuwait (GOK) about the specific activities of terrorist
financiers in country, Kuwaiti charities financing terrorism abroad, and Kuwait’s lack of a comprehensive anti-money
laundering and counter-terrorist financing regime. While the GOK has demonstrated a willingness to take action when
attacks target Kuwait, it has been less inclined to take action against Kuwait-based financiers and facilitators
plotting attacks outside of Kuwait. Al-Qa’ida and other groups continue to exploit Kuwait both as a source of funds and
as a key transit point.
(S/NF) The GOK has undertaken a number of initiatives to curb terrorist financing in the charitable sector (ending
direct cash donations, increasing monitoring and supervising mosques and charitable organizations, and enhancing
enforcement of regulations by a Ministry of Social Affairs task force). It also recently arrested some Kuwait-based
al-Qa’ida facilitators, but it is too early to assess whether this marks a change in Kuwaiti policy of co-opting
terrorists as a means of deflecting potential attacks against Kuwaiti interests.
(S/NF) Kuwait’s law prohibits efforts to undermine or attack Arab neighbors, a basis for the prosecution of al-Qa’ida
facilitators, Kuwait remains the sole Gulf Cooperation Council (GCC) country that has not criminalized terrorist
financing. The GOK faces an uphill battle to implement comprehensive terror finance legislation due to a lack of
parliamentary support. However the government is also not currently prepared to push hard on this issue. The GOK at
times has obstructed or been slow to enforce UN-mandated asset freezes of Kuwait-based entities.
(S/NF) A particular point of difference between the U.S. and Kuwait concerns Revival of Islamic Heritage Society (RIHS).
In June 2008 the USG domestically designated all RIHS offices RIHS under Executive Order 13224 for providing financial
and material support to al-Qa’ida and UN 1267-listed al-Qa’ida affiliates, including Lashkar e-Tayyiba, Jemaah
Islamiyah, and Al-Itihaad al-Islamiya. The United States nominated RIHS for listing under UNSCR 1267 but Indonesia
placed a technical hold on the RIHS listing due concerns regarding RIHS’s presence in Indonesia. Libya also placed a
hold - probably at Kuwait’s behest - citing insufficient information on RIHS’s activities. Indonesia has rotated off the
United Nation’s Security Council so only Libya’s hold on RIHS remains. (Department note: Libya’s hold will drop in 2010
unless one of the newly elected UNSC Members places a hold on our request to list RIHS.) In Kuwait, RIHS enjoys broad
public support as a charitable entity. The GOK to date has not taken significant action to address or shut down RIHS’s
headquarters or its branches, which is consistent with GOK tolerance of similar behavior by Kuwaiti citizens and
organizations as long as the behavior occurs or is directed outside of Kuwait.
(S/NF) Department note: The Department appreciates postVs thorough description of the staffing situation at Mission
Kuwait (ref B). The Department commends U.S. Embassy Kuwait for taking an active approach in proposing a strategy to
build GOK capacity in combating financial crimes through training and seminars focused on legislation and law
enforcement (ref C). The opportunity to engage the GOK on improving its capabilities to deal with financial crimes is
enthusiastically welcomed by agencies in Washington. Washington agencies appreciate post’s assessment and identification
of several focal areas that deal with financial crimes. These goals closely track the work of the IFTF Capacity Building
Working Group. The Department commends Embassy Kuwait’s recent support of Kuwait’s National Anti Money Laundering
Committee’s AML conference in early December 2009. In response to post’s request, the Department will work with relevant
members of the Washington inter-agency to provide comments and feedback to the draft of Kuwait’s amended AML law.
10. (U) Kuwait talking points
(S/REL USA, KWT) We appreciate the breadth and depth of our strong bilateral relationship. We would like to see our
cooperation on counter-terrorist financing improve to a level that matches our excellent cooperation in many other
areas. In this respect, the recent Kuwait anti-money laundering conference held in Kuwait is a positive step forward.
(S/REL USA, KWT) Our information indicates that Kuwaiti donors serve as an important source of funds and other support
for al-Qa’ida and other terrorist groups. The arrest in August of six Kuwaiti men who were plotting terrorist attacks on
U.S. and Kuwait interests marks an important step in enhanced counterterrorism cooperation. We encourage you to keep up
the positive momentum.
(S//REL USA, KWT) We underscore that the Taliban and LeT are aligned with al-Qaida and that your government’s support
for disrupting the financing of these groups is critical to the stability of Afghanistan, Pakistan and the broader
Central and South Asian region. We emphasize the need to prevent the Taliban from using the cover of reconciliation
talks to raise funds.
(S/REL USA, KWT) We appreciate your government’s generosity for a wide range of important causes and for the positive
contributions made by Kuwaiti charities. We commend Kuwait for some of the initiatives taken to enhance oversight of
charitable donations, but we need you to do more to prevent the financing of terrorism abroad from Kuwaiti soil.
(S/REL USA, KWT) Our goal is to work more closely with your government to separate and protect legitimate charitable
activity from those that fund terror. We have particular concerns about their foreign activities.
(S/REL USA, KWT) We remain concerned that the continued absence of counterterrorism legislation criminalizing terrorist
financing will continue to prevent effective counterterrorist efforts.
(S/REL USA, KWT) We urge your government to prioritize the passage of counterterror finance legislation. Robust and
comprehensive anti-money laundering and counterterror financing laws will enhance your government’s ability to prosecute
those seeking to undermine Kuwait’s security, but will also enhance the reputation of Kuwait’s financial sector as a
(S/REL USA, KWT) If raised, Kuwait RIHS: We have shared our concerns with your government regarding RIHS on numerous
occasions. We designated the organization in the United States as a specially designated terrorist entity based on
information that RIHS funds have supported terrorist groups in various regions of the world. The USG is not alone in its
concern; six other governments (Albania, Azerbaijan, Bangladesh, Bosnia-Herzegovina, Cambodia, and Russia) have taken
enforcement action against RIHS branches in their countries.
(S//REL USA, KWT) We would welcome the opportunity to work more closely with you to ensure that RIHS and other charities
cannot be used to support terrorists.
11. (U) United Arab Emirates background
(S/NF) UAE-based donors have provided financial support to a variety of terrorist groups, including al-Qa’ida, the
Taliban, LeT and other terrorist groups, including Hamas. Washington agencies note, however, that they have limited
information on the identity of Taliban and LeT donors and facilitators in the UAE. Hence there is limited information to
be shared with local interlocutors. Nonetheless, the point can be emphasized that the UAE’s role as a growing global
financial center, coupled with weak regulatory oversight, makes it vulnerable to abuse by terrorist financiers and
(S/NF) Department Note: The Department has received post’s comments regarding personnel staffing at Mission UAE and the
challenges post faces. The Department is supportive of the action plan laid out on engaging with the UAE on Taliban
finance issues (ref E). The Department assesses that a bilateral commitment by the United States and the UAE to focus on
weaknesses within its financial regulatory measures is an important step in making progress on strengthening UAE efforts
to disrupt potential terrorist financing.
12. (U) United Arab Emirates talking points
(S/REL USA, ARE) We appreciate the depth and breadth of our bilateral relationship. Since 2001, we have developed a
strong partnership with your government in countering financial support for al-Qa’ida, and more recently, in
constricting Iran’s ability to use UAE financial institutions to support its nuclear program.
(S/REL USA, ARE) We would like to extend our cooperation and partnership to efforts to deal with the threat represented
by Taliban and LeT fundraising in the UAE. We believe that the United States and UAE, which both have troops in the
field in Afghanistan, share a common interest in curtailing any Taliban or LeT fundraising activities and fully
implementing UN 1267 sanctions on such activities on behalf of these groups in the UAE.
(S/REL USA, ARE) However, we are pleased that concerns have been raised in the UAE regarding the Taliban and LeT
fundraising. We also commend the calls for increased vigilance, information sharing, and enforcement actions to disrupt
and deter this activity.
(S/REL USA, ARE) In our view, the alignment of the Taliban and LeT with al-Qa’ida means that our mutual efforts to
disrupt the financing of these groups also is critical to the stability of Afghanistan and Pakistan.
(S/REL USA, ARE) We emphasize the need to prevent the Taliban from using the cover of reconciliation talks to travel and
(S/REL USA, ARE) We appreciate your government’s willingness to work with the USG on cash courier interdiction and note
that such efforts are crucial to undermine al-Qa’ida, the Taliban, and other groups’ ability to exploit the UAE as a
fundraising and facilitation hub. We urge your government to strengthen its regulatory and enforcement regime to
interdict cash couriers transiting major airports.
13. (U) Pakistan background
(S/NF) Pakistan’s intermittent support to terrorist groups and militant organizations threatens to undermine regional
security and endanger U.S. national security objectives in Afghanistan and Pakistan. Although Pakistani senior officials
have publicly disavowed support for these groups, some officials from the Pakistan’s Inter-Services Intelligence
Directorate (ISI) continue to maintain ties with a wide array of extremist organizations, in particular the Taliban, LeT
and other extremist organizations. These extremist organizations continue to find refuge in Pakistan and exploit
Pakistan’s extensive network of charities, NGOs, and madrassas. This network of social service institutions readily
provides extremist organizations with recruits, funding and infrastructure for planning new attacks. On the
international stage, Pakistan has sought to block the UNSCR 1267 listings of Pakistan-based or affiliated terrorists by
requesting that China place holds on the nominations. China recently placed a technical hold on the designation of three
Pakistan-based or affiliated terrorists nominated by India, although China did not prevent the most recent
Pakistan-related U.S. designation nomination in June.
(S/NF) The Department has received post’s comments regarding personnel staffing and the detailed description of the
challenges faced by Embassy Islamabad in the area of terrorism finance (ref D). Department leaves it to post discretion
to determine which departments within the host government should receive the points provided in para 16 so that Pakistan
fully understands the priority the USG places on this issue.
14. (U) Pakistan talking points
(S/REL USA, PAK) Emphasize that Pakistan’s support for disrupting financing to the Taliban and LeT obligatory pursuant
to their obligations under UNSCR 1267 and successor resolutions, and is critical to achieving stability in Afghanistan
(S/REL USA, PAK) We are deeply concerned that Pakistan has failed to enact an AML/CTF law that meets APG/FATF standards.
As you may realize the FATF is currently engaged in a Co-Operation Review Group8 exercise, that is likely to have very negative multilateral repercussions if the Parliament
does not pass an adequate AML/CTF law.
(S/REL USA, PAK) We stress your government’s obligation, under UNSCR 1267, and successor resolutions to strictly enforce
existing sanctions against the 142 Taliban, LeT leader Hafiz Saeed, LeT/JUD, al Rashid Trust, al Akhtar Trust and other
individuals and entities on the UN 1267 Consolidated List.
(S/REL USA, PAK) We urge your government to support the international community’s efforts to combat terrorist financing.
Your government’s views of UNSCR 1267 listing requests for LeT and other Pakistan-based terrorist groups should be made
on the merits of the requests and not linked to politics, including what country made the nomination or which countries
are referenced in the public statements of the cases.
(S/REL USA, PAK) We urge your government to comply with UN and domestic legal obligations to enforce sanctions on the
Pakistan-based, UN-proscribed NGOs al Rashid Trust and al Akhtar Trust, and all successor organizations that continue to
funnel money and provide other forms of support to the Taliban and LeT.
(S/REL USA, PAK) We emphasize that social services provided by NGO extremist organizations, such as Jamaat-ud Dawa (JUD)
challenge the legitimacy of your government to provide for its people. This includes relief efforts in the Internally
Displaced Person (IDP) camps of the Northwest Frontier Provinces by the new LeT/JUD charity Falah-e Insaniyat
(S/REL USA, PAK) We stress that our governments must work together to ensure that there are moderate alternatives to
terrorist-controlled social welfare networks upon which IDPs and other vulnerable populations currently rely. We must
work together to develop and support NGOs not affiliated with terrorist groups, and establish a comprehensive oversight
and enforcement mechanism for NGOs that is consistent with the Financial Action Task Force’s international standard.
(S//REL USA, PAK) We urge your Government in the strongest possible terms to take action against the Haqqani network,
which is funneling weapons and fighters across the border to fight U.S. and Coalition Forces in Afghanistan. This
network, led by Sirajuddin Haqqani who was listed by the UN under UNSCR 1267, funds its activities through illicit
activities, including kidnapping, extortion, bank robbery, narcotics, smuggling, and fraud.
(S//REL USA, PAK) We urge your Government to replace the anti-money laundering decree recently promulgated by your
Executive Branch with legislation fully consistent with the Financial Action Task Force (FATF) Recommendations and to
ensure that the current decree can stand in court. The FATF Forty Plus Nine Recommendations are international standards,
which Pakistan, by virtue of its membership in the Asia-Pacific Group, committed to.
15. (U) Qatar background
(S//NF) Department Note: Qatar is one of the four Gulf countries included in the IFTF, and accordingly, the IFTF
developed the background information included in para 16 for inclusion in the diplomatic engagement strategy. However,
given the current focus of U.S. engagement with the GOQ on terror finance related to Hamas, it would be
counter-productive for Embassy Doha to engage the GOQ at this time on disrupting financial support of terrorist groups
operating in Afghanistan and Pakistan.
(S/NF) Qatar has adopted a largely passive approach to cooperating with the U.S. against terrorist financing. Qatar’s
overall level of CT cooperation with the U.S. is considered the worst in the region. Al-Qaida, the Taliban, UN-1267
listed LeT, and other terrorist groups exploit Qatar as a fundraising locale. Although Qatar’s security services have
the capability to deal with direct threats and occasionally have put that capability to use, they have been hesitant to
act against known terrorists out of concern for appearing to be aligned with the U.S. and provoking reprisals.
(S//NF) Department Note: The Department has received post’s comments regarding personnel staffing and the thorough
description of the coordination process on terrorist finance issues at Embassy Doha (ref F). Department appreciates
post’s assessment that GOQ definitions of what constitutes terrorism differs occasionally from those of the USG.
Department agrees with post’s suggested approach on this issue of engaging with direct discussions with host government
Points of contact and reporting deadline
16. (U) Please direct any questions or comments on this request to EEB/ESC/TFS (Jay J. Jallorina or Linda Recht). Posts
are requested to report back on responses from other governments by January 19, 2010. CLINTON