Anti-Terrorism: Operation Green Quest

The US Customs Service has implemented Operation Green Quest. Marcy Forman, the Director of Operation Green Quest, explained the operation's purpose: to identify, disrupt, and dismantle organizations and systems that fund or support terrorists. Treasury created OGQ in October 2001 as a multi-agency response to terrorism. It is the command and coordination center for investigating terrorist financial activities. In addition to Customs, member agencies include IRS, Secret Service, FBI, OFAC, FinCEN and other law enforcement agencies.

Since its creation, OGQ has received more than 1100 leads or referrals for investigation. There are currently 457 ongoing investigations. To date, OGQ has obtained 50 arrests, seized more than $18 million in bulk currency, and more than $7 million in assets.

Investigation resources
OGQ uses a variety of data bases including those created by CTRs and SARs. Their agenda is to dismantle hostile organizations first and then use the information for enforcement. In this effort, Forman told the audience that the financial industry is their best ally.

The group has already brought several cases involving movement of gems, gold, and baby formula. They have found that buying and selling baby formula internationally is a popular method of funding terrorism. OGQ is closely monitoring trade activity of these items.

OGQ has created a research tool, NIPS, that enables manipulation of trade, financial, and commercial data to identify anomalies in an industry or trade. The database includes immigration data and information from ATF.

As for those CTRs and SARs that the financial industry struggles with, Forman stated that they are invaluable sources of information. They prove every bit as valuable as sources. She commended the audience for their excellent work.

Charities
In addition to tracking finances and specific commodities, OGQ is watching several charities. Several suspect activities - or lack of activities - have emerged in investigations.

Charities using wire transfers to move funds to companies located in bank or tax haven countries may be funding terrorist activities. Other suspicious traits are charities that don't have apparent fund raising activities or that raise funds from only a few large sources.

OGQ looks for corporate layering including transfers between bank accounts of related entities, both profit and not-for-profit, for no apparent business reasons.

One element that OGQ identifies as a potential problem is overlapping officers and directors. Overlaps include officers, directors, signatories, common addresses, references, and financial activities. The overlaps often occur in connection with terrorism interests. These are information items that should be considered in developing the Customer Identification Program.

Other Red Flags
Front companies are being used to generate revenue for terrorist networks. They co-mingle legitimate and illegal funds to launder money and avoid suspicion. Popular businesses include convenience stores and international investment or management services. Trade in commodities, such as gold or precious stones, provides a technique for converting dirty money into commodities and then selling the commodity for "clean" funds.

Transactions involving a high number of wire transfers, into or out from the account, should be watched, especially when the transfers go to or from a high-risk country.

Reporting
You may send a SAR directly to OGQ. However you must still follow the SAR filing procedures under the regulation. Any direct filing with OGQ is in addition to the regulatory routine. OGQ uses the database of SARs and CTRs. If a situation arises that could be of immediate interest to OGQ, you may want to send the SAR directly to OGQ as well as to FinCEN.

Free Information
Operation Green Quest has published an information brochure about the organization and the effort. It is clear and to-the-point and includes some examples of the red flags that may indicate terrorism. It would be useful in management briefings and in staff training.

You can find information at www.customs.gov. Use "Operation Green Quest" as a word search.

ACTION STEPS

Make sure your CIP includes collection of information about the directors and officers of an organization so that you have the ability to identify overlaps.
Review your deposit accounts held by charities, including NOW accounts. Pull and review the information you have on the authorized users and the management of the accounts. Make sure it makes sense.
Get copies of OGQ's brochure and use it in training.