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Monday, October 3, 2022

DHS CVE Grant Program Must Ensure Terrorists, Extremists Aren’t Getting Funding

To properly execute the Department of Homeland Security’s (DHS) Countering Violent Extremism Grant Program (CVEGP) grant program and help adhere to congressional intent, DHS must ensure that grant recipients do not use Countering Violent Extremism (CVE) grant funding to support terrorism, engage in other criminal activities or otherwise conduct or support activities that are contrary to the purpose of the program, according to a new DHS privacy assessment of the program.

DHS uses the CVEGP to fulfill a congressional mandate to help states and local communities prepare for, prevent and respond to emergent threats from violent extremism.

According to the assessment, “The DHS Secretary has the discretion to consider those factors necessary to properly execute the grant program. Acting on behalf of the Secretary in administering the grant process, the DHS Office for Community Partnerships (OCP) and Federal Emergency Management Agency (FEMA) will review grant applications considering information and analysis contained in security assessments coordinated and produced by DHS’s Office of Intelligence and Analysis (I&A), with the assistance of Customs and Border Protection (CBP), directly in support of OCP, FEMA and this departmental effort.

The just released privacy impact assessment (PIA) examines the privacy implications of these security reviews.

The PIA explained that, “In July 2016, DHS announced the Fiscal Year 2016 Countering Violent Extremism Grant Program which will support programs, projects and activities designed to prevent recruitment or radicalization to violence in the homeland by interrupting those efforts, building community-level resilience to them and identifying the early signs of radicalization to violence and providing appropriate interventions through civic organizations, law enforcement or other entities. Eligible activities for the CVE initiative include planning, developing, implementing or expanding educational outreach, community engagement and social service programs, as well as other activities.”

With regard to “Identifying the early signs of radicalization to violence,” in early 2006, the FBI had already warned in a little known intelligence assessment, The Radicalization Process: From Conversion to Jihad, that, “This assessment provides a working model of the radicalization process for a legal US person who is a convert to Islam, utilizing FBI case examples that illustrate the process … derived from open and closed FBI investigations” and ‘academic literature,’ the profile stated.

Prepared specifically for counterterrorism investigators, analysts and law enforcement, the assessment is a detailed profile of the “indicators” of someone undergoing Islamist radicalization. The FBI said it specifically “developed [the assessment] in order to identify an individual going through the [jihadi] radicalization process.”

Since it was issued a decade ago, the underlying indicators of jihadi radicalization that it identified have been buttressed by what’s been learned from all the lone wolf jihadists in particular who’ve assumed the mantle of Muslim radicalization, or “sudden jihad syndrome,” in the US and around the world.

A top federal counterterrorism official told Homeland Security Today on background that when you “put [the indicators] in the context of an investigation of the suspicious actions or activity of a Muslim who also has suddenly become radical, the indicators are valid – we’ve seen them time and time again. This isn’t racial profiling when in the aggregate they paint a portrait of ideological radicalization.”

However, this and other counterterrorism officials believe the FBI’s report – directed to field agents and especially Joint Terrorism Task Forces (JTTF), hasn’t been referred to in many cases involving FBI investigations of suspected jihadists in the US who’ve gone on to commit attacks in the US.

“It’[s] also raise[d] questions about whether the [2006] assessment [has] even taken into consideration” during certain FBI and JTTF investigations, one of the officials said.

The notice of funding opportunity for the CVE program formally announced the program and solicited applications from states, local and tribal governments, non-profit organizations and institutions of higher education.

“The CVEGP grants are the first federal grants dedicated to supporting local CVE programs. Accordingly, they are of heightened concern,” the PIA said, noting, in [DHS] Secretary Jeh Johnson’s testimony before the House Committee on Homeland Security hearing, “Worldwide Threats to the Homeland: ISIS and the New Wave of Terror” on July 14, 2016, “several members of Congress highlighted the risk that some applicants might themselves support terrorism, engage in other criminal activities or otherwise conduct or support activities contrary to the purpose of the program. Unless the applicants were properly vetted, they continued, it was even possible that DHS grant money could be used to support nefarious activity.”

In testimony, Johnson acknowledged lawmakers’ concerns, and previewed a new risk assessment process to review applications for CVE grants.

DHS’s OCP has worked with other DHS stakeholder offices to refine a new review process.

“To design this new process, OCP used a risk-based approach,” the new PIA explained. “For instance, the risk that a state, local, tribal government or college or university would misuse a DHS grant to support terrorism is so comparatively small that OCP determined that applications from such institutions may be considered presumptively risk-free and judged under more traditional standards of grant review.”

However, the PIA emphasized, “On the other hand, even though the risk that any individual non-profit organization-applicant seeks to exploit a DHS grant program is exceedingly small, these are the portion of the applicant pool DHS typically knows the least about. Thus, out of an abundance of caution, prudence requires the swift and narrowly tailored risk assessment process for these organizations designed by the OCP” defined in the PIA.

So, in or to “properly execute the grant program and help adhere to congressional intent, DHS must ensure grant recipients do not use CVE grant funding to support terrorism, engage in other criminal activities or otherwise conduct or support activities contrary to the purpose of the program. Therefore, DHS will conduct security reviews of grant applications to determine the likelihood that:”

  • An applicant may use CVE grant funding to support terrorism or engage in other criminal activities;
  • An applicant may, with or without the funding, conduct or support activities contrary to the purpose of the CVE grant; or
  • An applicant may otherwise be an inappropriate choice to receive a CVE grant based on other domestic, national, or international security considerations.

As part of the Security Review Process, “Only applications that meet the initial eligibility requirements and score well in the merit process will go through the security review. Security reviews are used to examine the organization requesting the grant; those reviews may also require a review of individual-level data. DHS will provide written notice to these applicants prior to conducting the security review. In this written notice, DHS will provide grant applicants the opportunity to withdraw their applications.”

I&A, supporting OCP and FEMA, is responsible for providing the information analysis and support necessary to inform the security reviews, including identifying, with appropriate assistance from CBP’s National Targeting Center (NTC), relevant intelligence or information necessary for assessing the likelihood of an applicant’s involvement or association with terrorism or any of the other activities appropriate for considering an applicant’s suitability for receiving a grant award, as described above, the PIA said.

For each application that will undergo a security review, a security review is initiated when OCP provides I&A with:

  • The name, address, email, and phone number of the organization applying for the grant (applicants);
  • The name and email and/or phone number of the individuals submitting those applications on behalf of an organization (individuals); and
  • The name of the sub-applicant organizational entities (subs)

“This information is derived directly from the grant application,” according to the PIA, noting DHS receives information directly from grant applicants through grant applications. There are no additional or separate requests or collections of information from grant applicants by DHS. I&A, with appropriate assistance from CBP’s NTC, will use that information to identify from within available departmental, Intelligence Community and law enforcement holdings, open source and social media resources, financial data, import/export data, immigration data, travel history and foreign holdings in order to identify information responsive to security factors that are relevant for determining risk in this program.

For operational security reasons, DHS’s security factors are not identified in the PIA.

Homeland Security Todayhttp://www.hstoday.us
The Government Technology & Services Coalition's Homeland Security Today (HSToday) is the premier news and information resource for the homeland security community, dedicated to elevating the discussions and insights that can support a safe and secure nation. A non-profit magazine and media platform, HSToday provides readers with the whole story, placing facts and comments in context to inform debate and drive realistic solutions to some of the nation’s most vexing security challenges.

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