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DoD OIG Finds Lack of Standardized Procedures for Conducting Counter Threat Finance Activities at Combatant Command Level

The Department of Defense Office of Inspector General conducted an evaluation to determine whether U.S. Africa Command (USAFRICOM), U.S. Central Command (USCENTCOM), U.S. European Command (USEUCOM), and U.S. Indo-Pacific Command (USINDOPACOM) planned and executed counter threat finance (CTF) activities to impact adversaries’ ability to use financial networks to negatively affect U.S. interests.

The DoD conducts CTF activities in coordination with other U.S. Government agencies and partner nations to prevent adversaries from using global licit and illicit financial networks to negatively affect U.S. interests.

The Office of the Under Secretary of Defense for Policy (OUSD[P]) is responsible for coordinating and overseeing the implementation of policy and plans for DoD CTF activities and capabilities. The Office of the Deputy Assistant Secretary of Defense for Counternarcotics and Global Threats (DASD[CN&GT]) performs its responsibilities at the direction of the USD(P) and is responsible for providing oversight and guidance on policy, resource allocation, and measures of effectiveness for the DoD’s effort to disrupt and degrade the national security threats posed by illegal drugs, trafficking, piracy, threat financial networks, and any potential connections among these activities. The DoD Framework to Counter Drug Trafficking and Other Illicit Threat Networks requires that the DoD apply its capabilities to support a whole-of-government approach to countering transnational organized crime and conducting operations and activities to disrupt and degrade these national security threats.

In 2014, the Joint Requirements Oversight Council QROC) approved a Doctrine, Organization, Training, Materiel, Leadership, Personnel, Facilities, and Policy (DOTmLPF-P) Change Recommendation that directed the OUSD(P) to develop a CTF-specific DoD Instruction (DoDI) that details a common lexicon for CTF, target nomination procedures, and guidance in defining measures of performance for CTF activities. The DASD(CN&GT) office is responsible for developing a CTF-specific DoDI because they perform their responsibilities at the direction of the USD(P) and are responsible for providing oversight and guidance on DoD CTF activities and capabilities.

The Combatant Commanders are responsible for planning, coordinating, and executing DoD CTF day-to-day activities within their respective areas of responsibility or functional areas. The Combatant Commanders are required to establish a dedicated DoD CTF capability approved by the JROC that integrates intelligence and operations, analyzes financial intelligence, and coordinates the execution of DoD CTF activities.

USAFRICOM, USCENTCOM, USEUCOM, and USINDOPACOM planned and executed CTF activities to support their respective missions. However, OIG found they did not establish and maintain formalized command procedures. This occurred because USAFRICOM, USCENTCOM, USEUCOM, and USINDOPACOM personnel relied primarily upon their own experience and knowledge to conduct CTF activities. As a result, the Combatant Command CTF offices did not have established standardized procedures for conducting CTF activities at the Combatant Command level, with interagency partners, or with partnered nations.

Additionally, the USD(P), in coordination with the Under Secretary of Defense for Intelligence and Security (USD[I&S]), the Under Secretary of Defense for Personnel and Readiness (USD[P&R]), and the Under Secretary of Defense for Acquisition and Sustainment (USD[A&S]), did not oversee the full implementation of the DoD CTF policy. This occurred because the OUSD(P) was unable to successfully coordinate with other DoD components listed in DoD Directive (DoDD) 5205.14 and ensure that those components fulfilled their DoD CTF program-related roles and responsibilities. Furthermore, the USD(P) did not issue a DoDI for conducting DoD CTF activities as outlined in the 2014 JROC-approved DOTmLPF-P Change Recommendation. This occurred because the DASD (CN&GT) placed the DoDI on hold to develop and release an overarching DoD policy framework focusing on Counterdrug and Counter-Transnational Organized Crime. DASD(CN&GT) officials also stated that they would only issue a CTF-specific DoDI if they determined that there were gaps in CTF policy guidance not sufficiently covered by existing issuances, publications, and guidance documents.

As a result, the USD(P) and DASD(CN&GT) were unable to ensure DoD CTF personnel conducted DoD CTF activities in accordance with DoDD 5205.14 and other DoD CTF guidance. Without DoD Components providing program oversight, performing their roles and responsibilities, and further developing the program, the CTF program may not achieve its full effectiveness of impacting adversaries’ ability to use financial networks to negatively affect U.S. interests.

OIG recommended that the Commanders of USAFRICOM, USCENTCOM, USEUCOM, and USINDOPACOM develop and issue command-level CTF standard operating procedures in accordance with DoDD 5205.14.

OIG recommended that the Chairman of the Joint Chiefs of Staff, Under Secretary of Defense for Intelligence and Security, Defense Intelligence Agency Director, Under Secretary of Defense for Personnel and Readiness, and Under Secretary of Defense for Acquisition and Sustainment, in conjunction with the USD(P) and U.S. Special Operations Command (USSOCOM), develop a plan of action and milestones to implement guidance and responsibilities outlined in DoDD 5205.14.

OIG recommended that the USD(P) develop a plan of action and milestones to implement the CTF-specific DoDI as outlined in the JROC-approved Doctrine, Organization, Training, Materiel, Leadership, Personnel, Facilities, and Policy Change Recommendation, which includes:

  • a common lexicon,
  • procedures for nominating targets for sanctions and designations,
  • procedures for coordinating and executing CTF activities across organizational and geographic boundaries,
  • clearly stated objectives for use in defining measures of performance, and
  • procedures for engaging interagency and foreign partners with building partnership capacity efforts.

During the course of the evaluation, the Commanders of USAFRICOM, USCENTCOM, USEUCOM, and USINDOPACOM provided evidence of actions taken to address the recommendations in this report. We reviewed the formalized CTF procedures provided by USEUCOM and USAFRICOM and determined that the procedures met the intent of the recommendation. Therefore, the recommendations for USAFRICOM and USEUCOM are considered resolved and closed. We will close the recommendations for USCENTCOM and USINDOPACOM when we receive and review their approved command procedures.

Read the OIG report

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