Opioid deaths now exceed those from motor vehicle accidents. It's clear we need to do more. Fair Share Education Fund's latest report, “Anonymity Overdose,” connects opioid trafficking and the subsequent crisis with the activities of anonymous shell companies – companies formed with no way of knowing who is actually in charge. Because they shield the owners from accountability, anonymous shell companies are a common tool for disguising criminal activity and laundering money, and are also at heart of the Panama Papers.  I'm quoted in the report.  The text is available here:
www.fairshareonline.org/sites/default/files/AnonymityOverdose_Aug1_2016.pdf

​As a veteran of the U.S. intelligence and law enforcement communities, I was stunned with FBI Director’s James Comey’s dismissal of the Hillary Clinton email case.   Comey determined Clinton was “extremely careless,” but not criminal in her handling of classified emails.

If I had done what Clinton did during my career, I would have been dismissed from my job and prosecuted.  In the coming years, when there are alleged “security violations” in the intelligence, law enforcement, and diplomatic communities the subjects of the investigations will now have recourse to the “Hillary defense;” i.e. “I’m sorry.  I admit I was careless but it was not my intent to commit the security violation.”  Director Comey did the nation a huge disservice setting this low-bar precedent.

 This incident is further proof of the egregious politicization of our civil service.  I composed a draft article a few months ago focused on the enforcement arm of  Department of Treasury.  I couldn’t get the article published.  Particularly in light of the Comey ruling, it makes interesting reading.  So here it is in this blog post:

Politicization at Treasury’s  Enforcement Arm Must Stop
 
Last month, Treasury’s Acting Under-Secretary for Terrorism and Financial Intelligence Adam Szubin spoke at a forum and conclusively demonstrated what I have long suspected - the politicization of the Department of Treasury’s enforcement arm.  As a former Treasury Special Agent, I was appalled by his remarks.

Reading a prepared statement, Szubin discussed the Iran sanctions program and described how it helped pave the way to the "Joint Comprehensive Plan of Action (JCPOA)."  This is a fascinating topic.  The sophisticated audience at the FDD Forum was anticipating insights into this incredibly important and far reaching accord.  Instead, Szubin’s speech was an exercise in deception and political spin.

Sections of the speech are titled "The JCPOA: A Sanctions Success Story" and "The Benefits of the Bargain."  You get the idea.  Szubin ended with a flourish labeling the agreement "deft diplomacy." 

I was at the Department of Treasury for a short time.  I understand how these remarks are drafted and cleared.  In this case, I assume they were reviewed by both the State Department and the White House.  But just because something is called a "bargain" and a "success” doesn’t make it true.  

Since the September 11 terrorist attacks, the Department of Treasury pioneered a new era of financial warfare primarily revolving around targeted sanctions and designations.  Treasury has used American financial and economic power to protect the global banking system from international money laundering, other financial crimes, and even terror finance.  Working with international partners, the innovative use of these programs put in place by Treasury’s “financial intelligence wonks” – including Adam Szubin - was the primary reason that Iran came to the negotiating table. 
However, instead of negotiating from a position of strength and with the cunning, patience, and long-term outlook practiced by our adversaries, the White House and its negotiators threw years of hard work and international consensus building away.  Despite the remarks by the administration and its spokespeople, the true legacies of the JCPOA will be a case study of naiveté, a much more dangerous world, and disastrous results.  

Ben Rhodes, the White House’s Deputy National Security Advisor, recently boasted to a journalist of duping the American public about the JCPOA.   Mr. Rhodes bragged about his ability to spin, weave, and restructure a narrative divorced from reality.  One can only surmise that Adam Szubin’s speech was just one more opportunity for the White House to deceive and mislead. 

Unfortunately, this is not an isolated incident.  The Internal Revenue Service, also part of the enforcement arm of the Department of Treasury, has become politicized.   Lois Lerner’s pleading the Fifth Amendment against self-incrimination is eloquent testimony of the IRS’ efforts to suffocate groups critical of the administration.  In fact, efforts are underway to impeach the IRS Commissioner for making false statements under oath and failing to comply with a subpoena for evidence. 

While political appointees have always influenced the civil service, direction has reached new levels.   Political guidance at the Departments of Justice, Homeland Security, State and other agencies and departments I once held in high esteem frankly break my heart.   It is no wonder the overwhelming majority of the American people no longer trust their government.

If we are to turn this around, two things must happen: 1. the next administration must restore trust and credibility in the civil service by taking crass politics out of governance; 2. civil servants – particularly those at the highest levels - must say no when they know they are being used for political ends.  We must restore honor and integrity in government service.
​
Comments?

On  June 23, I was a witness before the Task Force to Investigate Terrorism Financing of the House Financial Services Committee.  The focus of the hearing was on coming trends so during my remarks I focused on Mobile Payments.   My written statement is available here:
http://www.defenddemocracy.org/content/uploads/documents/Cassara_The_Next_Terrorist_Financiers.pdf 

A video of the hearing is available here; 

www.youtube.com/watch?v=EAPS-pI2FEA

Tomorrow, June 23, I will testify before the Task Force to Investigate Terrorism Financing of the House Financial Services Committee.  The focus of the hearing is to summarize the Task Force's findings from previous hearings that have been held over the last two years.   In addition, the hearing will also identify emerging terrorism financing threats so that we can act to mitigate coming dangers.   I will discuss the "Growing Threat of Mobile Payments" or the use of cell phones to launder money and finance terror.  I will post my written statement on this website when it is publicly released.  Please look under "Articles."   For further information about the hearing, see this link:

www.financialservices.house.gov/calendar/eventsingle.aspx?EventID=400810

On April 13, I attended the Washington Forum Program sponsored by the Foundation for the Defense of Democracies.  There were some impressive panels and speakers and then there was was Treasury's  Acting Under Secretary Adam Szubin who read prepared remarks.  Szubin discussed the Iran sanctions program, and described how it helped pave the way to the "Joint Comprehensive Plan of Action (JCPOA)."  I do not normally comment on these types of presentations but listening to his shameless remarks I was appalled.  

The text of Szubin's speech is available here: https://www.treasury.gov/press-center/press-releases/Pages/jl0419.aspx
  
Sections are titled "The JCPOA:  A Sanctions Success Story" and "The Benefits of the Bargain."  You get the idea.  He ended with a flourish labeling the agreement "deft diplomacy."  

Having been at Treasury, I understand how these remarks are drafted and cleared.  I assume they were reviewed by both the State Department and the White House.   But Adam Szubin, just because you and the administration call something a "bargain" and a "success" and "deft diplomacy" doesn't mean that it is.  While I do not doubt the premise that sanctions brought Iran to the negotiating table, the true legacies of the JCPOA will be a case study of naivete, a much more dangerous world,  and disastrous results.    

An article I wrote on Chinese Underground Finance and its possible link with the purchasing of real estate in the United States and elsewhere was published today in Banking Exchange.   The article is available here:  http://www.bankingexchange.com/news-feed/item/6079-flying-money-may-land-in-u-s?Itemid=101
​

​

There have been a few interesting developments resulting from the February 3 hearings on trade-based money laundering.  (See other blog and articles posts).  It appears that there maybe some legislative initiatives.  See this article posted February 8th in The Hill:  http://thehill.com/policy/finance/269784-lawmakers-eye-crackdown-on-illicit-trade

I was recently honored to join the Board of Advisors of the Center for Sanctions and Illicit Finance (CSIF), which is part of the Foundation for the Defense of Democracies. (FDD).  The CSIF does great work bringing attention to various issues surrounding threat finance.  More information is available here:
http://www.defenddemocracy.org/csif

On February 3, I was honored to testify before the Task Force to Investigate Terrorism Financing of the House Financial Services Committee.  The hearing was on trade-based money laundering.  A video of the hearing is available here:
http://financialservices.house.gov/calendar/eventsingle.aspx?EventID=400192

The hearing went well.