Dawood Ibrahim's Name Again Surfaces With Latest Mumbai Terrorist Attack

By Victor Comras

It’s much too early to identify the group or groups involved in the Mumbai terrorist attack or to place blame for what has occurred. Identification will come with the expert police investigation and intelligence gathering now underway. But, at this...

Dialogue Bolstered by Sanctions - A Possible Option for Dealing With Iran

By Victor Comras

With world attention focused on the faltering international financial system, only back page notice is being given to the frightening progress Iran continues to make toward achieving nuclear weapons capability. An expert report now circulating within the halls of the...

New Treasury U-Turn Measures May Have Significant Impact on Iran

By Victor Comras

US Iran sanctions policy is again front and center with the Treasury Department’s announcement, November 6th, cutting off “U-Turn” privileges under general license for all transactions involving Iran’s financial institutions. This measure could have a significant impact on Iran, and...

Defining Terrorism- The UNGA Sixth Committee Struggles On

By Victor Comras

Once again the UNGA’s Sixth (Legal) Committee is struggling with defining terrorism as it seeks to finalize the longstanding proposed draft of a Comprehensive Convention on International Terrorism (CCIT). The Sixth Committee reconvened October 8th to focus on the draft...

General Assembly’s Opening Debate Dampens Hope For UN Progress in Dealing With Terrorism and Nuclear Proliferation

By Victor Comras

As the UN General Assembly ends its final day of principal level debate, the prognosis for its future work remains both murky and morose. As in the past the world’s ills have been laid plain for world leaders (if they...

Remembering 9/11 - “The Evil That Men Do Lives After Them”

By Victor Comras

It has become customary for commentators on terrorism to mark the anniversary of Al Qaeda’s 9/11 attack against the United States as an occasion to review and assess the progress we have made in combating terrorism. Our government and other...

Terrorism Financing Is Still Big Business Even If Terrorist Attacks Sometimes Are Carried Out on the Cheap

By Victor Comras

There is a common misperception that terrorism can be carried out on the cheap and that small terrorist cells simply raise their funds locally making it extremely difficult to detect. This seems to be the thesis of a number of...

UN SYSTEM FOR DESIGNATING TERRORISTS IS FALTERING

By Victor Comras

The UN system for designating terrorists is weak, under attack, and needs to be reformed. That is the thesis I present in an article just published online in Perspectives on Terrorism. And the challenges are coming from all sides....

Testimony in Canada About Proposal to Enable Civil Suits Against Terrorists

By Victor Comras

On June 18, I testified before the Canadian Senate Committee on Legal and Constitutional Affairs in Ottawa about a proposed bill to deter terrorism by providing a civil right of action against perpetrators and sponsors of terrorism. Segments of that...

Treasury Designates Major Saudi Charity -- Al Haramain - - For Financing Terrorists

By Victor Comras

Following several years of wrangling with Saudi Arabia over Al Haramain Islamic Foundation’s continuing international role in facilitating terrorism financing, the US Treasury Department has finally acted unilaterally to designate its whole world-wide operation, including Al Haramain's headquarter offices, structure...

UN Monitoring Team Report Highlights Problems Plaguing Implementation of Measures Against Al Qaeda and the Taliban

By Victor Comras

The United Nations Al Qaeda/Taliban Analytical Support and Sanctions Monitoring Team issued its 8th report earlier this month reviewing the implementation by states of the UN measures against Al Qaeda and the Taliban. The report also highlights several problems that...

It's Time Now for a Serious Public Debate on Our Iran Policy

By Victor Comras

I wrote here last month that the time has come for further clarification from the presidential candidates concerning their plans for dealing with Iran’s nuclear ambitions. We have heard numerous sound-bites and even read a few short paragraphs issued by...

France's Confused CFCM Elections -- An Opportunity for the Muslim Brotherhood?

By Victor Comras

Deciphering the current political trends and developments within France’s Muslim community is likely to challenge the most knowledgeable pundits for some time. But, what is clear is that the Muslim Brotherhood has made incredible strides in becoming France's most important...

The Soaring Price of Oil and Terrorism

By Victor Comras

A few days ago, when oil was just $115.00 per barrel, Iranian President Mahmoud Ahmadinejad declared that the price of oil was still “unrealistically low,” and that “Oil … needs to discover its real value." And, within a few days...

The Candidates Positions Re Iran's Nuclear Ambitions: Time for Some Clarification

By Victor Comras

Iran’s leaders are once again displaying their usual intransigence concerning Iran’s nuclear and uranium enrichment programs. They have refused Security Council and European attempts to engage them in a new round of negotiations despite the new round of sanctions and...

Security Council Approves New CTED Counter-Terrorism Program

By Victor Comras

The Security Council voted last week to give the UN’s Counter Terrorism Executive Directorate (CTED) a new lease on life until December 31, 2010. CTED was established in March 2004 (UNSC Resolution 1535) as part of a Security Council effort...

New FATF Study Highlights Need For Closer Government - Financial Sector Cooperation to Combat Terrorism Financing

By Victor Comras

From time to time FATF, the Paris based Financial Action Task Force, publishes new guidance and “best practices” to re-enforce the anti-money laundering and counter-terrorism financing practices of its member countries and the international financial community in general. The latest...

Finally, A Security Council Resolution on Iran With Some Teeth!

By Victor Comras

Iran’s leaders should surely take note of today’s Security Council action imposing a new round of sanctions on them for their continuing defiance of international non-proliferation norms. The measures included in UN Security Council Resolution 1803 appear to go well...

Let The Protect America Act Extension Debate Run Its Course

By Victor Comras

While I agree with my colleagues, Dennis Lormel and Jeffrey Breinholt, that renewal of the Protect America Act should be considered by Congress as urgent and serious business, it’s misplaced to ascribe current delays to merely “playing politics.” Few pieces...

Let's Make Fighting Terrorism Financing An International Battle

By Victor Comras

I want to build on the very useful piece posted here by my colleague Jeff Breinholt, which describes the Bank Secrecy Act and the due diligence and suspicious transaction report responsibilities it imposes on US financial institutions. These responsibilities go...

Are We Winning The Financial War On Terror? - Another Perspective

By Victor Comras

A few days ago my colleague Matthew Levitt published here an insightful essay asking, rhetorically, whether we are winning the war against terrorism financing. His piece was structured largely as a response to critic’s that have questioned the efficacy of...

New GAO Report Questions Efficacy of Sanctions Measures on Iran

By Victor Comras

A new GAO report, released January 16, 2008, seriously challenges the efficacy of current US sanctions on Iran and calls for a re-evaluation of our overall sanctions measures vis a vis Iran. The report is particularly critical of the Administration’s...

Iran To Seek 2009 Security Council Seat While Ignoring UN Sanctions

By Victor Comras

Word is circulating though the halls of UN headquarters in New York that Iran will actively campaign for a non permanent seat on the Security Council for 2009 or 2010. Perhaps such an Iran candidacy should come as no surprise...

Boim Case Reversal Could Be Major Blow To Victim-of-Terrorism Litigants

By Victor Comras

I want to join my colleague Andrew Cochran in expressing disappointment with the Seventh Circuit Court of Appeals decision to reverse and remand the Boim Case for a new trial. This landmark case is key to determining whether those responsible...

No New UN Sanctions on Iran Now Despite US Concessions

By Victor Comras

Word is out that today’s last ditch efforts to come up with new Security Council sanctions measures on Iran have failed. The Political Directors of the Security Council’s Permanent Five Members ( US, UK, France, Russia, China) and Germany reportedly...

Keeping Kosovo From Becoming a New Breeding Ground for Terrorism

By Victor Comras

Kosovo’s Albanian community leaders will likely unilaterally declare Kosovo’s secession and independence from Serbia in the next few weeks. This follows the failure of UN sponsored negotiations on Kosovo’s final status. This will not be a smooth separation and is...

Iran: Has the Rising Price of Oil Trumped Sanctions?

By Victor Comras

A major debate is ranging in European capitals on how best to deal with the growing prospect of confrontation with Iran over its ongoing nuclear weapons development program. Last month French President Sarkozy and British Prime Minister Gordon Brown called...

The New US Sanctions on Iran - Can They Be Effective?

By Victor Comras

Today’s announcement of new US sanctions on Iran follows months of reporting that the US is seeking to convince foreign governments, banks and business to pull away from the Iranian marketplace. The Washington Post reported last August that the U.S....

A New Mandate For FATF? Combating Nuclear Proliferation Financing

By Victor Comras

FATF (The Financial Action Task Force) appears to be poised to take on a greater role in combating illicit international financial activities, adding nuclear proliferation financing to its focus of attention. Meeting in Paris earlier this month, under British chairmanship,...

France Calls For Tough European Sanctions On Iran

By Victor Comras

The New French Government is now adding its own weight in support of U.S. efforts to get Iran to back off from its accelerated uranium enrichment program. French President Sarkozy indicated shortly after his election that he would place a...

A New International Counter-terrorism Organization Makes Good Sense

By Victor Comras

John Edwards’ proposal for a new international Counterterrorism and Intelligence Treaty Organization (CITO) deserve serious consideration. Edwards has put his finger on the single most important shortcoming in the war on terrorism – the serious lack of international cooperation and...

Will Designating the IRGC as Terrorists Really Have an Effect?

By Victor Comras

Today’s announcement that President Bush intends to designate the Iran Revolutionary Guard Corps (IRGC) as a terrorism supporting organization is certainly welcome, even if it is somewhat redundant. The IRGC has major commercial and investment interests throughout Iran and internationally....

The New Guantanamo Military Commission Debate

By Victor Comras

There doesn’t seem to be much going anymore for the Guantanamo Military Commission. Its utility, function and procedures are being challenged from all sides, including from the inside. General public condemnation of the process is growing here and abroad, the...

Isolating Hamas In Gaza May Be Best Road Ahead

By Victor Comras

Middle East experts have to be scratching their heads as they seek to analyze the enigma's posed by Hamas’ takeover of Gaza. Could this be the seminal event that causes a realignment in the interests and actions of key Arab...

US Supreme Court To Review Guantanamo Terrorism Detention Cases

By Victor Comras

Catching the Bush Administration by surprise, the Supreme Court decided late last week to take a close look at the legitimacy and constitutionality of the operation and procedures of Guantanamo’s Combatant Status Review Tribunal and of the trials conducted by...

EU To Implement New Cross Border Cooperative Measures to Combat Terrorism

By Victor Comras

The EU Justice and Home Affairs Council decided, June 11th to finally implement their agreement last January to expand cross border police and judicial cooperation on an operational and information-sharing basis to combat terrorism, cross-border crime and illegal migration. (See...

No New Counter-Terrorism Initiatives at This Year’s G8 Summit

By Victor Comras

The war on terrorism was not one of the “hot topics” at this year’s G8 summit at Heiligendamm, Germany. Terrorism didn’t constitute a separate agenda item, although it reportedly came up during the discussion of several agenda items, and in...

Europe's New Anti Terrorism Convention Strong on Substance, Short on Adherents

By Victor Comras

The new European Anti-Terrorism Convention which entered into force on June 1st, provides for a much broader and improved framework of investigative and judicial cooperation among European countries in combating terrorism than was previously the case. It builds on an...

Iran Sanctions: French Development Bank Drops Its South Pars Oil Field Investment

By Victor Comras

As a critic of the effete sanctions measures adopted by the international community against Iran, I want to be among the first to recognize a success in the application of US Treasury tactics re foreign banks doing business with Iran....

US-EU Differences Flare Over US Travel Data Requirements

By Victor Comras

Tensions are mounting again between the EU and US over planned new travel information requirements set by the Department of Homeland. The dispute is coming to a head just as transatlantic air traffic reaches its peak season. An interim agreement...

Foreign Banks Still Consider Iran Lucrative Market Despite US Treasury Curbs

By Victor Comras

The US Treasury Department’s financial curbs on Iranian banks and its new outreach program concerning the risks of doing business with Iran are undoubtedly having an impact on international financial dealings with Iran. According to Treasury officials more than 40...

Treasury Deputy Secretary Kimmitt's Washington Institute Speech: Is the Administration Too Soft on Iran Sanctions?

By Victor Comras

In yesterday's speech at the Washington Institute, Deputy Treasury Secretary Robert Kimmitt presented an overview of Treasury’s new role in combating national security threats. The Treasury Department has taken the lead (apparently away from the State Department) when it comes...

Is the Administration Shifting Priorities from Terrorism Financing to Money Laundering?

By Victor Comras

Last week the Bush Administration issued its new strategy for combating money laundering. Crafted by the Department of the Treasury, along with Justice, State, Homeland Security, the Federal Reserve, Comptroller of the Currency, and the Federal Deposit Insurance Corporation, it...

America At A Crossroads - Caution Needed When Dealing With the Muslim Brotherhood

By Victor Comras

PBS’s week-long “America at a Crossroads” series presented many of the issues and dilemmas now facing America in the War on Terrorism. The series got mixed reviews on content and temper. There were criticisms about its objectivity from both the...

FATF Identifies Weaknesses in Turkey's AML/CTF Program

By Victor Comras

Last September a special FATF-sponsored team of financial experts undertook an evaluation of Turkey’s Anti-money laundering and counter-terrorism financing programs. The evaluation was undertaken with the cooperation of the Turkish Government, and involved extensive discussions with both government officials and...

Weak Sanctions On Iran Simply Won't Work

By Victor Comras

A number of my colleagues have suggested that I discuss further my concerns with the latest UN Security Council Sanctions Resolution on Iran. Many in the news media are characterizing the new round of UN Security Council Sanctions on Iran...

The New Iran Sanctions: “Full of Sound and Fury, Signifying Nothing”!

By Victor Comras

The UN Security Council, unable to come up with a consensus on meaningful sanctions measures against Iran, has settled on an effete set of measures unlikely to cause Iran to change course. In fact, UN Security Council Resolution 1747 (2007)...

ICJ Eminent Panel of Jurists on Terrorism, Law & Human Rights Continues to Question US Practices

By Victor Comras

The US Congress has so far paid little attention to the work of the Eminent Panel of International Jurists appointed by the International Court of Justice (ICJ) to develop and recommend new international legal standards in the war on terrorism....

The Muslim Brotherhood and the Growing Sunni-Shiite Conflict

By Victor Comras

My colleague Olivier Guitta has just posted an excellent piece on the growing Sunni Shiite conflict. The heightened tensions between these two principal confessions of Islam is already putting great pressure on the Muslim Brotherhood. There has long been a...

UN Counter-Terrorism Handbook -- Form Over Substance

By Victor Comras

Following up on a recommendation contained in last year’s UN Global Counter-Terrorism Strategy, the UN has put together a new on-line “counter-terrorism” handbook which is meant to help guide countries wishing to assess UN counter-terrorism support services. As the UN...

Another UN Designation Goes Awry

By Victor Comras

For the last several years, US terrorism financing trackers have noted suspicious financial transactions coming out of South Africa that appeared to be for the benefit of al Qaeda. Some of these transactions predate 9/11. Following the money led them...

EU To Take Important New Step to Expand Counter Terrorism Police Work

By Victor Comras

EU Justice and Home Affairs Ministers agreed today to move ahead with plans to expand cross border police and judicial cooperation on an operational and information-sharing basis to combat terrorism, cross-border crime and illegal migration. Meeting in Dresden, Germany, the...

Securing the Homeland; GAO Recommends Areas for Increased Congressional Oversight in 2007

By Victor Comras

We got through 2006 without any new terrorist attack at home. But, most terrorism experts are convinced that 2007 remains fraught with danger. Internationally, terrorism continues to rage with no letup against US and allied assets and interests. And we...

Iran Sanctions: The UN Finally Acts –But Much too Softly

By Victor Comras

The UN Security Council finally acted and imposed a limited set of sanctions on Iran for its continued defiance of IAEA norms re uranium enrichment. I have long argued that sanctions will be needed to turn Iran around. But, the...

Another Terrorism Case Is Dismissed Against Saleh Kamel and His Dallah Al Baraka Investment Group

By Victor Comras

The Arab News is touting a decision by US District Court (SDNY) Judge Richard Conway Casey dismissing a series of consolidated insurance company lawsuits against Saleh Kamel and his Dallah Al Barakat Group (not to be confused with the Al...

Hague Action Plan To Combat Terrorism & Crime Needs Update

By Victor Comras

EU Council members meeting in Brussels December 4th called on the EU Commission, and the incoming EU Presidency (Germany) to update the Hague Action Plan which lays out critical measures for combating crime and terrorism in Europe. The Hague program,...

Federal Court Judge Questions Legality of Executive Order Designation of Terrorists

By Victor Comras

In what could become a very problematic ruling, US District Court Judge Audrey Collins has challenged the President’s “unfettered” authority to designate individuals or groups as “Specially Designated Global Terrorists (SDGTs)” by Executive order. The court found that “the President’s...

UN Deadlock On Defining Terrorism Persists

By Victor Comras

The UN General Assembly’s Sixth (Legal) Committee again failed this session to break the deadlock preventing progress on a Comprehensive Counter-Terrorism Convention and a Definition of Terrorism that would be binding on all countries. The Committee adjourned November 21st after...

Both US and EU Want to Improve Anti-Terrorism Information and Investigation Cooperation

By Victor Comras

I have often written criticizing shortcomings that have hampered close US- EU information sharing and cooperation related to the investigation of terrorism and terrorism financing. So it’s a real pleasure to write now on steps recently taken by both sides...

UN Finally Gets Around to Listing IIRO Indonesia

By Victor Comras

On August 3rd, 2006 the US Treasury Department moved to designate the Philippine and Indonesia Branches of the International Islamic Relief Organizations as global terrorist entities (SDGTs). The Treasury Department also designated the Saudi based Executive Director of the Eastern...

Civil Liability is Crucial in the War on Terrorism: A Response to the Wall Street Journal.

By Victor Comras

Ted Frank’s provocative Op-ed in Friday’s Wall Street Journal questions the rationale for allowing victims of terrorism to hold third-party institutions potentially liable for their own contributory actions. He wants Congress to enact new restrictions on attorneys and on the...

North Korea Sanctions: The Difficulties Are In the Details!

By Victor Comras

Editor's Note: In light of North Korea's status as an official "State Sponsor of Terrorism" since January 20, 1988 and President Bush's warning yesterday that any attempted North Korean transfer of nuclear technology to any party would be interdicted, this...

Putting Together a Coherent International Strategy to Combat Terrorism Financing

By Victor Comras

A report issued October 4th by Canada’s Financial Intelligence Unit, Fintrac, estimated that “the total value of case disclosures of suspected terrorist activity financing and other threats to the security of Canada {during the 2006 reporting period} was approximately $256...

UN Terrorist List Essential to Combating Terrorism and Terrorism Financing -- An Answer to A Recent Wall Street Journal Article

By Victor Comras

David Crawford’s article in the Oct. 2nd Wall Street Journal, entitled The Black Hole of a U.N. Blacklist -- Terrorism Suspects Are Stripped of Assets Without Hearings or the Right to Appeal, raises interesting and difficult issues concerning the war...

This Round of Negotiations on Iran's Nuclear Program May Lead to Suspension or to Sanctions

By Victor Comras

The United States, the European Union and Iran are now engaged in a serious game of three-way hardball over Iran’s nuclear enrichment program. Iran’s President Mahmoud Ahmadinejad, used his visit to the UNGA in New York to suggest that Iran...

The UN's New Global Counter-Terrorism Strategy Has Some Serious Deficiencies

By Victor Comras

The UN General Assembly’s 60th Session was supposed to lay the foundation for a new Counter-Terrorism Strategy to re-enforce, and better coordinate international efforts against terrorism and terrorism financing. Secretary General Kofi Annan put forth a plan of action earlier...

Iran Sanctions: A Necessary Step in a Difficult Situation

By Victor Comras

Time has run out on a negotiated settlement with Iran on its nuclear enrichment program. The latest