SELECT COMMITTEE ON
INTELLIGENCE
UNITED STATES SENATE

Additional Pre-Hearing Questions for
Ms. Isabel Patelunas upon her nomination to be Assistant Secretary for
Intelligence and Analysis, Department of the Treasury

1.

Please describe how, if confirmed as the Assistant Secretary of the Treasury
for Intelligence and Analysis, you will be responsive to the Director of
National Intelligence (DNI) and the Secretary of the Treasury.
 Because of its dual character as a member of the Intelligence Community
and the Department of the Treasury, OIA is positioned to serve as a
critical bridge between the Intelligence Community and the Executive
Branch’s financial policymakers on issues of financial intelligence. If
confirmed, I would support the DNI by leading OIA to be an agile
organization that can respond to the complex and rapidly changing
national security environment the U.S. continues to face, and by further
integrating OIA in the Intelligence Community as the lead organization
on financial intelligence. I would support the Secretary of the Treasury
as the Department formulates policy and executes authorities through
all-source analysis of global financial networks, the financial
vulnerabilities of U.S. adversaries, the impact of targeted U.S. financial
measures, and threats to international financial stability.

2.

If conflicts arise between the priorities of the DNI and the Secretary of the
Treasury, how will you act to resolve them?
 I am not aware of any conflicts between the priorities of the DNI and the
Secretary of the Treasury. If I am confirmed and such a conflict does
arise, I would work to resolve any conflicts in the best interest of the
United States.

3.

Please explain your understanding of OIA’s responsibilities and authorities
within the IC for coordinating, facilitating, or otherwise improving financial
intelligence collection and analysis. Do you see OIA as the IC’s lead agency
on financial intelligence issues?
 It is my understanding that OIA drives collection by IC counterparts on
top Treasury priorities and produces all-source intelligence analysis to
inform Treasury activities. Given its expertise and focus on the topic, I
view OIA as the IC’s leader on financial intelligence analysis, a role that
also involves working collaboratively with partners across the IC.

4.

Do you intend to comply with the president's executive order on
ethics? Will you promptly notify the committee if any waivers are granted?
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 If confirmed, I will comply with the President’s Executive Order on
ethics, including signing the ethics pledge. I will abide by any rules or
procedures established by the White House with respect to any waivers
granted by the President or his designee.
5.

Please describe your current understanding of OIA’s participation in the
CFIUS process. Do you think OIA is positioned well to support the
interagency in the CFIUS process? How do you see OIA evolving to better
support the CFIUS process?
 It is my understanding that OIA provides intelligence support to
Treasury’s role in the CFIUS process. If confirmed, I will seek
opportunities for OIA to enhance its analytic contribution to this national
security function.
o Background: Press reporting describes the volume of CFIUS cases
as increasing “considerably” or “dramatically;” some press
reports describe case volume as “surging” or “skyrocketing.”
Exact case volumes for 2015, 2016, and 2017 have not been
publicly released; 2014 case volume was 147.

6.

Please explain your understanding of how the oversight roles of the Senate
Select Committee on Intelligence and the House Permanent Select
Committee differ from the oversight roles of other congressional committees
that have oversight jurisdiction for other offices within TFI and the Treasury
Department.
 As a member of the Intelligence Community, OIA falls under the
oversight of the SSCI and the HPSCI. Both committees have a unique
role in their jurisdiction to review the activities of Intelligence
Community entities, assure that intelligence activities are lawful and
Constitutional, and authorize funds for OIA. If confirmed, I look forward
to working with the intelligence committees as they fulfill their oversight
role.

7.

OIA is the only component within the broader Treasury Department that is
designated as an Intelligence Community element under the National
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Security Act of 1947. With that comes challenges in coordination and
information sharing both within the Treasury Department as a whole, and
with the broader Intelligence Community.
a.

If confirmed, how would you protect IC-related information within
the Treasury Department, while at the same time working with the IC
and the congressional intelligence committees to ensure that we can
accomplish our oversight obligations?
o It is my understanding that OIA’s policies and practices on
protecting IC-related information align with ODNI guidance. If
confirmed, I would meet with my Security leadership team early on
to ensure that is the case. At the same time, I am fully committed
to engaging with OIA’s Congressional intelligence committees to
assist you in accomplishing your oversight objectives.

b.

If confirmed, how will you ensure that OIA’s intelligence information
is protected from information requests directed to the Treasury
Department writ large?
o If confirmed, I will work with OIA and review the existing
procedures and practices to ensure that classified information held
by the Treasury Department continues to be appropriately handled
and protected.

8.

In 2010, then-DNI Clapper established the National Intelligence Manager
for Threat Finance (NIM-TF) and appointed Assistant Secretary Ireland to
the position.
What are your views on the policy of dual-hatting the Assistant
Secretary as the NIM-TF?
Treasury needs to remain as a central player in threat finance. Its
workforce has significant expertise to bring to bear in this important
and growing analytic and reporting area. I understand that the
ODNI is doing a review of all of its positions, including NIMS, and if
confirmed, I will engage early with both Treasury and ODNI leaders
to determine the best use of resources to ensure that Treasury remains
the focal point for Threat Finance.
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a.

If confirmed, how would you use your dual-hatted role to ensure the
necessary integration with the broader IC’s threat finance intelligence
components and efforts?
I have strong ties to many of the players in the IC, particularly ODNI
and CIA. If confirmed, I will ensure that OIA leverages all IC and
USG forums to ensure we are informing decisionmaking in a
transparent and collaborative way, and reviewing all options and
implications of USG actions. OIA will continue to take a leading role
in threat finance efforts, helping to ensure that we are taking a wholeof-government approach.

9.

What legal authorities does OIA primarily rely upon to identify, disrupt, and
dismantle terrorist financing? Do you believe there are additional legal tools
that OIA needs for its efforts against terrorist financing?
 I understand OIA supports Treasury and the U.S. Government under
authorities that include Sections 311 and 312 of Title 31, U.S. Code, as
well as Executive Order 12333, as amended. If confirmed, I will give
careful attention to the question of whether OIA requires any additional
legal authorities to enhance its mission in supporting the U.S.
Government’s whole-of-government approach to identify, disrupt, and
dismantle terrorist financing.

10.

What terrorist organizations are of most concern to OIA? Please describe
how, if confirmed, you would proceed to identify, disrupt, and dismantle the
financial networks of these organizations?
 It is my understanding that OIA’s terrorism priorities are driven by
national terrorism priorities. Accordingly, ISIS and its branches and AQ
and its affiliates would be OIA’s primary concerns right now. I
understand OIA is also looking with great concern at other terrorist
groups operating in Afghanistan and Pakistan, such as the Taliban and
Haqqani Network, among others. It is also my understanding that OIA
closely follows Iran’s IRGC-Qods Force, Hizballah, and Hamas.
Identifying funding networks that support these groups is a unique
intelligence discipline, requiring the right mix of smart analysts, training,
tools, and information. I have had the privilege of working with OIA’s
terrorism analysts in previous positions and I know they are some of the
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best in the IC. I would ensure that OIA retains its highly skilled
workforce, that it can recruit and train top talent, and that its analysts
have access to the tools and information they need to continue supporting
the disruption of terrorist financial networks.
11.

If confirmed, how would you proceed to identify, disrupt, and dismantle the
charities that raise money for terrorist organizations?


12.

I understand OIA is critical to enhancing the collection, analysis, and
sharing of financial intelligence across the U.S. Government on terroristlinked charities. OIA analysts pore over all-source reporting to identify
key vulnerabilities and support the application of Treasury authorities
and policy tools. I plan, if confirmed, to review existing analysis on this
topic and, if necessary, conduct a comprehensive evaluation of how
charities may be involved in supporting terrorism.

What are the challenges that OIA faces regarding virtual currencies, such as
bitcoins, pre-paid cards, and other payment forms that are traditionally
difficult to track? If confirmed, how would you address those challenges?
 Like any payment system or financial product, virtual currencies and
pre-paid cards offer opportunities for both legitimate and illegitimate
use. The primary reason illicit actors use these products is the potential
for greater anonymity in conducting financial transactions. It is my
understanding that OIA works closely with Treasury counterparts and IC
colleagues to gain greater fidelity into the range of tactics, techniques,
and procedures used by terrorists, drug traffickers, and other illicit
actors to obfuscate their financial activity. I will ensure that OIA analysts
focus on both the financial networks associated with national security
threats and laundering methodologies and financial technology more
broadly in order to inform Treasury policymakers of potential
vulnerabilities with non-traditional payment forms.

13.

It is critical that OIA have a workforce that is positioned to address the
challenges posed by virtual currency, financing on the dark web, and other,
new threats. How is OIA working to train and recruit a workforce that is
fluent in how illicit financial networks operate?
 I understand that OIA analysts receive training, mentorship, and
rotational opportunities to help them develop methodological skills and
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fluency with tools and data for analyzing current and emerging illicit
financial networks and mechanisms. Training and employee
development would be a top priority of mine, if confirmed, including an
emphasis on analytic tradecraft to ensure that OIA’s products continue to
exceed IC standards and deliver value to customers.
14.

Recent unauthorized disclosures have motivated different IC elements to
focus on their insider threat programs. How does OIA confront and mitigate
the insider threat challenge? Do you have any plans to revisit and readdress
those programs?
 It is my understanding that Treasury’s Insider Threat Program operates
in accordance with Executive Order 13587. I believe that deterring and
identifying insider threats depends, among other things, on educating the
workforce and maintaining robust insider threat capabilities consistent
with applicable law, regulations, and policies. If confirmed, I will ensure
that the Treasury Insider Threat Program continues to enhance its
capabilities to confront and mitigate insider threats.

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