SELECT COMMITTEE ON
INTELLIGENCE
UNITED STATES SENATE

Additional Pre-Hearing Questions for
Ms. Shannon Corless 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.
• If confirmed for this position, I will ensure that OIA continues to provide the
most timely, accurate, and nuanced intelligence information possible to the
Secretary. I will also ensure that OIA continues to effectively support DNI
Haines and the broader intelligence community (IC) she leads.
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 unaware of any conflicts between the DNI’s priorities and those of the
Secretary. If confirmed, I will coordinately effectively with the Secretary
and the DNI and work diligently to resolve any such conflicts consistent
with Administration priorities.
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?
• Treasury has a long history of enhancing U.S. national security, and OIA’s
mission is critical to Treasury’s work. This role has evolved over time,
along with Treasury’s mission. OIA, as an intelligence community
component within Treasury, works on the cutting edge of global financial
intelligence. OIA was established in 2003 as part of the reorganization of
our intelligence and defense agencies following the terrorist attacks of 9/11.
I understand OIA frequently produces intelligence products for the President
and Cabinet-level officials, as well as Treasury policymakers and fellow IC
components. Over the years, economic sanctions and financial diplomacy
have increasingly become tools of choice for policymakers. If confirmed, I
will support OIA as it continues to build on its strong financial intelligence
knowledge base and analytic expertise to provide critical support to the use
of those important tools.

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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?
• In connection with the nomination process, I have consulted with the Office
of Government Ethics and the Department of the Treasury’s Designated
Agency Ethics Official to identify potential conflicts of interest. Any such
potential conflicts will be resolved in accordance with the terms of the ethics
agreement that I have entered with the Department, which has been provided
to this Committee.
• I intend to comply with the President's Executive order on ethics. If there is
a need for a waiver, I will make the Committee aware.
5. Please describe your current understanding of OIA’s participation in the CFIUS
process. Do you think OIA is well positioned 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 serving as the CFIUS chair is one of Treasury’s
most critical national security responsibilities. I have spent the majority of
my career at ODNI leading the IC’s support to the CFIUS process. If
confirmed, I will work with OIA, TFI and the Office of the Undersecretary
for International Affairs to look at OIA’s contributions to the CFIUS
process.
6. Please explain your understanding of how the oversight roles of the Senate
Select Committee on Intelligence and the House Permanent Select Committee
on Intelligence differ from the oversight roles of other congressional
committees that have oversight jurisdiction for other offices within the Office of
Terrorism and Financial Intelligence and the Treasury Department.
• The Senate Select Committee on Intelligence and the House Permanent
Select Committee on Intelligence share oversight responsibility of executive
branch intelligence activities. As OIA is an intelligence community
component housed within the Department of the Treasury, a non-intelligence
community agency, these important committees provide a critical
intelligence oversight role for intelligence activities and authorities specific
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to OIA. If confirmed, I will ensure OIA works effectively within TFI and
Treasury to facilitate Congress’ important oversight responsibilities.
7. OIA is the only component within the broader Treasury Department that is
designated as an Intelligence Community element under the National 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 If confirmed, I will ensure that OIA continues to work closely with
other Treasury offices and bureaus to ensure that only Treasury
employees with the appropriate security clearances and assigned
mission need have access to intelligence information, consistent with
the need to protect intelligence sources, methods, and activities.
o I recognize that Congress plays an important oversight role regarding
executive branch activities, and I pledge to thoughtfully consider all
congressional information requests, recognizing the importance of
transparency in government. If confirmed, I pledge to work through
the accommodations process to comply with Congressional requests
for information to the fullest extent consistent with the constitutional
and statutory obligations of the executive branch.

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 I understand that OIA has senior disclosure officers who are
experienced in protecting national security and safeguarding classified
information consistent with Treasury’s disclosure obligations. If
confirmed, I will exercise appropriate oversight of this critical
responsibility, and ensure OIA continues to work closely with the
Treasury Legal Division. If confirmed, I will ensure that careful
consideration continues to be given to any request seeking downgrade
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or disclosure of any intelligence information, including delisting
actions, litigation, or OIA’s intelligence information.
8. In 2020, the DNI established the role of Economic Security and Financial
Intelligence Executive (EFX) and appointed you to that role. Given EFX’s
roles and responsibilities, what does Treasury OIA contribute to the financial
intelligence and economic security mission? How has Treasury OIA’s role
changed in recent years, given the increasing importance of that mission?
• The role of the EFX is to align and integrate the IC’s collection and analytic
capabilities against the nation’s most important strategic issues related to
economic security and financial intelligence. I understand OIA’s
contribution to the IC’s financial intelligence and economic security mission,
it’s alignment with IC priorities, and its emphasis on providing timely,
relevant, and accurate intelligence and analysis to the Secretary.
• As economic sanctions and financial diplomacy have increasingly become a
tool of choice for policymakers, the need for timely, accurate, economicfocused intelligence makes OIA indispensable to the Department’s mission
and an asset to the IC. In addition to meeting the daily intelligence needs of
the Office of Foreign Assets Control (OFAC), the Financial Crimes
Enforcement Network (FinCEN), the Office of Terrorist Financing and
Financial Crimes (TFFC), Treasury’s Office of International Affairs, and
Office of Cybersecurity and Critical Infrastructure Protection (OCCIP), OIA
serves as a liaison between the IC and these Treasury policy offices, to
ensure that Treasury policy offices are staffed with the timeliest intelligence
and that the nation’s economic policy considerations are factored into IC
collection efforts.
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?
• It is my understanding that OIA carries out its intelligence mission of
identifying, tracking, and enabling the disruption of threats to the U.S.
financial system -- whether from geopolitical actors, terrorist groups, or
foreign-based criminals -- under authorities provided by Executive Order
12333 and sections 311 and 312 of title 31 of the U.S. Code.
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• If confirmed, I will examine OIA’s tools and authorities to combat terrorist
financing and will work to ensure that OIA staff continue to be fully
equipped to deal with this and other critical national security issues.
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?
• The United States currently faces dynamic and constantly evolving terrorist
threats from groups that seek to target the homeland and U.S. diplomatic and
financial interests abroad. While groups such as al-Qa’ida and ISIS continue
to demonstrate both the aspirations and capacity to target U.S. interests,
there are emerging groups – particularly religiously and ethnically motivated
violent extremists (REMVE) – that also pose a threat to our financial system
and values.
• If confirmed, I will work to ensure that OIA’s unique expertise and tools
continue to be an important part of TFI’s critical work of safeguarding the
U.S. financial system from abuse and bringing malign actors that threaten
the national security of the United States to account for their activities. I
will also work to ensure that OIA plays a leading role in the IC’s efforts in
these areas as well.
11. If confirmed, how would you proceed to identify, disrupt, and dismantle the
charities that raise money for terrorist organizations?
• A critical component of OIA’s mission is to identify not just threats to the
U.S. financial sector but also vulnerabilities in the global financial system
that terrorist groups exploit to raise and move funds. Despite significant
progress over the last two decades, the charitable sector in some countries
remains vulnerable to abuse.
• If confirmed, I will support and work closely with relevant senior officials to
address this critical issue.

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12. What issues related to strategic competition are of more concern to OIA? Please
describe, if confirmed, how you would seek to ensure OIA is able to meet the
financial intelligence mission in light of strategic competition.
• If confirmed, I will work with OIA, TFI and Treasury senior leadership
more broadly to review issues and priorities related to strategic competition.
• I understand that OIA recently stood up a Cyber Directorate to leverage its
cyber analytic, technical, and collection resources to enrich intelligence on
state-supported cyber threats against the U.S. financial sector, as well as on
the financial networks that enable malicious cyber activities.
13. What are the challenges that OIA faces regarding digital assets, such as digital
and crypto currencies, mobile payment platforms, and other electronic payment
forms? If confirmed, how would you address those challenges?
• Malign actors cannot be permitted to utilize cryptocurrency, digital assets,
and other electronic payment forms as a means to evade sanctions, finance
terrorism, or violate U.S. law. If confirmed, I will examine OIA’s tools and
authorities to gather information related to such illicit activity and ensure
that OIA staff are fully equipped to provide timely, relevant, and accurate
intelligence and analysis on the use of digital assets to evade sanctions,
finance terrorism, or otherwise undermine the integrity of the U.S. financial
system.
14. It is critical that OIA have a workforce that is positioned to address the
challenges posed by digital currencies and associated infrastructure, financing
on the dark web, and other, new threats. How should OIA work to train and
recruit a workforce capable of carrying out OIA’s financial intelligence
mission?
•

It is my understanding OIA is fortunate to have many talented and
experienced technical experts on cyber and financial issues. If confirmed, I
will ensure that OIA continues retention efforts that align with broader
Treasury and IC retention efforts and continues to work with Treasury’s
human resources personnel to take the steps necessary to effectively recruit
additional candidates who have those essential skills and qualifications.

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• If confirmed, I will undertake a review of OIA’s training to determine if
modifications to the training program are warranted. In addition, I am aware
that OIA provides an Illicit Finance Course to the larger Intelligence
Community.
15. How does OIA confront and mitigate insider threat challenges? Do you have
any plans to revisit and readdress those programs?
•

I understand that Treasury's Insider Threat Program meets the national-level
standards established by the National Insider Threat Task Force under
Executive Order 13587. If confirmed, I will assess the maturity of the
program, its framework, and its operations to ensure compliance, efficacy,
and efficiency.

16. Unlike other elements of the Intelligence Community, Treasury’s Office of
Intelligence and Analysis has not finalized Attorney General approved EO
12333 procedures. DNI Haines, ODNI General Counsel Fonzone, and
Assistant Attorney General nominee Olsen have all committed to prioritizing
the completion and public dissemination of those procedures. Do you make the
same commitment?
• Yes, I am committed to prioritizing the completion of Treasury’s Executive
Order 12333 procedures and their public release following the Attorney
General’s approval.
17. Do you believe that the People’s Republic of China (PRC) is engaging in a
zero-sum game of economic and technological competition against the United
States?
• As Deputy Secretary Adeyemo has noted, competition with China and
Chinese statecraft is one of the central challenges that the United States and
its allies and partners face in the 21st century. According to the DNI’s 2021
Annual Threat Assessment of the U.S. Intelligence Community, these
challenges include China’s whole-of-government efforts to spread China’s
influence, undercut that of the United States, drive wedges between
Washington and its allies and partners, and foster new international norms
that favor the authoritarian Chinese system.

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18. If confirmed, please list and explain the top five priorities you will have as
Assistant Secretary for Intelligence and Analysis.
• If confirmed, I anticipate my priorities will be:
• Ensuring that OIA is effectively utilizing human resources (to include
recruiting, training, and retaining a diverse staff) to enhance the financial
intelligence expertise of OIA’s workforce, particularly to support efforts
countering China and Russia, as well as supporting Treasury’s sanctions
actions;
• Ensuring that OIA continues to invest in modernizing data and
information technology, and to leverage OIA’s analytic expertise to
maximize the benefits gained from such investments;
• Implementing the priorities of the Secretary and the DNI, particularly
with respect to countering China and ensuring the resiliency of the U.S.
and allied economies;
• Ensuring that OIA is developing and sustaining strong and productive
partnerships with stakeholders across the Department, foreign partners,
and, consistent with applicable authorities, the private sector; and,
• Fostering an agile and innovative workforce.
19. If confirmed, do you commit to use your position and voice to press your
Treasury counterparts to use OIA’s analysis and assessments to advance the
United States’ economic competition with China? If so, how?
• If confirmed, I will commit to working to ensure that OIA’s unique expertise
and tools remain a critical element of Treasury’s efforts maintaining the
nation’s economic leverage and leadership.
20. The PRC, its malign influence, and efforts to rewrite the international rulesbased system is one of the greatest threats to U.S. national security. If
confirmed, do you commit to prioritizing collection and analysis on PRC
exploitation of the U.S. financial system to advance its political and economic
goals?

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• Yes, if confirmed, I will commit to working with the Office of the Director
of National Intelligence to ensure that OIA and IC collection capabilities are
arrayed against the nation’s most important strategic issues related to
economic security and financial intelligence, including challenges presented
by China.

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