Abstract: Bin Laden and his co-conspirators analysed that a small amount of financing was sufficient for the 9/11 attack. Between $400,000 and $500,000 was spent planning and carrying it out. Experts account that a minute percentage of their total budget of $30 million annually is paid for weapons for AQ. Even though profits may be down as of now, AQ could still afford another attack.
Assessing the anticipated damage’s magnitude, the ambitious venture prompted Al Qaeda to support the terrorists. Providing his operatives with most of their funds is how Khalid Shiekh Mahammed (KSM) helped them travel to the U.S., receive training, and live under the radar. While not particularly advanced, their techniques unfortunately proved to reliable. They used ordinary means to move, store, and spend their money, successfully evading the detection measures that were in place at the time. Although today we have some understanding as to how al-Qaeda funded itself before 9/11, the origin of the funds remains unclear.
Problem statement: What could the pre-9/11 era government reforms on financial transactions have looked like to avoid the terrorist attacks altogether?
So what?: To combat terrorism funding, a national framework for public-private partnerships (PPPs) is required, as the private sector is critical in fighting terrorist funding. This framework should establish a platform for the private sector and law enforcement to collaborate on information sharing and coordination. Industry-specific training programs on detecting terrorism funding and risk-based compliance measures should be implemented. All private sector employees should have access to hotlines or reporting systems, and risk-based measures should be created. To raise knowledge of terrorism financing, public awareness campaigns and educational resources should be used. Governments should invest in counterterrorism intelligence and collaborate with other countries to share information and coordinate on counterterrorism actions.
Al Qaeda’s General Financing
Financial support for Al Qaeda (AQ) came from neither Bin Laden personally nor any Sudanese company networks he had access to.[1] According to the Central Intelligence Agency (CIA): to keep operations up and running before 9/11, the organisation turned to a growing pool of contributors, spending roughly $30 million each year. Evidence showed that Bin Laden received just $1 million annually from 1970 to 1994, making it insufficient to sustain his jihad efforts. Bin Laden tried unsuccessfully in 1994 to sell his share of the company to Saudi officials,[2] who declined, thus preventing him from acquiring a sizable amount of wealth. Financial intermediaries, crucial for AQ’s operations, obtained funds from diverse sources, including notable donors in Gulf countries like Saudi Arabia. Mosque Imams also played a role in fundraising by redirecting ‘Zakat’ (a form of religious tax) donations toward supporting radical Islamic groups.
Evidence showed that Bin Laden received just $1 million annually from 1970 to 1994, making it insufficient to sustain his jihad efforts.
CIA’s Failures and Investigation Challenges
Prior to The September 11 Attacks
With no concrete understanding of Osama Bin Laden[3] and AQ prior to the September 11, 2001, attacks, the CIA only had vague estimates of his wealth.[4] Following the White House push, Vice President Al Gore discussed isolating and damaging Bin Laden’s money network with Saudi Crown Prince Abdullah. Following 9/11, the intelligence community developed specialised institutions to restrict AQ’s financial reach and harness financial information as an investigatory asset. A lack of intelligence and an unwillingness to use classified data initially hindered the Office of Foreign Asset Control (OFAC) asset freezes via the International Emergency Economic Powers Act (IEEPA). In response to the 1998 East Africa attacks, President Clinton declared Osama Bin Laden and AQ under the penalty of IEEPA.[5] With AQ deemed by the State Department as a foreign terrorist organisation, banks in the U.S. were ordered to stop processing transactions and freeze their assets. Within U.S. financial organisations in 1999, almost $34 million worth of Taliban possessions were taken by OFAC.[6]
How AQ Moved Money
Before 9/11, it appeared that AQ relied mostly on hawala and couriers to transmit large sums of money for its operations in Afghanistan. Charities were also employed as intermediaries between contributors and AQ officials. AQ operatives and supporters in the West and other financial centres have sometimes utilised the worldwide financial system.
Hawala: Prior to 9/11, AQ utilised hawala to transfer payments owing to Afghanistan’s old and untrustworthy banking infrastructure. Following the 1998 East Africa attacks, Bin Laden turned to established hawala networks in Pakistan, Dubai, and the Middle East. Due to their lack of official monitoring and thorough records, hawalas were appealing to AQ.[7] They utilised a dozen reliable hawaladars, both willing and unsuspecting.
Financial institutions – After Bin Laden travelled to Afghanistan, AQ’s internal finances were in disarray, and the Afghan financial system was primitive. Following the East African bombings and UN resolutions, using official financial institutions became challenging. However, before 9/11, AQ’s extensive network of followers and operatives still managed to utilise the legitimate finance system. Hawaladars, charities, and fund-raisers most likely utilised banks without realising they were facilitating money flow into AQ.[8] These operations flourished because of a lack of legislation and control in the UAE and Pakistan.
Couriers – AQ used couriers as a safe way to deliver finances, typically recruiting from inside the organisation and keeping a low profile. Couriers were often recruited within AQ and had no idea what the monies were for. They collected money from either a hawaladar, financial facilitator, or donor and then delivered it to the intended recipient. For example, AQ utilised a money changer in Pakistan to transfer $1 million from the UAE to Pakistan, then over the border into Afghanistan. The 9/11 transaction, in which plan leader Khalid Sheikh Mohammed (KSM) handed funds to facilitator Abdul Aziz Ali in Dubai, exemplifies AQ’s use of couriers.
AQ’s Expenditure
Before 9/11, AQ’s costs included supporting activities, maintaining its training and military machinery, assisting the Taliban and its high-level leaders, and occasionally supporting other terrorist organisations. The CIA believes that maintaining said standards costs AQ roughly $30 million annually. Bin Laden concentrated his efforts in Afghanistan towards establishing AQ as a fully operational organisation, investing money in military training, support, and propaganda. AQ was extremely well-organised, with a committee structure that included a finance division. Bin Laden was heavily involved in planning each operation and was particularly concerned with money issues. Sheikh Qari Sa’id, a qualified accountant, was the most crucial player in AQ funding. Occasionally, operational commanders may have requested funding directly from Bin Laden, bypassing Sa’id and the finance committee. AQ members funded their own daily costs and depended on the central organisation only for operational expenses. AQ supported various terrorist actions, including the 1998 East African embassy bombings, the 9/11 attacks, the Bali bombings on October 18, 2002, and prospective marine operations against oil tankers in the Strait of Hormuz. Although the actual activities were very inexpensive, there is little evidence that terrorist attacks were hindered by cyclical fundraising.
Bin Laden was heavily involved in planning each operation and was particularly concerned with money issues. Sheikh Qari Sa’id, a qualified accountant, was the most crucial player in AQ funding.
AQ’s Financial Network to Fund An Attack On the American Homeland
AQ gained funds from diverse donors and fundraising efforts through a network of financial facilitators mainly based in Gulf nations like Saudi Arabia. Before 9/11, they channelled funds to AQ through internationally recognised charities. Authoritarian groups might have hidden fundraising operations by concealing their ideological kinship with AQ supporters, as was the case with Zakat funding. After migrating to Afghanistan in 1996, AQ also employed hawala as an informal trust-based process for trading money. Prior to 9/11, AQ spent money as rapidly as it received it, financing jihadist wages, training camps, airfields, automobiles, weapons, and the development of instruction manuals.
Other Sources Of Funds
The 9/11 commission report claims that AQ obtained financing through illegal means, including drug trafficking, blood diamonds, oil smuggling and government backing. However, little evidence supports AQ ‘s involvement in the drug trade and the fact that it might heavily rely on such income. These members, geographically constricted and lacking useful skill sets, were ignored by operatives who established traffickers unengaged in profitable activities and unable to contribute meaningfully while AQ lacked control over territory. According to the 9/11 Commission Report, affluent people in Saudi Arabia, the UAE, and Qatar provided major financial assistance to AQ. The audit also revealed that while the Pakistani Inter-Services Intelligence (ISI) may have offered some financial assistance, there was no proof that the government was actively engaged in the 9/11 attacks.
No Hawalas, Self-Funding, Or State Support
The commission investigations found no evidence of the hijackers using hawala or any other informal value transfer mechanism to send money to the U.S., particularly money that was used for the 9/11 attacks. The interrogated hijackers and other surviving plot members have either not mentioned hawalas or explicitly denied their use.[9] Wire transfers, physical importation of funds, and access to foreign bank accounts were sufficient to support the hijackers. There is no reason AQ would have used hawaladars.[10] The hijackers were not expected to provide their own financing once they arrived in the U.S., except for Nawaf al Hazmi, who worked part-time at a gas station, earning $6/hr.
No Illicit Financial Markets Trading
Evidence uncovered during investigations led by the U.S. administration and the SEC/FBI showed no illicit trades connected to the 9/11 incidents. Their leaders knew too much about the plan and were thus unlikely to profit personally through securities speculation. Financial markets function better when there is complete openness. It’s easy to flag a dubious movement that is posed to be part of a legitimate financial strategy, though the trail can be kept disconnected from the funds used for the attacks committed by terrorists. Investigators looked into the AMR Corp and UAL Corp put trading activities of two shady methods discovered during the Securities and Exchange Commission (SEC) and Federal Bureau of Investigation (FBI) probe.[11] Investigations were conducted through coordination with nations owning significant U.S. securities trading interests. The U.S. government questioned hundreds of agents despite seizing papers. However, no proof exists of insider trading in overseas equities before 9/11 benefiting AQ.[12]
AQ Fundraising In the U.S.
Despite sources within the U.S. being a minor financial contributor to AQ, some funds raised there might have gone towards supporting the group. A jihadist network within the U.S. had allowed AQ to access funds from Mujahidin connected to AQ for financial backing.[13] Still, no clear signs indicate extensive U.S.-based funding for AQ’s existance. Despite common perception, AQ did not cooperate with Hamas, Hezbollah, or Palestinian Islamic Jihad on fundraising initiatives.
The Financing Behind 9/11
The 9/11 commission’s study was based on significant investigations conducted by the U.S. government, primarily the FBI. The staff independently reviewed the previous investigation, gaining access to evidence of the plotters’ bank activities, FBI work product, and witness interviews. They spoke with important personnel from various agencies, including the CIA and the Financial Crimes Enforcement Network (FinCEN). The FBI also interviewed law enforcement officers, examined investigative materials, and questioned witnesses from the business sector. The team was also routinely updated on the interrogations of plot members in detention. The inquiry was founded on substantial government investigations. The relevance of the plot’s finances appeared in a somewhat elaborate manner.
The 9/11 plotters spent between $300,000 and $500,000 to plan and execute their operation – most of which AQ funded. Although the source of the funds is unknown, significant research has revealed much about the financial transactions that might have aided the 9/11 conspiracy. The hijackers and their financial facilitators took advantage of the anonymity afforded by the vast international and domestic banking systems to move and store funds. They did so via a series of ordinary transactions. The established measures for preventing financial system misuse did not fail. They were never intended to identify or disrupt the kind of transactions that financed 9/11. According to the pieces of evidence, the 19 operatives were sponsored by AQ, either by wire transfers or cash handed over by KSM, which they took into the U.S. or deposited in foreign banks and accessed from within the nation. The 9/11 commission’s investigation found no credible evidence that anyone in the U.S. gave the hijackers significant financial assistance. Similarly, no proof of any foreign government or foreign government official providing funds has been discovered.
The 9/11 plotters spent between $300,000 and $500,000 to plan and execute their operation – most of which AQ funded.
There is no evidence that the members of the Hamburg cell (Mohamed Atta, Marwan al-Shehhi, Ziad Jarrah, and Ramzi Binalshibh) received money from AQ before late 1999. KSM, Binalshibh, and another plan facilitator, Mustafa al Hawsawi, each received money to carry out their roles in the scheme, perhaps up to $10,000. When the Hamburg recruits joined the 9/11 plot, AQ began to fund them. Before the operatives arrived in the U.S., the commission’s grasp of the funds was murky.
Before Arrival In the U.S.
Prior to the hijacker’s landing in the U.S., AQ absorbed the expenditures associated with the 9/11 hijacking plot. Atta, Shehhi, Jarrah, and Binalshibh of the Hamburg cell got $5,000 (plus additional pocket money) for their return from Afghanistan to Germany in late 1999 or early 2000. The three Hamburg pilots were also given extra money to travel to the U.S. Following training, they were given $2,000 to go to Saudi Arabia to get new passports and visas,[14] as well as $10,000 to help them travel to the U.S. There is no indication that members of the Hamburg cell received cash from AQ prior to late 1999.
The UAE military was financing Shehhi’s studies in Germany. He continued to receive a salary throughout December 23, 2000. Binalshibh worked occasionally in Germany until November 1999, and his family supported Jarrah. The Spanish AQ cell, directed by Barkat Yarkas and including AQ European financier Mohammed Galeb Kalaje Zouaydi, did not fund 9/11 or the Hamburg plotters. The training camps where the 9/11 hijackers were recruited and trained were also paid for by AQ, although this was not included in the plan’s expenditures.
Financing In the U.S.
The FBI identified $300,000 in funds put in the bank accounts of 9/11 hijackers in the U.S.[15] The funds were used for flight training, living expenses, and travel. The FBI believes the payments were adequate to cover their expenses. The commission’s investigation found no evidence to the contrary; however, it is possible that the $300,000 figure includes cash brought into the country by the hijackers and spent without being deposited into a bank account or otherwise creating a record. AQ funded the hijackers in the U.S. via wire or bank-to-bank transfers, actual cash or traveler’s checks, and the use of debit or credit cards to access funds held in foreign financial institutions. When the hijackers landed in the U.S., they used the banking system to store their cash and facilitate transactions. They were assisted by two UAE facilitators, Ali Abdul Aziz Ali and Mustafa al Hawsawi, as well as, to a lesser extent, Binalshibh, who helped fund the operation from Germany. The FBI believed it had uncovered every conceivable source of funding.[16]
The FBI believes the payments were adequate to cover their expenses. The commission’s investigation found no evidence to the contrary.
Wire Transfers
Upon their arrival in the U.S., the hijackers collected around $130,000 from foreign facilitators via wire or bank-to-bank transactions. Most transfers came from Dubai, UAE, and were transferred by plan facilitator Ali, who was KSM’s nephew. Before the September 11 attacks, Ali resided in the UAE for several years and worked for a computer wholesaler in a free trade zone. Later in 2000, KSM sent the majority of the funds through courier. Between April 16, 2000, and September 17, 2000, Ali sent a total of $119,500 to the hijackers in six transactions. Ali used aliases and sent $114,500 to Shehhi and Atta from the UAE Exchange Centre in Dubai. He sent $5,000 to a Western Union facility in New York and made four bank-to-bank transactions to Shehhi and Atta’s SunTrust Bank checking account in Florida. All transactions were routed through the UAE Exchange’s Citibank correspondent account. After 9/11, Ali provided enough personal information for the FBI to decipher the aliases. He relied on the secrecy afforded by Dubai’s financial district and the enormous worldwide banking system. He transferred the remaining $70,000 in one transfer since Shehhi requested that he “send him everything.” KSM was upset, but Ali knew that Dubai computer businesses often transmitted such large sums of money.[17]
Ramzi Binalshibh helped finance a scheme by sending over $10,000 from Germany to the U.S. He sent $2,708.33 by Traveler’s Express/Moneygram from Hamburg to Shehhi in New York, $1,803.19 via Western Union from Hamburg to Shehhi in Florida, and two Western Union transfers from Hamburg to Shehhi in Florida. Binalshibh paid for these transfers by withdrawing funds from Shehhi’s Dresdner Bank account.[18] None of the financial transfers related to the scheme elicited substantial suspicion. They were almost undetectable among the billions of dollars in wire transfers that occur daily throughout the world.
Importation of Cash and Traveler’s Cheques
The hijackers, Khalid al-Mihdhar and Nawaf al Hazmi, brought a significant amount of cash and traveller’s checks to the U.S. They opened an account at Bank of America in San Diego with a $9,900 deposit after arriving in Los Angeles on January 15, 2000. They presumably brought extra money since they needed to pay for products and services. KSM provided Hazmi $16,000 to cover his and Mihdhar’s travel and living expenses. Shehhi also carried cash, purchasing $2,000 in traveller’s checks from a New York bank two days after his arrival in New Jersey on May 31, 2000. Before departing from Germany, he seems to have removed this cash from his Dresdner Bank account.
Similarly, Jarrah established an account with a bank in Venice, Florida, on June 28, two days after landing in the nation, with a $2,000 cash deposit, most likely monies he brought with him. Mihdhar and Hazmi transported a large sum of cash and traveller’s checks to the U.S. After landing in Los Angeles on January 15, 2000, they established an account with Bank of America in San Diego on February 04, 2000, with a deposit of $9,900. The 13 hijackers who arrived in the U.S. between April 23 and June 29, 2001, brought with them cash or traveler’s cheques for their own expenses and to replenish the funds of the hijackers who had previously arrived. An investigation confirmed that six of the muscle hijackers who arrived in this period purchased traveler’s checks totalling $43,980 in the UAE and used them in the U.S.[19]
Ali Abdul Aziz Ali and Mustafa al-Hawsawi supported the hijackers on their way to the U.S. logistically. Al-Hawsawi’s diary indicates payments he made to or on behalf of hijackers crossing the UAE in June. He assisted the hijackers when they were in the UAE, giving them his phone number and arranging lodgings and meals. It is unknown why Hawsawi became engaged in the conspiracy, but Ali asked for help from KSM to prevent jeopardising his day job with a computer business. Hawsawi was ordered to assist him, but the hijackers had left Dubai by the time he arrived and did not require much of his time.
Funding For the Other Plot Participants
For their participation in the 9/11 plan, AQ donated funds to 19 hijackers. KSM spent $6,000 of his earnings to rent a safehouse in Karachi, but Ali did not require any assistance because he resided and worked in the UAE. AQ compensated Hawsawi, a UAE-based plot facilitator, for his travel and living expenses related to 9/11 and other AQ activities. Hawsawi incurred significant costs on behalf of the plot. Hawsawi claimed to have received $30,000 in cash from AQ finance manager Hamza al Qatari and $3,000-$4,500 in cash from Fayez Banihammad, all of which were allegedly provided by KSM or Qatari. The rest of the events are listed out as chronologically as they can be:
Binalshibh claimed to have met KSM in June 2001 in Karachi and got $5,000 from Abu Hafs to fund his visit. These funds, however, were less than Hawsawi’s known expenses in the UAE. The money he brought covered living expenses, purchasing supplies, wiring $16,500 to Binalshibh, and wiring funds to another AQ operative in Saudi Arabia. He also provided $13,000 to another AQ operative transiting from the UAE before departing for another operation on September 10, 2001.
In August 2001, Hawsawi received two wiretransactions totalling $6,500 from a Sudanese individual living in Saudi Arabia.[20] Binalshibh, who met KSM in Karachi in June 2001, was given a plane ticket to Malaysia as well as $5,000 by Abu Hafs to help fund his trip.[21]
On September 03, 2001, Hawsawi transferred $1,500 from the UAE to Binalshibh in Hamburg under an identity to cover his following flight from Germany. Binalshibh supported his actions by controlling Marwan al Shehhi’s bank account, which he accessed using an ATM card with the help of Mounir Motassadeq. Atta wired a $1,500 wire transfer via Western Union from Florida to Binalshibh in Hamburg in January 2001, which appears unusual given that Binalshibh had access to Shehhi’s German account at the time.
For their participation in the 9/11 plan, AQ donated funds to 19 hijackers.
Overseas Accounts
The hijackers funded their actions in the U.S. by gaining access to funds deposited in foreign banks. Hani Hanjour had accounts with the Saudi British Bank in Saudi Arabia and Citibank in the UAE. While in the U.S., he used an ATM card to access his international accounts, depositing roughly $9,600 into the Saudi British Bank account and $8,000 into the Citibank account. Ali stated that he sent Hanjour $3,000 to start the Citibank account and then deposited another $5,000 into it while Hanjour was in the U.S. Fayez Banihammad also established a foreign account for fundraising in the U.S. He created two accounts with Standard Chartered Bank in the UAE and deposited around $30,000 in UAE dirhams. Hawsawi was given power of attorney and, with the assistance of Hanjour, obtained the Visa card from the bank after he left for the U.S. and delivered it to Banihammad. Banihammad used both cards to fund the conspiracy after landing in the country, using the Visa card to acquire 9/11 aircraft tickets and pay his Boston hotel bill. On August 20, 2001, Hawsawi increased Banihammad’s finances by depositing $4,900 into Banihammad’s SCB account.[22]
Use Of U.S. Banks
In the U.S., the hijackers utilised a variety of institutions, including renowned international banks like Bank of America and SunTrust and smaller regional banks including Hudson United Bank and Dime Savings Bank. SunTrust may have been selected by plot founders Atta and Shehhi because their Florida flying school banked there and urged its pupils to utilise it.[23] Using passports and other forms of identification, the hijackers frequently established checking accounts and Visa debit card accounts at the same time.
There is no indication that the hijackers ever opened bank accounts using phoney social security numbers. In certain situations, a bank staffer entered the hijacker’s date of birth or visa control number into the social security number section on the new account application on their own.
False Numbers and Aliases
The hijackers were unfamiliar with the American banking system. For example, a SunTrust banker who created the original Atta-Shehhi joint account in July 2000 spent roughly an hour with them explaining the wiring process. The hijackers once again attracted suspicion at a SunTrust bank in Florida in June 2001 while attempting to cash a $2,180 cheque.[24] The bank manager declined to sign the cheque and sent an internal notice to other branches to keep an eye on the account for potential fraud. However, Binalshibh, using an alias, sent $14,000 in two instalments to Zacarias Moussaoui in early August 2001. Binalshibh received the money for these transfers from Hawsawi, wired in two instalments on July 30 and July 31, 2001.[25]
The hijackers were unfamiliar with the American banking system. A SunTrust banker who created the original Atta-Shehhi joint account in July 2000 spent roughly an hour with them explaining the wiring process.
Return Of Funds to AQ
The Hadith prompts the community to pay a martyrdom tax known as ‘Istishadi’ to the “martyr’s” family. It can be speculated that the money remaining from the operation was to be equally divided and added to the tax owed to the families. The hijackers collected their surplus monies and shipped them to Hawsawi in the UAE between September 05 and September 10, 2001. Fayez Banihammad sent $8,000 from his SunTrust Bank account to his Standard Chartered Bank account in the UAE and then transferred $18,260 to Hawsawi via four Western Union wire transactions. On September 10, Hazmi and Mihdhar transferred their surplus cash into an account maintained by Mihdhar at First Union Bank in New Jersey, raising the amount to $9,838.31. Hazmi and Hanjour delivered the debit card connected to Mihdhar’s First Union account to a P.O. box in the UAE rented by Hawsawi. Following the 9/11 attacks, a receipt for the mailing of this item was discovered in Hazmi’s car at Dulles International Airport, and the FBI intercepted the package. Binalshibh and Atta discussed the return of funds, and Hawsawi withdrew around $7,880 in dirhams from Banihammad’s Standard Chartered Bank account using a blank check and ATM card. He then transferred $41,000 to his Standard Chartered Bank Visa card before departing Dubai for Karachi, Pakistan, leaving some money in the account. KSM utilised a supplementary Visa card issued for Hawsawi’s Standard Chartered Bank account to withdraw $900 from ATMs in Karachi.[26]
Origins Of the Funds
The U.S. government has yet to pinpoint the source of the finances used in the 9/11 attacks, despite evidence linking them to KSM and potentially Qatari, but no further.[27] According to KSM, Bin Laden donated 85–95% of the funding, with the rest coming from general AQ finances. However, this assertion is questionable, as Bin Laden did not personally finance AQ during the period. A minor portion of the scheme’s finances came from Shehhi’s bank account, probably from his military pay. Binalshibh transferred $10,000 to Shehhi in the U.S. Yazeed al Salmi, a Saudi citizen, may have sent money to a hijacker, but there is no proof that Salmi ever gave Hazmi any further dollars.
The U.S. government has yet to pinpoint the source of the finances used in the 9/11 attacks, despite evidence linking them to KSM and potentially Qatari, but no further.
In the end, and more importantly, the origin of the cash has little practical consequence. AQ certainly had several financial sources. If one source of funding were to be stopped, it could easily have turned to another or redirected funds from another project to support an attack that cost $400,000–$500,000 over nearly two years.[28]
Total Cost
The estimated costs range from $400,000 to $500,000 for the 9/11 attacks. The hijackers spent about $270,000 in the U.S. Additional expenses include the costs associated with obtaining passports and visas and those spent by leaders and facilitators during their trip to the U.S. Training camp establishment in Afghanistan, alongside other costs, were left out of the estimated budget. About $400,000 was the estimated overall cost, according to KSM, who planned the plot and paid the hijackers and others involved.
Although the exact number is unknown, the costs appear reasonable given the details. Experts account that a minute percentage of their total budget of $30 million annually is paid for weapons for AQ. Even though profits may be down now, AQ could still afford another attack.[29]
Neglected Red Flags
The hijackers’ transactions were not unusual or noteworthy. They frequently followed a pattern of making significant deposits, withdrawing cash, and occasionally writing checks. The FBI reports said that the transactions resulted in numerous red flags that, if reported by either Bank of America or SunTrust, would have avoided the disaster. The hijackers opened accounts in the U.S. using visas issued by their native governments, with an average amount of $3,000 to $5,000. These accounts were mostly joint and opened within 30 days of their entry.
The hijackers often used the same address and telephone numbers on the accounts. Twelve hijackers opened accounts at the same bank, and some accounts directly received and sent wire transfers from UAE, Saudi Arabia and Germany. Over $100,000 was wired from the UAE and Saudi Arabia from Khalid Al-Mihdhar’s account to the German account of the hijacker Mohamed Atta in a 15-month period.[30] The hijackers made numerous attempts to withdraw cash in excess of the debit card limit, making numerous balance inquiries.
The overall transactions were below reporting requirements, with funding from cash and overseas wire transfers. ATM transactions occurred with multiple hijackers present, creating a series of transactions involving several hijackers at the same ATM. Contrary to frequent media accounts, no financial institution submitted a Suspicious Activity Report (SAR) in connection with any of the 19 hijackers prior to 9/11, yet such SARs were made after the hijackers’ names became public.[31]
An Assessment
Post 9/11, there was a case of open help from contributors and those showing sympathy towards AQ. The long-term effects of these actions are unknown. Little evidence served as a foundation to assign early designations, which later sparked court battles. Rapid actions regarding intelligence requests are required and must be done openly. With multilateral methods, there is now a necessary waiting time before money can be locked down, eliminating the element of surprise and providing a safety net to the assailants.[32] Evading vigilance is made easy despite sufficient measures being enforced for global account freezes and asset seizures. However, other benefits exist beyond stopping funds, including forcing groups to resort to costly methods and labelling them as terrorists.[33]
Post 9/11, there was a case of open help from contributors and those showing sympathy towards AQ. The long-term effects of these actions are unknown.
9/11 Commission Report Recommendations
The government has made progress against fund creation and dissemination by successfully targeting AQ-reliant financiers. Put differently, recognising that identifying terrorist funding sources could help track and stop their activities – since 9/11, the U.S. government vigilantly monitors terrorist finance. With fewer funds available, AQ faces increased costs and complexity upon collection and transportation following key figure eliminations or arrests.
Intelligence gathered through captures could potentially be used to sustain the disruptive cycle. Financial institutions, both domestic and international, have offered immense help to law enforcement agencies and intelligence services by providing relevant data during probes. Labelling terror groups publicly may never lead to a perfect result. Countering AQ requires raising the financial burden and danger of planning and executing large-scale attacks.[34]
Vipul Tamhane is a specialist in anti-money laundering and combating terrorist financing. He provides legal and commercial advice to businesses, governments, and law enforcement organisations. While being a visiting faculty member at Pune University’s Department of Defence and Strategic Studies, he is also the founder and editor-in-chief of Diplomacy Direct, a public interest Think Tank (and YouTube Channel) based in India. He often writes about counterterrorism, international relations and geopolitics. The views contained in this article are the author’s alone.
[1] Clarke testimony before the Senate Banking Committee, Oct. 22, 2003; see Clarke’s testimony to the Congressional Joint Inquiry. Contemporaneous documents support Clarke’s recollection concerning his frustration. For example, in November 1998, Clark wrote that four years after the NSC first asked the CIA to track down UBL’s finances, the CIA could only guess at the main sources of Bin Ladin’s budget, where he parks his money, and how he moves it.
[2] State Department memorandum, Nov. 24, 1998 (“We are still far, however, from possessing detailed information that would enable us to approach key Middle Eastern and European government with specific action requests concerning Bin Ladin’s financial network”).
[3] Amy B. Zegart, “September 11 and the Adaptation Failure of U.S. Intelligence Agencies,” International Security 29, no. 4 (2005): 78–111.
[4] CIA, Intelligence reporting, April 12, 2001.
[5] Anne L. Clunan, “The Fight against Terrorist Financing,” Political Science Quarterly 121, no. 4 (2006): 569–96.
[6] TERRORIST ASSETS REPORT, Calendar Year 2008, Seventeenth Annual Report to Congress on Assets in the United States of Terrorist Countries and International Terrorism Program Designees, Executive Orders 12947 and 13099 – Specially Designated Terrorists (SDTs)
[7] A definition of hawala is contained in the case study of the al-Barakaat network. Additionally, a good discussion of hawala is found in U.S. Department of Treasury, A Report to Congress in Accordance with Section 359 of the USA PATRIOT Act, November 2002 (online at www.fincen.gov.hawalarptfinal11222002.pdf).
[8] Hawala was frequently combined with other means of moving money. For a single transaction, the hawaladars sometimes used both hawala and the formal banking system or money remitters; the senders and receivers of the funds also often used couriers to transfer the funds to and from their respective hawaladars. Hawala also enabled operatives to access the banking system without having to open an account.
[9] CIA, 9/11 Detainee Interrogation Reports Chapters 5 and 7, Guantánamo Bay, January 11, 2002.
[10] Lawrence Malkin, and Yuval Elizur, “Terrorism’s Money Trail,” World Policy Journal 19, no. 1 (2002): 60–70.
[11] September 18, 2001, Associated Press Report.
[12] John Roth Douglas Greenburg Serena Wille, 9/11 Monograph, National Commission on Terrorist Attacks Upon the United States, Staff Report to the Commission, Pg. 149. The press has reported this claim, and the allegation even found its way into the congressional testimony concerning the terrorist financing of a former government official. The government investigation would have detected such traders because the investigators focused on people who purchased profitable positions— regardless of when, whether or when they closed out the position. Moreover, officials at the SEC and the Options Clearing Corporation, a private entity that processes options trading, pointed out that any profitable options positions are automatically exercised upon the expiration date unless the customer explicitly directed otherwise. Any direction not to exercise profitable options is a highly unusual event, which the OCC double-checks by contacting the broker who gave them such instruction. The OCC personnel had no recollection of any such contacts after 9/11.
[13] National Commission on Terrorist Attacks, 2004, The 9/11 Commission Report, New York, NY: WW Norton.
[14] 9/11 Commission report, Sa’id reportedly vetoed a $1500 expense for travel to Saudi Arabia to get visas for the 9/11 attacks until Bin Ladin overruled him (although there is no reason to believe that Sa’id knew the reason for the travel at that time).
[15] FBI Assistant Director, Counterterrorism Division, John S. Pistole, stated during a congressional hearing last fall that “the 9/11 hijackers utilized slightly over $300,000 through formal banking channels to facilitate their time in the U.S. We assess they used another $200-$300,000 in cash to pay for living expenses . . .” Senate Committee on Banking, Housing, and Urban Affairs, September 25, 2003, FDCH Political Transcripts at page 5. His statement concerning additional cash was apparently made in error. The FBI personnel most familiar with the 9-11 investigation have uniformly disagreed with it, and the FBI has never conducted any financial analysis that supports it. Although some FBI personnel involved in the early days of the investigation after 9/11 believed the hijackers had substantially more cash than that which was deposited in their accounts, the FBI view after a more thorough investigation is to the contrary.
[16] Amy B. Zegart, “September 11 and the Adaptation Failure of U.S. Intelligence Agencies,” International Security 29, no. 4 (2005): 78–111.
[17] Central Banker Sultan bin Nasser al-Suweidi was quoted in the press earlier this year as contending that the UAE reported to U.S. officials Ali’s large wire transfer to Al-Shehhi a year before 9/11. See Associated Press, Dubai Banks Remain Focus of Terror Funding Investigation (January 17, 2004) (printed from WSJ.Com, 2/5/05). We have found no evidence the UAE provided any such notification. We have been told Al-Suweidi later backed off the statement in discussions with the FBI.
[18] Josh Meyer, Greg Krikorian, and William C. Rempel, “Quiet Investigation Centers on Al Qaeda Aide in New York,” Los Angeles Times (September 03, 2004).
[19] 9/11 Commission Report, The FBI has confirmed purchases by Majed Moqed, Wail Al-Shehri, Ahmed Al-Haznawi, Saeed Al-Ghamdi, Hamza Al-Ghamdi, and Ahmed Al-Nami.
[20] United States, 9/11 Commission, “Chapter 7: The Attack Looms,” 215-241. In The 9/11 Commission Report: Final Report of the National Commission on Terrorist Attacks Upon the United States. Washington, D.C.: U.S. Government Printing Office, 2004.
[21] Ibid. The meeting in Malaysia ultimately did not take place because Atta was busy awaiting the arrival of the additional hijackers in the U.S.; the meeting took place later in Spain.
[22] United States, 9/11 Commission, “Chapter 5: Al Qaeda Aims at the American Homeland,” (2004): 145-169. In The 9/11 Commission Report: Final Report of the National Commission on Terrorist Attacks Upon the United States. Washington, D.C.: U.S. Government Printing Office, 2004.
[23] 7.2, “The Hamburg Pilots Arrive in the United States”, United States, 9/11 Commission, “Chapter 7: The Attack Looms,” 215-241. In The 9/11 Commission Report: Final Report of the National Commission on Terrorist Attacks Upon the United States. Washington, D.C.: U.S. Government Printing Office, 2004.
[24] Rohan Gunaratnam “AL QAEDA’S GLOBAL NETWORK,” In Inside Al Qaeda: Global Network of Terror, 95–166. Columbia University Press, 2002.
[25] 9/11 Commission Report, Binalshibh and Al-Hawsawi both used aliases for these transactions.
[26] 9/11 Commission Report, The supplemental Visa card had been applied for on August 25, 2001, in the name of an alias used by KSM.
[27] FBI Assistant Director Pistole testified that the FBI had traced the funds back to certain bank accounts in Pakistan, see Senate Govt. Affairs Committee, July 31, 2003, but the FBI has clarified that Pistole meant the funds were traced back to KSM in Pakistan. No actual bank accounts there have been identified.
[28] Stanley R. Sloan, and Lawrence Freedman, “The 2000s: Turbulent Transatlantic Ties,” In Defense of the West: Transatlantic Security from Truman to Trump, Second Edition, 182–252. Manchester University Press, 2020.
[29] United States, 9/11 Commission, “Chapter 5: Al Qaeda Aims at the American Homeland,” (2004): 145-169. In The 9/11 Commission Report: Final Report of the National Commission on Terrorist Attacks Upon the United States. Washington, D.C.: U.S. Government Printing Office, 2004.
[30] United States, 9/11 Commission, “Chapter 5: Al Qaeda Aims at the American Homeland,” (2004): 145-169. In The 9/11 Commission Report: Final Report of the National Commission on Terrorist Attacks Upon the United States. Washington, D.C.: U.S. Government Printing Office, 2004.
[31] Shima Baradaran, Michael Findley, Daniel Nielson, and Jason Sharman, “Funding Terror,” University of Pennsylvania Law Review 162, no. 3 (2014): 477–536.
[32] Rohan Gunaratna, “Responding to the Post 9/11 Structural and Operational Challenges of Global Jihad,” Connections 4, no. 1 (2005): 9–42.
[33] John Roth Douglas Greenburg Serena Wille, “9/11 Monograph, National Commission on Terrorist Attacks Upon the United States,” Staff Report to the Commission, 47.
[34] United States, 9/11 Commission, “Chapter 13: How to Do It? A Different Way of Organizing the Government,” 399-423. In The 9/11 Commission Report: Final Report of the National Commission on Terrorist Attacks Upon the United States. Washington, D.C.: U.S. Government Printing Office, 2004.