VZCZCXRO2954
RR RUEHBC RUEHDA RUEHDE RUEHIHL RUEHKUK
DE RUEHGB #1348/01 1220957
ZNR UUUUU ZZH
R 010957Z MAY 08
FM AMEMBASSY BAGHDAD
TO RUEHC/SECSTATE WASHDC 7123
INFO RUCNRAQ/IRAQ COLLECTIVE

UNCLAS SECTION 01 OF 02 BAGHDAD 001348 
 
SIPDIS 
 
SENSITIVE 
SIPDIS 
 
E.O. 12958: N/A 
TAGS: ECON EFIN PGOV PREL KTFN KCRM PTER SNAR IZ
SUBJECT: RESULTS OF FINANCIAL SYSTEMS ASSESSMENT TEAM VISIT TO THE 
KURDISTAN REGION OF IRAQ (SECOND OF TWO CABLES) 
 
NOTE: This cable is Part II of a two-part report. See Reftel for 
Part I. END NOTE 
 
Asayeesh (Special Police) 
------------------------- 
 
¶43. (SBU) The Asayeesh (Special Police) has jurisdiction over crimes 
such as terrorism and terrorist financing.  The Asayeesh is set up 
to be somewhat self-contained so that it can conduct its 
investigations without alerting a large group of people.  Where the 
Asayeesh have a presence, such as at a station, they have 
investigative judges devoted to the Asayeesh that follow and 
coordinate the legal process with felony courts.  Prosecutors do not 
get involved until the case gets to the investigative judge.  The 
Asayeesh also has its own legal department with judicial 
investigators, who can file for warrants with the investigative 
courts.  There are some senior officers within the Asayeesh who can 
file for the warrants directly with the court.  There are also 
officers who went to college and studied law who can also file 
directly with the court.  There is also a special economic section 
within the Asayeesh who coordinates investigations related to 
terrorist financing. 
 
¶44. (SBU) The Asayeesh noted that terrorist financing in the 
Kurdistan Region had some unique characteristics.  Because of a lack 
of sympathy by the local population to AQI and related groups, it is 
difficult for these groups to conduct meaningful fundraising in the 
Kurdistan Region.  According to the Asayeesh, the primary funding 
and support sources, including weapons, for these groups are foreign 
intelligence services, with secondary contributions from Zakat 
(mostly from individuals in Saudi Arabia).  The Asayeesh noted that 
AQ had a strong financial structure under Zarqawi, but that it is 
less effective now, with AQ relying more on alternate sources 
including kidnappings, zakat and the smuggling of cash. 
 
¶45. (SBU) The Asayeesh noted a shift away from the use of cash 
towards the use of goods to raise and move value.  The Asayeesh also 
noted that former regime members abroad often provided funding 
through this mechanism.  Basically, the terrorists and other 
criminal entities will ship goods into Iraq legally.  The goods are 
whatever is desired on the market, and profit is not the ultimate 
goal.  Rather, the goods are purchased elsewhere, shipped into Iraq, 
sold inside of Iraq and the money from the sale goes to supporting 
terrorists or other criminal groups.  Because of the connection with 
Zakat and the increased use of goods, the Asayeesh is increasingly 
concerned with charities and front companies as vehicles for the 
movement of terrorist funds. 
 
¶46. (SBU) The Asayeesh noted that it had a cooperative relationship 
with the money exchangers and transmitters and that this 
relationship had helped the Asayeesh prevent a number of terrorist 
attacks including at least two major terrorist operations.  This 
relationship also assisted in the investigation of the May 9th 2007 
bombing of the KRG Ministry of Interior in Erbil. 
 
¶47. (SBU) The Asayeesh noted that while the money transmitters were 
cooperative in this investigation, their efforts were hampered by 
the lack of customer identification records, as well as multiple 
transfers and exchange transactions.  The Asayeesh was able to 
obtain valuable information, but it had to obtain and analyze a 
great deal of transactional information from the money exchangers 
because of the lack of customer identification requirements.  The 
money changers and transmitters were unable to verify the identities 
of the end users of the money they were moving.  The Asayeesh has 
asked the MOI to close down money remitters and exchangers, in the 
hopes that the public will then use the formal banking sector to 
conduct money movements, where it will be easier to track said 
movements, at least in theory. 
 
¶48. (SBU) According to the Asayeesh sources, most of the funding for 
the PKK is cash smuggled in from Europe and to a lesser extent from 
Turkey and Iran. 
 
Asayeesh Challenges and Vulnerabilities 
--------------------------------------- 
 
¶49. (SBU) The Asayeesh clearly understands the terrorist threat and 
investigates terrorist financing.  While the Asayeesh has developed 
a beneficial rapport with the money exchange/transmitter sector, 
they do not have a similar relationship with the MLRO.  The Asayeesh 
could also benefit from formal financial "follow the money" 
investigative training, but geared more towards a cash-based 
society, given the current limitations of the Kurdistan Region's 
banking sector. 
 
Intelligence Sector 
------------------- 
 
¶50. (SBU) The KRG intelligence community is spread across several 
areas.  The Parastin and Zanyari are mainly responsible for external 
 
BAGHDAD 00001348  002 OF 002 
 
 
intelligence operations while the Asayeesh is mainly responsible for 
internal intelligence operations.  However, the lines between 
internal and external are not absolute - the Parastin and Zanyari do 
collect intelligence inside the Kurdistan Region. 
 
¶51. (SBU) All components of the KRG intelligence community recognize 
the usefulness of financial intelligence - as noted elsewhere in 
this paper, the KRG intelligence community used financial 
intelligence to track down the perpetrators of the May 9th MOI 
attack. 
 
¶52. (SBU) The KRG intelligence community has demonstrated that it 
has well-developed sources in and outside Iraq.  They, like all 
other sectors of the KRG, would benefit from additional equipment 
and training - especially Threat Finance training. 
 
Ports of Entry (POEs) 
--------------------- 
 
¶53. (SBU) The FSAT did not have the opportunity to visit the primary 
land ports of entry.  The FSAT did, however, have the opportunity to 
visit the Erbil International Airport (EIA), the primary air port of 
entry in the Kurdistan Region.  The FSAT was able to meet with the 
EIA representatives responsible for security.  The FSAT noted that 
the EIA was modern, had trained staff and modern security equipment 
and procedures.  Furthermore, there is a major construction project 
currently underway to build a substantially larger new terminal that 
will augment the current terminal.  It will allow for more planes 
and handle many more flights in a year.  The new terminal is 
scheduled to be completed by early 2009.  The FSAT believes that 
specialized training on the identification, prevention, and 
investigation of bulk cash smuggling would be beneficial to selected 
security and border personnel at POEs throughout Iraq. 
 
Conclusion and Recommended Training 
----------------------------------- 
 
¶54. (SBU) The Kurdistan Region of Iraq is currently in the infancy 
of developing a modern financial sector.  The FSAT notes the KRG's 
strong political will to combat terrorist financing, particularly 
involving terrorist groups such as AQI , Ansar Al Sunna, and related 
groups, as well as a strong desire for training and technical 
assistance.  The current disconnects between entities within the 
Kurdistan Region and between the KRG and the Government of Iraq 
(GOI), hamper overall efforts to combat terrorist financing and 
money laundering throughout all of Iraq, including the KAR.  The 
FSAT recommends giving serious attention to using technology to 
create stronger communication among these entities.  Most 
importantly, the Central Bank must re-evaluate its policies and 
approach to creating a situation in which the public is willing to 
use the banking sector as its primary way to move and store funds. 
 
¶55. (SBU) Based on our assessment the FSAT team would recommend that 
priority consideration be given to the following training 
initiatives:  1) Basic Financial and Regulatory training for the 
Central Bank employees from both the branches and headquarters; this 
should include fundamental banking, credit analysis, compliance 
(anti-money laundering and counterterrorist financing) and 
information technology courses; 2) Training on the AML law and the 
AML prosecutions for judges and prosecutors; 3) basic financial 
crimes investigations training for the MOI and Asayeesh;  and 4) 
Bulk Cash Smuggling training; 5) Threat Finance training for the 
intelligence community  (Note:  Because the KRG's  training 
facilities are located in a relatively more secure environment, we 
strongly urge that USG training initiatives utilize those 
facilities.  Invitations for training should be extended to both KRG 
personnel and officials from other parts of Iraq, in order to help 
reduce the Iraq-wide threat of cash smuggling for terrorist 
financing and money laundering. 
 
BUTENIS