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INFO RUCNCLS/ALL SOUTH AND CENTRAL ASIA COLLECTIVE

UNCLAS SECTION 01 OF 08 NEW DELHI 000356 
 
SENSITIVE 
SIPDIS 
 
S/CT FOR VICTOR NELSON, JANE MOSBACHER, BRYAN KOONTZ 
 
E.O. 12958: N/A 
TAGS: PTER PREL IN PK NP BG CE MV BT
SUBJECT: RSI PROPOSALS: SOUTH ASIA 
 
REF: SECSTATE 124641 
 
¶1. (SBU) The following are 2010 Regional Security Initiative 
(RSI) program proposals for South Asia.  Compiled by the RSI 
Coordinator at Embassy New Delhi, they include proposals 
covering Pakistan, Nepal, Bangladesh, Bhutan, Sri Lanka, the 
Maldives, and India. 
 
¶2. (SBU) Regional Technical Conference(s) 
 
Need for project:  South Asia is one of the most 
terror-afflicted regions in the world, yet regional 
counterterrorism cooperation has lagged, impeded by regional 
political dynamics and long-standing bilateral tensions. 
India, in particular, has been reluctant to engage in 
regional cooperation involving Pakistan, which it has 
regarded as a source of support for terrorism.  The November 
26, 2008 attacks in Mumbai (known as "26/11") underscored 
that government officials in the region are ill equipped to 
deal with an enemy that increasingly has the capacity to 
commit large-scale attacks with minimal effort; governments 
often lag even further on preparedness for emerging threats. 
Recognizing these realities, Indian officials are 
increasingly open to regional cooperation on technical 
issues, as opposed to themes that touch on broader political 
issues.  This technical cooperation is needed both to develop 
the capabilities of governments in the region, as well as to 
engage the regional heavyweight, India, in a regional 
approach to counterterrorism cooperation. 
 
Description of the program proposed:  In an effort to 
increase the capacity of law enforcement and government 
officials throughout South Asia, we propose a one week 
regional conference addressing a range of technical issues, 
including countering terrorist finance and narcotics, 
bioterrorism, and cyber security.  The technical focus of 
these topics will avoid regional sensitivities while engaging 
key government officials with an urgent need to bolster their 
technical skills.  This proposal could be executed through a 
series of smaller conferences, though we are proposing a 
single conference with break-out sessions for each topic to 
economize on conference expenses and to maximize the chances 
that governments will find something to like and agree to 
participate.  We would invite technical specialists from 
Afghanistan, Bangladesh, Pakistan, India, Nepal, Sri Lanka, 
and the Maldives to India to discuss their respective 
approaches to these issues and to raise awareness of these 
threats.  Additionally, we would bring in expert speakers 
from outside the region to highlight global best practices 
and to suggest a program of further trainings and exchanges. 
A successful conference could lead to more detailed follow-on 
conferences on each of the technical issues and the emergence 
of a community of practice among regional technical 
specialists. 
 
Time frame for implementation:  Late 2010/Early 2011 
 
Where implemented:  New Delhi, India 
 
Implementing body:  U.S. Department of State, with expertise 
drawn from other agencies. 
 
Audience of program:  Approximately 42 regional participants 
representing law enforcement, financial intelligence units, 
drug interdiction agencies, first responders, and security 
agencies involved in bioterrorism prevention and disaster 
management. 
 
Funding breakdown: (Note:  costs would increase somewhat if 
separate conferences are held.) 
Estimated Cost:  $108,916 
Facilitator's travel/per diem/lodging:  $60,000 ($3,000 per 
person x 20pp) 
Flights for regional participants:  $31,500 ($750 per person 
x 42pp) 
New Delhi per diem:  $2,916 ($486/day per person for 6 days) 
Facility rental costs:  $4,500 
In-country costs (vehicle rental, etc):  $10,000 
 
Tie to law enforcement:  This conference is an effort to 
increase the technical abilities of law enforcement and 
government officials who require specialized technical skills 
to address and respond to bio terrorism, cyber terrorism, and 
terrorist finance, and narcotics. 
 
Relation to RSI:  By limiting the content to technical 
issues, this conference has the potential to engage all the 
countries in the region. 
 
What have the S/CT sponsor so the program done to coordinate 
 
NEW DELHI 00000356  002 OF 008 
 
 
this program with this interagency? (What offices/agencies 
have been consulted? How did you ensure this is not 
duplicative?):  The South Asia RSI Coordinator cleared this 
proposal with the other U.S. agencies present at Embassy New 
Delhi, as well as the other Embassies in the region. 
 
¶3. (SBU) Regional Counterterrorism Training Center 
 
Need for project:  Unlike most other regions, South Asia 
lacks a consolidated regional training center in which law 
enforcement agencies can receive concurrent counterterrorism 
training to address common regional threats.  A regional 
center in Bangladesh would provide a central training 
facility for law enforcement agencies from across South Asia. 
 It would also encourage cooperation and communication among 
the various law enforcement agencies in South Asia and, over 
time, improve levels of trust and facilitate coordination. 
Australian CT coordinator Ambassador Bill Paterson briefed 
the UN Counterterrorism Action Group (CTAG) in Dhaka last 
November on a proposal to establish a regional law 
enforcement training center similar to the center in Jakarta. 
 In an effort to move this project forward, the European 
Union is sending a scoping team to Dhaka in February 2010 to 
assess the environment and sustainability of this type of 
training center.  This type of regional CT training center is 
a large undertaking and, although the E.U. is taking the 
lead, they will look to donor countries to provide assistance 
to ensure the success of the facility.  Due to the scope of 
this project, implementation will be phased, thereby 
providing an opportunity for funding to be approved in 
several tranches. 
 
Description of program proposed:  The program is a joint 
effort between the United States, European Union, Australia, 
the United Kingdom, and other potential donors.  Bangladesh 
would provide land and facilities.  The proposed program 
would provide funds to conduct a feasibility study; engage 
subject matter experts to advise the host government on the 
center's organization, personnel and logistic requirements; 
develop the initial curriculum; fund instructors; and support 
other start-up costs for the center. 
 
Time frame for implementation:  The target date for 
conducting the feasibility study is mid-year 2010, with a 
goal of conducting the first training programs in the 
following 12-18 months, depending on the identification of 
the center's location and pre-existing infrastructure. 
 
Where implemented:  Bangladesh hosts the Bangladesh Institute 
of Peace Support Operation Training (BIPSOT), which provides 
United Nation Peacekeeping Operation training to contributing 
nations in the region, including Nepal, Maldives, China, 
Cambodia, Malaysia, Indonesia, and the Philippines.  The 
United States enjoys good relations with Bangladesh and there 
is growing international support for locating the training 
center in Bangladesh, which would be accessible to and 
noncontroversial for countries across the region. 
 
Implementing body:  ICITAP would provide the subject matter 
experts to advise the Bangladesh government in the 
establishment of the center.  Once operational, donor 
countries would finance training and provide instructors. 
Bangladesh's law enforcement agencies would have 
responsibility for operating the center.  A governing board, 
if modeled on the Jakarta Center, would include seats for the 
primary donor countries, most likely the United States and 
European Union.  A seat for a SAARC representative could help 
encourage regional participation. 
 
Audience of program:  The program would appeal to the various 
law enforcement agencies in South Asia.  As the center 
matures, additional countries could be included in its 
training programs. 
 
Funding breakdown:  We request $2 million, using ATA and CTE 
funds, to cover the feasibility study and provide an ICITAP 
subject-matter expert to assist establishing the training 
center.  This can be broken into tranches based on how soon 
the funds would be needed: (i) funding for feasibility study 
(now until mid-2010), (ii) funding for subject matters 
experts to assess and advise on course content (mid to late 
2010)), (iii) funding for training and classes (early to mid 
2011). 
 
Tie to law enforcement:  Regional law enforcement is the 
program's primary focus. 
 
Relation to RSI:  The proposed center supports RSI objectives 
to increase regional law enforcement and counterterrorism 
capabilities and cooperation.  The program would also build 
 
NEW DELHI 00000356  003 OF 008 
 
 
political will among participating nations to combat 
international terrorism and enhance trust and cooperation 
between law enforcement agencies in the region. 
 
What have the S/CT sponsors of the project done to coordinate 
this program with this interagency?:  Mission Dhaka's 
interagency counterterrorism working group discussed the 
proposal for the training center and consulted with UNCTED, 
UNDP, and the diplomatic missions of the EU, UK, Australia, 
Spain, Japan, Denmark, and other potential donors.  A donors 
joint working group will coordinate efforts to avoid 
duplication.  The RSI Coordinator in New Delhi cleared the 
proposal with other countries in the region. 
 
¶4. (SBU) Regional Cyber Security Training 
 
Need for project:  South Asia is one of the most 
terror-afflicted regions in the world and also a global hub 
for information technology and services.  The confluence of 
these realities, together with broader Asian power dynamics, 
makes the region particularly vulnerable to cyber terrorism, 
an increasingly serious threat to global security.  Cyber 
attacks are not only disruptive and costly, but can also 
imperil critical infrastructure.  Developing a robust cyber 
security cadre to thwart and respond to these attacks will 
bolster the safety and security of national infrastructure 
and other interests.  India, in particular, has identified 
cyber security as a priority in the Counterterrorism 
Cooperation Initiative (CCI) concluded during Prime Minister 
Singh's state visit in November.  Senior Indian officials 
have also stressed that cyber security is the kind of 
technical issue they would welcome addressing through a 
regional approach, something they have shied away from in the 
past. 
 
Description of the program proposed:  We propose sending a 
mixed group of officials from South Asian countries to attend 
cyber security training at United States Telecommunications 
Training Institute (USTTI) and to meet U.S. law enforcement 
and government officials tasked with securing the United 
States against cyber attacks.  In an earlier proposal, five 
Indian officials were authorized to attend USTTI training. 
This program would expand to include officials from other 
countries in the region (with the exception of Pakistan), as 
well as consultations with U.S. officials.  The attendees 
would participate in the Cyber Security Awareness Raising and 
Capacity Building course for one week, and spend a second 
week meeting U.S. officials at the Department of Defense, 
Federal Communications Commission, Department of State, and 
other agencies.  (Note:  Embassy Islamabad is already 
conducting cyber security training through DS/ATA and 
expressed skepticism that Pakistan and India would cooperate 
on this issue.) 
 
Time frame for implementation:  October/November 2010, TBD. 
Specific dates would be based on the dates the course is 
offered. 
 
Where implemented:  The training would take place in the 
Washington, D.C.  The RSI Coordinator at U.S. Embassy New 
Delhi would be the logistical point of contact for the event. 
 
Implementing body:  U.S. Department of State, in coordination 
with the United States Telecommunications Training Institute 
(USTTI), and other agencies. 
 
Audience of program:  Government officials from the regional 
countries (except Pakistan) with technical and law 
enforcement functions. 
 
Funding breakdown: (Note:  Based on six participant per 
country, except Pakistan.  Numbers of participants could be 
scaled back to reduce costs.) 
Total Cost:  $108,000 
Roundtrip flights for 30:  $60,000 ($2,000 per person) 
Washington, D.C. per diem:  $96,180 ($229/day per person for 
14 days) 
USTTI administrative cost:  $4,500 ($150 per person) 
Incidentals:  $1,320 
 
Tie to law enforcement:  Law enforcement officials from the 
host governments with cyber security functions will be 
invited to attend. 
 
Relation to RSI:  This is a regional program to enhance the 
ability of government and law enforcement officials to 
counter cyber terror attacks. 
 
What have the S/CT sponsor so the program done to coordinate 
this program with this interagency? (What offices/agencies 
 
NEW DELHI 00000356  004 OF 008 
 
 
have been consulted? How did you ensure this is not 
duplicative?):  The South Asia RSI Coordinator cleared this 
proposal with the other U.S. agencies present at Embassy New 
Delhi, as well as the other Embassies in the South Asia 
region.  This is an extension of a previously funded program. 
 
¶5. (SBU) India-Pakistan Security Dialogue 
 
Need for project:  South Asia remains one of the most 
terror-afflicted regions of the world, but regional 
approaches to counterterrorism have been inhibited by 
political dynamics and long-standing bilateral tensions. 
Official relations between India and Pakistan have been 
frozen since the November 2008 Mumbai attacks, though 
unofficial contacts between think tanks and others have 
continued.  As a matter of long-standing U.S. policy, the 
United States plays no official role in this dispute, which 
it regards as a bilateral issue between India and Pakistan to 
be worked out by the parties themselves; however, we continue 
to encourage them to do so through peaceful dialogue. 
Between official dialogue and public awareness efforts (like 
the recent 'Aman Ki Asha' campaign), there is considerable 
scope for unofficial, Track II engagement between think tanks 
and retired officials who retain considerable influence in 
official circles in each country.  Adapting the successful 
model of the India-Bangladesh Strategic Dialogue, which 
contributed to an about-face in relations between India and 
its neighbor to the East, we propose supporting a Track II 
dialogue between think tanks in India and Pakistan to build 
trust and examine areas for potential cooperation. 
 
Description of the program proposed:  We propose funding two 
rounds of an India-Pakistan Track II dialogue to assess areas 
for possible engagement aimed at restarting official dialogue 
between the governments.  The dialogue would be modeled after 
the successful India-Bangladesh Security Dialogue.  Working 
through India's Observer Research Foundation (ORF) and a 
similar think tank in Pakistan we would bring together 
regional civil society leaders for meetings in New Delhi and 
Islamabad, or possibly a third country.  Both organizations 
will be encouraged to share the conference recommendations 
with decision-makers in their respective countries. 
 
Time frame for implementation:  September 2010 * January 
2011 
 
Where implemented:  One round each in New Delhi and 
Islamabad, or possibly in a third country. 
 
Implementing body:  Observer Research Foundation (India) and 
a Pakistan based think tank (TBD). 
 
Audience of program:  Indian and Pakistani think tanks and 
opinion leaders, and indirectly government officials. 
 
Funding breakdown: 
Total:  $100,000; each round would cost an estimated $50,000. 
Lodging:  $11,700 (3 days x 13 x US$ 300) 
Airfare:  $4,600 ($460 x 10pp) 
Direct Conference Costs:  $26,500 
Conference Secretariat Costs:  $7,200 
 
Tie to law enforcement:  The dialogue addresses the capacity 
of the governments to prevent terrorism in South Asia, 
including law enforcement cooperation and capacity building. 
 
Relation to RSI:  This kind of focused bilateral dialogue is 
an important first step in developing regional approaches to 
counterterrorism cooperation, and no relationship in the 
region is more important when it comes to counterterrorism 
than this one. 
 
What have the S/CT sponsor so the program done to coordinate 
this program with this interagency? (What offices/agencies 
have been consulted? How did you ensure this is not 
duplicative?)  The South Asia RSI Coordinator cleared this 
proposal with the other U.S. agencies present at Embassy New 
Delhi, as well as the other Embassies in the South Asian 
region, including Embassy Islamabad. 
 
¶6. (SBU) India-Bangladesh Security Dialogue (Rounds 3 & 4) 
 
Need for project:  South Asia remains one of the most 
terror-afflicted regions of the world, but regional 
approaches to counterterrorism have been inhibited by 
regional political dynamics and long-standing bilateral 
tensions.  Improving bilateral relationships is an important 
first step toward developing a broader regional approach to 
counterterrorism, as well as addressing localized terrorist 
threats.  In this regard, the first round of the S/CT-funded 
 
NEW DELHI 00000356  005 OF 008 
 
 
India-Bangladesh Track II dialogue can be counted a 
tremendous success.  This dialogue did much of the work 
behind the scenes to prepare for the breakthrough January 
2010 visit of Bangladeshi Prime Minister Sheik Hasina to 
India, which resulted in five MoUs, three of them on 
counterterrorism cooperation.  Bangladesh and India have 
resolved to work together to stem the movement of terrorists 
across their borders and to broadening their relationship. 
S/CT should continue its support for this unprecedented 
counterterrorism cooperation in a difficult region with two 
more rounds of Track II dialogue. 
 
Description of the program proposed:  We propose extending 
the successful India-Bangladesh South Asia Security Dialogue 
for two more rounds.  Working through India's Observer 
Research Foundation (ORF) and the Bangladesh Enterprise 
Institute, the first rounds of the dialogue brought together 
regional civil society leaders, government officials and law 
enforcement agency representatives for dialogues in Dhaka.  A 
second round is scheduled to take place in New Delhi in March 
2010 with some government participation, making it more of a 
track one-and-a-half rather than just track two.  To further 
develop this successful initiative, we propose funding a 
third and a fourth round of dialogue, in part to focus 
further attention on counterterrorism cooperation, to 
encourage more direct involvement from government officials, 
and to solidify this fruitful bilateral cooperation as a 
foundation for further regional cooperation. 
 
Time frame for implementation:  September 2010 * January 
2011 
 
Where implemented:  One additional round each between New 
Delhi, India and Dhaka, Bangladesh. 
 
Implementing body:  Observer Research Foundation (India) and 
Bangladesh Enterprise Institute (Bangladesh). 
 
Audience of program:  Indian and Bangladeshi think tanks, 
security agencies, police officers and governmental officials 
with equities in law enforcement and security. 
 
Funding breakdown: 
Total:  $100,000; each round would cost an estimated $50,000. 
Lodging:  $11,700 (3 days x 13 x US$ 300) 
Airfare:  $4,600 ($460 x l0pp) 
Direct Conference Costs:  $26,500 
Conference Secretariat Costs:  $7,200 
 
Tie to law enforcement:  Members of the Security Council and 
law enforcement agencies from each country attended the first 
dialogue and are invited to the second round.  The dialogue 
addresses the capacity of the governments to prevent 
terrorism in South Asia, including law enforcement 
cooperation and capacity building.  The first round 
contributed to the conclusion of three counterterrorism and 
law enforcement-related MoUs during the visit of Bangladeshi 
Prime Minister Sheik Hasina to India, and there is scope for 
further progress. 
 
Relation to RSI:  This kind of focused bilateral dialogue is 
an important first step in developing regional approaches to 
counterterrorism cooperation. 
 
What have the S/CT sponsor so the program done to coordinate 
this program with this interagency? (What offices/agencies 
have been consulted? How did you ensure this is not 
duplicative?)  The South Asia RSI Coordinator cleared this 
proposal with the other U.S. agencies present at Embassy New 
Delhi, as well as the other Embassies in the South Asian 
region, including Embassy Dhaka.  It is an extension of a 
previously funded program. 
 
¶7. (SBU) Training for South Asian Governments in Countering 
Bulk Cash Smuggling 
 
Need for project:  Cutting off the financing of terrorist 
groups is a key component of our national strategy to combat 
terrorism.  A large number of terrorist organizations operate 
in South Asia including, but not limited to, al-Qa'ida, 
Lashkar e-Tayyiba, Tehrik*i-Taliban), Harakat 
ul-Jihad-i-islami/Bangladesh, Harakat ul-Jihad-Islami, 
Harakat ul-Mujahedin, Jaish-e-Mohammed, and Lashkar I 
Jhangvi.  In order to operate and grow, these groups depend 
on and receive funding from outside sources including wealthy 
donors and grass root organizations in Pakistan, Saudi 
Arabia, UAE and other Gulf and Islamic states.  Much of this 
funding is smuggled across regional borders. In order to 
detect and stop the flow of cash and other illicit items 
across the borders, the USG needs to assist South Asian 
 
NEW DELHI 00000356  006 OF 008 
 
 
governments in building their border enforcement capacity. 
The creation of robust border enforcement regimes in South 
Asia is important to reaching our counterterrorism goals of 
denying funding to terrorist networks. 
 
Description of the program proposed:  The USG will seek to 
build financial investigative capacity, strengthen border 
control and increase regional cooperation by training key 
government agencies from Afghanistan, Pakistan, UAE, 
Bangladesh, India, and Nepal.  This will be a two-year, 
two-phase project that will be provided to customs and border 
control agencies to strengthen their capacity to investigate 
and interdict bulk cash smugglers and bulk cash couriers at 
all ports of entry including land crossings, ports and 
airports.  The first phase of the project will include a 
regional Bulk Cash Smuggling (BCS) course and a Regional 
Operational Cash Courier course. The Department of Homeland 
Security (DHS) will provide these courses, which are designed 
to build capacity to target, detect, interdict and 
investigate cash couriers.  The second phase of the program 
will be a "Train the Trainer" course to establish advanced 
training divisions and experts within host countries to train 
personnel on the detection, interdiction and investigation of 
illicit cash couriers and BCS. 
 
Time frame for implementation:  2010-2011. 
 
Where implemented:  United Arab Emirates. 
 
Implementing body:  Department of Homeland Security/ICE and 
CBP. 
 
Audience of program:  Customs, border protection, federal 
investigative agencies, Financial Intelligence Units, Air and 
Port Authority Police/Border Guards from Pakistan, 
Afghanistan, UAE, Bangladesh, India, and Nepal 
 
Funding breakdown: 
Total:  $250,000 
FY 10 - Basic and Advanced BCS courses: $150,000 
FY 11- Train the Trainer Course: $100,000 
 
Tie to law enforcement:  The program will strengthen the 
capacities of law enforcement agencies to stop illicit 
financing of terrorist groups. 
 
¶8. (SBU) Training for South Asia Financial Intelligence Units 
 
Need for project:  Cutting off the financing of terrorist 
groups is a key component of our national strategy to combat 
terrorism.  A large number of terrorist organizations operate 
in South Asia including, but not limited to al-Qa'ida (AQ), 
Lashkar e-Tayyiba (LT), Tehrik*i-Taliban (TTP), Harakat 
ul-Jihad-i-Islami/Bangladesh (HUJI-B), Harakat 
ul-Jihad-Islami (HUJI), Harakat ul-Mujahedin (HUM), 
Jaish-e-Mohammed (JEM), and Lashkar I Jhangvi (LJ).  In order 
to operate and grow, these groups depend on and receive 
funding from outside sources including wealthy donors and 
grass root organizations in Pakistan, Saudi Arabia, United 
Arab Emirates (UAE) and other Gulf and Islamic states. 
Building the capacity of governments in South Asian countries 
to stem the flow of funds to terrorist groups is essential to 
disrupting their activities.  The creation of robust 
financial investigative capabilities in South Asia is 
critical to reaching our counterterrorism goals. 
 
Description of the program proposed:  In an effort to build 
financial investigative capacity and increase CT cooperation 
in South Asia, we propose regional training through 
conferences/seminars and exchange programs for Financial 
Intelligence Units (FIU) from Pakistan, Bangladesh, India, 
Sri Lanka, Maldives and Nepal.  We propose building the 
capacities of the FIUs through 1) regional 
conferences/seminars and 2) training and exchange programs. 
Bangladesh, Maldives, and Sri Lanka have the most advanced 
financial investigate capacities in the region and therefore 
should host the conferences/seminars.  However, none of the 
South Asian countries have met all the standards and 
requirements necessary for admission to the Egmont Group. 
Therefore, representatives from other countries that have met 
Egmont Group requirements and are internationally recognized 
as having robust Counter 
Terrorist Finance (CTF) regimes such as Australia, Singapore, 
Thailand and Malaysia would be invited to participate in the 
training. Other presenters at the conference/seminar could 
include multilateral organizations such as the Financial 
Action Task Force's (FATF) regional body, the Asia Pacific 
Group and the Egmont Group.  The seminars/conference would 
provide training in financial investigation techniques.  The 
second phase of this project would include an exchange 
 
NEW DELHI 00000356  007 OF 008 
 
 
program between FIU officials from Pakistan, Bangladesh, 
India, Sri Lanka and Nepal with FIUs in Australia, Singapore, 
Thailand and Malaysia.  This would include hands-on practical 
training in financial investigations. 
 
Time frame for implementation:  2010-2011.  The first year 
would be a conference or series of seminars and second year 
would be the exchange program. 
 
Where implemented:  Bangladesh, Sri Lanka, Maldives, 
Australia, Singapore, Thailand or Malaysia. 
 
Implementing body:  Department of Treasury. 
 
Audience of program:  Officials from FIUs from Pakistan, 
Bangladesh, India, Sri Lanka, Maldives, Nepal, Australia, 
Singapore, Thailand and Malaysia. 
 
Funding breakdown: 
Total:  $300,000 
Conference/Seminars:  $150,000 
Exchange Program:  $150,000 
 
Tie to law enforcement:  Building the capacities of financial 
investigations is necessary in order law enforcement agencies 
to stop illicit financing of terrorist groups and to try 
terror financing and money laundering cases in their judicial 
systems. 
 
¶9. (SBU) Support for Enactment by Pakistan of AML/CTF 
Legislation, in compliance with Asia pacific Group 2009 
Mutual Evaluation Recommendations. 
 
Need for project:  Pakistan's legislature is coming close to 
finally enacting a long-awaited anti-money laundering law. On 
January 27, the National Assembly adopted the Anti-Money 
Laundering Bill 2009.  The progress was, in large part, a 
response to international pressures, including the detailed 
criticism by the regional FATF body, the Asia Pacific Group 
on Money Laundering (APG), in its 2009 Mutual Evaluation 
Report (MER).  While the new legislation is an important 
step, it falls short of providing for a comprehensive 
Anti-Money Laundering/Counter Terrorist Financing (AML/CTF) 
legal regime in full compliance with international standards. 
Pakistan seeks admission to the Egmont Group, and eligibility 
will depend on enactment of further amendments and revisions 
to the new AML legislation.  These efforts must be completed 
in advance of May 2011, the next opportunity for Egmont 
review. 
 
Description of the program proposed:  Background: Pakistan's 
on-again/off-again efforts at enacting and implementing an 
AML/CTF regime have been half-hearted at best.  After years 
of delay, the government finally issued, by executive order, 
an AML Ordinance in 2007.  The Ordinance was reissued, with 
some additional amendments, in November 2009 -- constituting 
the version now enacted by Parliament.  Some additional AML 
provisions have also been included in the country's 
anti-narcotics and anti-terrorism legislation.  The 
legislation as passed, however, falls short of international 
standards and requirements necessary for admission to the 
Egmont Group.  For example, the law still requires that a 
bilateral mutual legal assistance agreement (MLAA) be in 
place before Pakistan can engage in international cooperation 
or share evidence concerning money laundering investigations 
or prosecutions. 
 
Accordingly, further "tweaking" of the new AML legislation 
will be required. Pakistan's legislature, however, remains a 
largely dysfunctional institution, capricious in its 
attention, and ineffectual in pursuing its agendas.  The 
challenge will be to keep key government officials and 
ministries focused on the need for refinement of the new AML 
legislation, so that they, in turn, can continue to exert 
pressure on the legislature.  (Programming Note: Direct 
participation in the legislative drafting process in Pakistan 
has not proved to be generally feasible for USG or Embassy 
personnel--or for other international institutions or 
partners--regardless of subject matter area. Accordingly 
programs aimed at influencing the legislative process will 
need to work through a combination of "sideways" efforts 
including development of personal relationships, provisions 
of technical expertise, and engagement of third country 
partners to provide comparative models.) 
 
Post proposes funding efforts designed to promote and 
encourage amendments to the new legislation to bring it into 
full compliance with FATF requirements, consistent with the 
clear recommendations of the APG MER and necessary as a 
precursor to Egmont review in 2011.  The Program would use 
 
NEW DELHI 00000356  008 OF 008 
 
 
periodic U.S. Department of Justice Intermittent Legal 
Advisors (ILAs), with substantive background in AML/CTF 
legislation, assigned to post on a TDY-basis, working with 
Post's Resident Legal Advisor (DOJ), Treasury Attach and 
with the NAS, POL and ECON Sections.  The ILAs would be 
tasked with implementing the following efforts designed to 
maintain momentum and pressure for enactment of AML/CTF laws 
through: 
 
-- Mobilization of regional resources and models from across 
the APG, to promote compliance with APG MER recommendation 
and to emphasize reforms still necessary to satisfy Egmont 
review.  While South Asia as a region has noticeably lagged 
in the area of AML/CTF enforcement, many Southeast Asian 
nations, notably Thailand, Singapore and Malaysia, have been 
regional leaders in these efforts.  The ILAs would facilitate 
engagement of Pakistani officials and parliamentarians with 
regional counterparts, through regional events and programs, 
and through the organization of study visits by Pakistani 
officials, including parliamentarians, to Egmont member 
countries with successful AML/CTF legislative regimes. 
 
--Continued direct efforts by ILAs at "lobbying" of relevant 
Pakistani officials, across the Pakistani interagency and in 
Parliament, on the need for further revision of the AML law, 
through one-on-one meetings, provision of relevant reference 
and resource materials, and clarification and reinforcement 
of APG's MER recommendations. Many Parliamentarians, for 
example, are poorly schooled in issues relating to AML/CTF, 
but are not always an easy group to corral into a large 
conference setting; the ILAs would use direct meetings or 
small group sessions to break down current apathy and 
resistance to further consideration and enactment of the 
AML/CTF amendments. 
 
--Facilitate participation of US and international AML 
experts in programs in Pakistan designed to promote further 
modification of the new AML/CTF regime, including both small, 
focused workshops and larger conferences. As has been the 
case in other settings, DOJ ILAs would enlist direct 
involvement of DOJ's Asset Forfeiture and Money Laundering 
Section (AFMLS) -- the lead office in the USG for AML 
legislative policy coordination.  ILAs would also work with 
appropriate embassy officials to coordinate efforts with 
other international donors working in the AML/CTF area, 
including Asian Development Bank and UNODC. 
 
Time frame for implementation:  2010-2011 
 
Where implemented:  Islamabad, with regional visits/programs 
to appropriate counterpart countries and venues in South and 
Southeast Asia. 
 
Implementing body:  At Post Islamabad: DOJ Resident Legal 
Advisor and NAS Section. Supported by DOJ Office of Overseas 
Prosecutorial Development, Assistance and Training (OPDAT), 
Washington, DC. 
 
Audience of program:  Pakistani Parliamentarians, legislative 
staff, and relevant officials from Ministries of Law and 
Justice, Interior and Finance. 
 
Funding breakdown: 
Total:  $600,000 for eighteen months 
Intermittent Legal Advisors (2-3 month TDY):  $300,000 
In country (Pakistan) workshops/conferences (including travel 
costs for experts):  $150,000 
Regional conferences/study tours:  $150,000 
 
Tie to law enforcement:  Sound and comprehensive AML/CTF 
legislation is the building block on which all law 
enforcement efforts are based.  At present, Pakistani lacks 
such a fully adequate legal framework.  The lack of effective 
laws is reflected in the weak record of Pakistani law 
enforcement in pursuing such cases.  Legal reform is a 
critical component of larger efforts to promote more 
aggressive AML/CTF enforcement efforts in Pakistan.  Such 
reform is also a precursor for Egmont membership -- which, in 
turn, is a vehicle for greater international cooperation in 
building AML/CTF cases. 
ROEMER