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 Statement by Adam J. Szubin, Nominee for Under Secretary for Terrorism and Financial Crimes, Before the Senate Committee on Banking, Housing, And Urban Affairs


WASHINGTON - Chairman Shelby, Ranking Member Brown, and distinguished Members of the Committee:  It is an honor to be appearing before this Committee today.

With your permission, I would like to introduce the members of my family who are in attendance:  My wonderful wife Miriam, my beloved sons, Nathan, Micah, and Josiah, my mother Laurie Szubin, and my father-in-law Steve Weiner.  I want to thank my wife Miriam in particular for her unwavering support—whatever I have accomplished has been made possible by her.  Finally, I want to recognize my family members who weren’t able to be here today but who are watching from a distance, including my father, Zvi Szubin, my Grandma Malkie, my sister Lisa and her family, my mother-in-law Roz Heifetz, and the rest of my loved ones.  My family has provided me with endless love and strength.

Mr. Chairman, Ranking Member Brown, and esteemed members of this Committee, I am honored to have been nominated to serve as Under Secretary of the Treasury for Terrorism and Financial Crimes.  I want to thank the President for the confidence he has placed in me, and Secretary Lew, for his recommendation and strong support.  

I do not take this opportunity for granted.  Indeed, I don’t take for granted the fact that I have been allowed to serve my government at all for the last sixteen years.  My father was not born here; he was born in Poland in 1933.  His parents fled the Nazis at the outbreak of World War II.  They were captured by the Soviet army and exiled to Siberia, where they lived out the war years.  Siberia was a place of great hardship, but it turned out that their capture and exile had saved their lives; nearly all of my father’s aunts, uncles, and cousins were wiped out by the Nazis.  There are today few remnants of a family that should have numbered in the thousands.  

My parents raised us to be conscious of the existence of real evil in the world, evil not as an abstract concept, but as an all too real threat that they had seen in their lifetimes: regimes—leaders and willing followers—who pursued murder and even genocide, in the Holocaust and, sadly, in other places in the decades that followed.  But we were not raised in an environment of fear or anger or mourning.  To​ the contrary, we were raised to savor life, to seek out joy, and to be aware of and grateful for the many gifts that we enjoyed.  High among those gifts was the ability to grow up in America—the goldene medina to which my father had come.  He has never stopped marveling at this country—at our brilliant Constitution and legal system, our openness to new immigrants, our work ethic, and our enduring hopefulness that we can improve the world and leave it a little better for our children.  For all of these I was taught to be grateful.

So, while it is perhaps not a surprise that I sought out a career in government service, I have been regularly amazed that this country has allowed the child of an immigrant to take on positions of trust and to participate in shaping our national security policies.  This truly is a country like no other.

I appreciate how significant the responsibilities of this office are.  Eleven years ago, I followed Stuart Levey from the Justice Department when he was named the first Under Secretary for the newly created Office of Terrorism and Financial Intelligence, or TFI.  I have served in TFI ever since, as the director of its sanctions office, the Office of Foreign Assets Control, or OFAC, for nine years, and, most recently, as the Acting Under Secretary for the last six months, overseeing the more than 700 exceptional individuals who make TFI what it is.  

Our office was created to bring together, under one roof, an array of capabilities—intelligence, regulation, enforcement, and policy—to confront our adversaries on the financial battlefield.  The twin missions of TFI are to harness financial intelligence and exercise authorities to advance national security and foreign policy objectives, and to secure our financial system against abuse by criminals and other illicit actors.  It is an easy mission to describe but a challenging one to execute, as I have seen firsthand.  Nonetheless, this office has accomplished amazing things in its short history.

When I started at TFI, a decade ago, the conventional wisdom in schools of international affairs and in foreign ministries was that sanctions did not—and could not—work; that the targets of sanctions would always find ways to circumvent them, money being like water that would always flow downhill.  Thanks to the remarkable and dedicated women and men in TFI and across our government, I don’t hear these arguments as much anymore.  People have seen that smart, creative, and persistent financial efforts, when backed by the superb support of the U.S. Intelligence Community, can strangle illicit organizations, shake regimes, and change their behavior.    

Our efforts to track and disrupt the money flows to terrorist groups have been a key plank in our broader strategy against murderous groups such as al Qaida, ISIL, Hizballah, and Hamas.  We continue to have much critical work ahead of us, but every bank account frozen, every charitable front exposed, every procurement company neutralized, and every fundraiser designated or deterred, strikes a blow against these groups.  And, across the Middle East and Asia, we have worked with governments to help them strengthen their counter terrorism laws and empower themselves to identify and act against illicit money flows.  

Indeed, we have raised standards and increased transparency in the global financial system across the board.  The world’s financial system is—in every arena and every continent—more transparent and more resilient than it was fifteen years ago.  

In the field of human rights, we have used sanctions to combat abuses, facilitating positive changes in places such as Burma—though much remains to be done.

In the arena of narcotics trafficking and money laundering, we dealt once-powerful cartels such as the Cali cartel and the Sinaloa cartel major setbacks due to our concerted and patient efforts to expose their financial holding companies and money launderers—hitting them in their point of greatest vulnerability—their wallets.

We have used sanctions to combat North Korea’s attempts to access and abuse the world’s financial system, closing out front companies and banks that were willing to launder the regime's money for a cut.  In perhaps the most famous example, FinCEN’s action against Banco Delta Asia in Macau severed North Korea's primary channel for moving and collecting illicit revenues and showed that one well-aimed blow can have the impact of years of broad restrictions.  

When we saw Russia violate Ukraine’s territorial sovereignty, we worked with our allies in Europe to devise a creative and powerful set of sanctions that not only went after the key cronies and business interests around President Putin, but also cut some of Russia’s largest banks and energy companies off from the things they need most—western technology and western financing.  

Finally, under Stuart Levey’s and then David Cohen’s leadership, TFI devised and executed a strategy to dramatically intensify the pressure against the government of Iran and its malign policies, its nuclear program chief among them.  Through a steady campaign to expose Iran's deceptive activities in the financial arena, we cut Iran’s banks off from the world’s financial centers, and badly wounded its trade and financial strength.  In 2010, Congress, with this Committee at the center, then dramatically advanced the effort, passing bipartisan measures that brought Iran’s crude oil sales down by 60 percent, escrowed Iran’s foreign reserves in banks around the world, and ensured that Iran’s leaders knew that it would not recover economically until it clearly and verifiably closed off all of its pathways to a nuclear weapon.  These efforts led to the election of President Rouhani and culminated in the diplomatic process that produced the Joint Comprehensive Plan of Action.  The women and men of TFI worked incredibly hard over the past decade to impose and enforce these measures, and to combat every effort to circumvent them.  And, even as we prepare to suspend our secondary nuclear sanctions if Iran fulfills its commitments under the deal, we are simultaneously intensifying a battery of sanctions that will not change under the terms of that deal.  These include sanctions against Iranian human rights abusers as well as our powerful campaign against the Iran Revolutionary Guard Corps and the Quds Force, as well as Hizballah and other Iranian partners and proxies in Syria, Iraq, Yemen, Gaza, and beyond.  And we will be doing so in active cooperation with our partners in Europe, the Gulf, and Israel.

So I have seen first-hand the power of American economic statecraft in advancing our national interests.  And, over the past 11 years, TFI has been continually improving—honing our intelligence focus and developing more innovative, tailored measures to combat and restrain our adversaries.  In this time, I have also gained an appreciation for the importance of exercising our authorities judiciously, in order to preserve the strength of our instruments and financial system well into the future.  But I am also aware that we cannot rest.  I sit in a SCIF every morning to read the latest intelligence, and the threats we face are serious, deadly, and adaptive.  We need to be vigilant, smart, and aggressive.    

Mr. Chairman, I am extremely proud to have been part of TFI from the start, for over a decade, under four Treasury secretaries.  As the international landscape evolves, I am confident that the organization will remain at the forefront of our government’s efforts to protect our national security.  Our work has benefited greatly from strong bipartisan support in the House and Senate, and from the Members and staff of this Committee in particular.  If confirmed, I intend to preserve and build upon the close relationship between TFI and this Committee to take on the pressing challenges ahead.

Thank you again for your time and consideration.  I will be glad to answer any questions you may have.

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