RSI PROPOSALS: SOUTH ASIA

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

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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

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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

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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

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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

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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

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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