June 30, 2026

Rethinking Treasury's Terrorism and Financial Intelligence Office

By: Alex Zerden

This article was originally published in Lawfare.

More than 21 years have passed since Congress created the Treasury Department’s Office of Terrorism and Financial Intelligence (TFI). In that time, TFI has pioneered the targeted use of financial sanctions, financial intelligence information, financial regulation, and international standard setting to support U.S. foreign policy and national security objectives “while also protecting the integrity of the U.S. and global financial systems.” Financial sanctions in particular have become a “tool of first resort,” as noted by the Treasury Department’s 2021 Sanctions Review and other analyses.

The United States does not need a new department. It needs its existing economic statecraft apparatus to work—better resourced, better organized, and better calibrated to a threat environment that has moved well beyond the post-9/11 world that shaped TFI’s original design.

However, as put bluntly by former Treasury Department Deputy Secretary Justin Muzinich, TFI “is not a team built to analyze the complex economic and financial links that would be implicated in a great-power clash.” TFI’s analytical demands have expanded well beyond its 9/11-era design. Over the past 20 years, sanctions programs have grown more than 1,000 percent; anti-money laundering/countering the financing of terrorism (AML/CFT) policy has shifted toward risk-based frameworks that presuppose quantitative evidence that TFI has no permanent capacity to produce; and when high-stakes operational decisions have required serious macroeconomic analysis—the 2022 Russia oil price cap being the clearest example—that work has fallen to other Treasury offices whose mandates do not include national security.

Read the full article in Lawfare.

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