And statistics.  Yesterday's numbers showing the skewed priorities of the Treasury Department in throwing more investigative resources at petty violations of the Cuba embargo than uncovering illicit financial channels to Iran and al Qaeda were incomplete.

It turns out that the data, as presented by Ann Louise Bardach in an opinion piece  in Sunday's Washington Post that I cited approvingly, was not quite up to date.
 
Bardach rightly noted a 2007 government study which found that 61 percent of the investigations carried out by the Treasury Department's Office of Foreign Assets Control (OFAC) since 2000 had "been aimed at just one target: Cuba," and that "between 2000 and 2005, OFAC penalties for violations of the Cuban embargo represented more than 70 percent of all the penalties the office imposed."

As Max Baucus, the Montana Democrat who chairs the Senate Finance Committee wondered out loud at a hearing last year,  "Is the office setting its priorities correctly?"

"In 2003, the Committee learned that two employees were assigned to go after Saddam's missing funds. And two employees were assigned to go after Osama Bin Laden's money. But 21 employees were assigned to go after those who violate Cuba sanctions," Baucus noted caustically.

His questions were directed mainly at Stuart A. Levey, Treasury's Undersecretary for Terrorism and Financial Intelligence. 

In written answers to Baucus's queries - which I just discovered yesterday, thanks to Andrew Cochran and Douglas Farah at The Counterterrorism Blog - a more complete picture of Treasury's efforts emerged.

The statistics Levey produced show the department has begun to shift its priorities to where they belong. Partly that's because of  bureaucratic changes at the department, which in 2004 created the Terrorism and Financial Intelligence section.

As Farah informed me, the TFI office brought over the terrorism experts and their cases from the Office of Foreign Assets Control, including the Iran account. Since OFAC only designates terrorist entities and doesn't actually investigate cases anymore, its stats showed skewed and wasted resources spent on Cuba. 

Or, as Levey put it to Baucus:

"OFAC has adopted new strategies with respect to sanctions violations in recent years that have resulted in a significant reduction in Cuba penalty cases. Enforcement resources committed to Cuba are being reduced and enforcement efforts are being targeted in a more effective way by concentrating on those facilitating illegal travel to Cuba."

 The number of OFAC cases against Cuba violations, Levey said, had dropped from a peak of 587 in 2004 to 32 in 2007.

Levey conceded that in 2003, OFAC had 21 fulltime employees administering and implementing cases against violations of the Cuba trade sanctions. Since 2004, though, "most of OFAC's Cuba-related work has been centered in its Licensing Division ... processing applications for travel to Cuba to market and sell agricultural products."

Of the office's 155 fulltime employees, he said, six in Washington and five in Miami "are devoted full-time to the Cuba program."

To me, that's still about 10 too many, 10 financial sleuths who should be working on al Qaeda instead of this relic of the cold war, Cuba.

But the numbers don't lie -- or do they?

"But a 2007 government study found that 61 percent of the office's investigations since 2000 had been aimed at just one target: Cuba," Bardach reports. "Between 2000 and 2005, OFAC penalties for violations of the Cuban embargo represented more than 70 percent of all the penalties the office imposed."

"At the hearing, OFAC acknowledged that it had just four employees searching for the funds of Osama bin Laden and Saddam Hussein, as opposed to more than 20 full-time investigators charged with hunting down suspected violators of the embargo."

"Iranian banks illegally shifted billions of dollars through American financial institutions in recent years, and authorities suspect some of the money may have been used to finance Iran's nuclear and missile programs."

"It 'stripped' information that would have identified the transfers in order to deceive American financial institutions, which are barred from doing business with Iranian banks ..."

"This is the pipeline at its best. One simply has to shift addresses, at least on paper, the companies go again, and the pipeline is unclogged and continues to carry its vital products. The flexibility of the pipeline and its ability to adapt and reroute itself in a very short period of time is one of its greatest strengths."