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Stuart Levey
Under Secretary of the Treasury for Terrorism and Financial Intelligence
In office July 21, 2004 – March 2011
President	George W. Bush Barack Obama
Succeeded by	David S. Cohen
United States Secretary of the Treasury Acting
In office January 20, 2009 – January 26, 2009
President	Barack Obama
Preceded by	Henry Paulson
Succeeded by	Timothy Geithner

Stuart A. Levey was the first Under Secretary for Terrorism and Financial Intelligence within the United States Department of the Treasury. He was sworn in on July 21, 2004 as a political appointee of President George W. Bush. President Obama asked Levey to remain in his position and Levey was one of only a small number of Senate-confirmed Bush appointees to be held over. Levey served until March 2011. Levey played a central role in the efforts to combat North Korea's and Iran's allegedly illicit conduct in the international financial system. Prior to his nomination, Levey served as the Principal Associate Deputy Attorney General at the U.S. Department of Justice. He had previously served as an Associate Deputy Attorney General and as the Chief of Staff of the Deputy Attorney General.^[1] He was succeeded by David S. Cohen. In January 2012, Levey joined HSBC as the bank's Chief Legal Officer.^[2]

Education and early career

He grew up in Jewish family^[3] near Akron, Ohio, where his father had practiced dentistry. In 1986 he graduated from Harvard College summa cum laude, and in 1989 he graduated magna cum laude from Harvard Law School.^[1] He clerked for Judge Laurence Silberman on the U.S. Court of Appeals for the D.C. Circuit from 1989 through 1990.^[1]

Prior to joining the Justice Department in 2001, Mr. Levey spent 11 years in private practice at the Washington law firm Miller, Cassidy, Larroca & Lewin LLP (which merged into Baker Botts LLP). He had a litigation practice with a special emphasis on white collar criminal defense.^[1]

Acting Treasury Secretary

On January 15, 2009 President-elect Barack Obama designated Levey to serve as Acting Treasury Secretary until Obama nominee Timothy Geithner was confirmed to the post.^[4] Geithner was confirmed on January 26.^[5]

Under Secretary for Terrorism and Financial Intelligence

As the first Under Secretary of the Treasury for Terrorism and Financial Intelligence, from July 2004, Levey was responsible for creating a new office to lead the Treasury Department's revitalized post-9/11 national security mission. Levey is credited with developing and executing financial strategies to counter threats to U.S. national security and protect the integrity of the international financial system.^[6][7] He has also been recognized for his efforts in leading the U.S. government's efforts to disrupt financial networks supporting terrorist organizations; developing and implementing financial measures against proliferators of weapons of mass destruction; and playing a central role in U.S. strategies to pressure the regimes in North Korea, Iran and elsewhere.^{[8][9][10][11][12]} He is credited, in particular, with designing the financial strategy that resulted in tremendous pressure on Iran's economy and its isolation from the international financial system.^[13]

One of Levey's innovations was harnessing the private sector to enhance the effectiveness of governmental measures. He "led an effort to convince foreign banks to cease conducting business with Iran until that country agreed to comply with international banking standards. By showing companies and banks that doing business in Iran has financial and diplomatic repercussions, he has convinced corporations to cut off business with Iran." ^[14] TFI's efforts received support from both Republicans ^[15] and Democrats ^[14][16] Levey, a Bush appointee, was asked to remain in his position by the Obama Administration.

TFI, through its economic sanctions, put pressure on countries such as North Korea, Iran,^[17][18] and Libya ^[19] TFI was responsible for leading the government's efforts to cut off financing to terrorist organizations such as al Qaeda, Hamas and Hezbollah. In pursuing that effort against al Qaeda, Levey focused attention on wealthy Gulf-based donors, particularly from Saudi Arabia.^[20] He was once quoted as saying,"If I could somehow snap my fingers and cut off the funding from one country, it would be Saudi Arabia." No one identified by the United States and the United Nations as a terror financier has been prosecuted by the Saudis, he elaborated.^[21] He later acknowledged significant improvement in the partnership between the U.S. and Saudi Arabia in targeting al Qaeda financing.^[22]

He has accused Iran of facilitating missile exports to North Korea, saying Bank Sepah has been facilitating business with North Korea's chief ballistic missile-related exporter, KOMID.^[23] When the Department of the Treasury moved to freeze the bank accounts and financial assets of the Higher Institute for Applied Science and Technology, the Electronics Institute and the National Standards and Calibration Laboratory, he stated that Syria is using official government organizations to develop nonconventional weapons and the missiles to deliver them.^[24]

In June 2006, it was revealed that counterterrorism officials had gained access to financial records from a vast international database of banking transactions involving Americans and others in the United States. In response to concerns about privacy issues, Levey said that the program "has provided us with a unique and powerful window into the operations of terrorist networks and is, without doubt, a legal and proper use of our authorities."^[25]

In July 2010, he said that Anwar al-Awlaki "has proven that he is extraordinarily dangerous, committed to carrying out deadly attacks on Americans and others worldwide ... [and] has involved himself in every aspect of the supply chain of terrorism—fundraising for terrorist groups, recruiting and training operatives, and planning and ordering attacks on innocents."^[26]

Prior to serving in the Treasury Department, Levey served in several senior positions at the U.S. Department of Justice, including as Principal Associate Deputy Attorney General for Deputy Attorney General Larry Thompson and Deputy Attorney General James Comey.^[27] In that role, Levey was the Deputy Attorney General's primary advisor for coordinating the Department's varied counterterrorism and national security activities, including investigations, intelligence collection and prosecutions. Prior to serving in that role, Levey was an Associate Deputy Attorney General and Chief of Staff to the Deputy Attorney General.

Chief Legal Officer, HSBC Holdings plc

Since January 2012, Levey has served as the Chief Legal Officer of HSBC Holdings plc, a global bank with 257,000 employees across 67 jurisdictions and $81 billion in operating income in 2014.^[28] He manages a legal department made up of more than 800 lawyers in more than 50 countries. He is also a Group Managing Director of the firm.

Criticism

According to The New York Times, the failure of the United States to carry out sanctions against many Iranian companies and individuals is cited by European diplomats as an example of America failing to do what it has promised. Valerie Lincy of Iran Watch has said, "The United States now lags many other countries in enforcing sanctions that the United Nations has already voted."^[29] The Tehran Times wrote that the U.S. Treasury has increased pressure on foreign banks not to deal with sanctions against Iran, including performing "U-turn transactions," which allow U.S. banks to process payments involving Iran that begin and end with a non-Iranian foreign bank.^[30]

In reply to Lincy's comments, Levey said that the United States has tougher sanctions on Iran than any other country. He said that because their list of organizations and individuals involved in financial crime is accurate, it is America's list that "is by and large used by financial institutions around the world."^[1]

References