BSST 370: Terrorist Financing and Counterterror Financing

Course Time: Summer Semester 2017 (May 30 – July 9)

Classroom Location: Online

Office Location: Online

Office Phone Number: 202-215-5807(cell)

Office Hours: Tuesday 8-10pm

Lecturer: Jason Blazakis

The course examines how terrorist groups finance their operations. It also explores

current policy approaches to curb financial support to terrorists through the application of

U.S. and international sanctions, in particular how multilateral fora, such as the United

Nations and the Financial Action Task Force, disrupt and deter terrorist financing. At the

completion of the course, students will have a better understanding of the key tools,

including law enforcement, diplomacy, and intelligence, that are used to counter

terrorists’ financial networks and activities. Students will use structured analytic tools

such as weighted ranking methods, scenario trees, causal flow programming, game

theory, and logic to form analytic judgments.

Analytical Reasoning Learning Objectives

By the end of the course, students will be able to:

Demonstrate proficient ability to communicate using formal or mathematical tools

through Venn analysis, weighted rankings, cost benefit analysis, causal flow

diagramming, chronologies and timelines, matrices, network analysis,

morphological analysis, adversarial collaboration analysis, pattern recognition,

and game theory.

Distinguish between premises and conclusions, or between data and inferences

from data through weighted rankings and Venn analysis.

Course Materials

The following books are required for the course:

Biersteker, Thomas and Eckert, Sue, Countering the Financing of Terrorism, New

York, NY: Routledge Press, 2008.

Fowler, Robert, A Season in Hell: My 130 Days in the Sahara with al Qaeda,

Toronto, Canada: Harper Collins, 2011.

Heuer, Richards and Pherson, Randolph, Structured Analytic Techniques, Second

Edition, CQ Press, 2014. ISBN: 1452241511.

Adams, James, The Financing of Terrorism. Simon and Schuster, 1986.

Course Requirements

Your final grade in this course will be based on:

Tentative

40% Final Paper (DUE JULY 9)

30% Lab Exercises/Group Activity (15% per activity)

20% Mid-Term Paper/Briefing (DUE BY 1159PM ON JUNE 14)(MUST BE FROM

LECTURES 1-6)

10% Class participation

Final Exam

The final paper will constitute 40%. You must draft a paper based on a topic covered

between lectures 7-14. The paper must be between 10-20 pages double spaced. Please use

MLA style citations. FINAL PAPER US DUE JULY 9 at 1159PM

In Class Team-Lab Exercises/Weekly Homework

Students (in small groups and online) will actively participate in solving problems that

focuses specifically on learning analytical techniques. Lab sessions/Team Exercises will

constitute 30% of your grade. These assignments are due on June 10 and June 19. I will

assign the groups. In these sessions areas that will be explored include:

1. Weighted Rankings and Venn Analysis

2. Chronologies, Matrices, and Network Analysis

3. Causal Flow Diagramming and Morphological Analysis

Mid-Term Paper and Briefing

The mid-term will take place on week seven. The mid-term will consist of two parts, a

paper and a presentation. The paper will constitute 10% of the grade. The topic of the

mid-term paper must be approved by the instructor at least two weeks prior to the due

date. The paper should focus on a week one, two, three, four, five, or six lecture, reading,

or lab topic.

Each student will also provide a short five-minute presentation of his/her paper to the

class. You will tape this online as a video blog. This portion of the mid-term will

constitute 10% of your grade. This is all due by 1159PM on June 14.

Class Participation

In-class participation is a critical component of the course. In order to facilitate

discussion, it is essential that you keep pace with the assigned readings. You responses

to the discussion board questions will serve as your form of class participation. Class

participation will represent 10% of your grade.

CLASS POLICIES:

Student Conduct and Academic Integrity. Students are expected to adhere to the

University of Maryland’s Code of Student Conduct and to treat each other with respect. Tentative

Disruptive behavior of any kind will not be tolerated. Students who are unable to

demonstrate civility with one another or with the instructor or teaching assistants, will be

subject to referral to the Office of Student Conduct or to the Campus Police. The Code of

Student Conduct is available online:

http://www.president.umd.edu/policies/docs/v100b.pdf.

Students are also expected to adhere to the University of Maryland’s Code of Academic

Integrity and to refrain from acts of academic dishonesty. All students must write the

Student Honor Pledge on all assignments:

I pledge on my honor that I have not given or received any unauthorized

assistance on this examination.

Any student committing an apparent act of academic dishonesty will be subject to referral

to the Student Honor Council. The Code of Academic Integrity is available online:

http://www.president.umd.edu/policies/docs/III-100A.pdf.

Plagiarism. I will not tolerate plagiarism. If you are caught plagiarizing, you will receive

an “F” on the assignment, and you may be referred to the University of Maryland’s

Honor Council. The following text on what constitutes plagiarism comes from the

website, http://www.plagiarism.org/, which is a useful resource if you would like more

information on the topic:

Many people think of plagiarism as copying another individual’s work or

borrowing someone else's original ideas. But terms like “copying” and

“borrowing” can disguise the seriousness of the offense. The expression of

original ideas is considered intellectual property and is protected by copyright

laws, just like original inventions. Almost all forms of expression fall under

copyright protection as long as they are recorded in some way (such as a book or

a computer file).

All of the following practices are acts of plagiarism:

“The Forgotten Footnote”

The writer mentions an author's name for a source but neglects to include

specific information on the location of the material referenced. This

practice often masks other forms of plagiarism by obscuring source

locations.

“The Misinformer”

The writer provides inaccurate information regarding the sources, making

it impossible to find them. Tentat

ive

“The Too-Perfect Paraphrase”

The writer properly cites a source but neglects to place quotation marks

around text that has been copied word-for-word (or close to it). Although

attributing the basic ideas to the source, the writer is falsely claiming

original presentation and interpretation of the information.

“The Resourceful Citer”

The writer properly cites all sources, paraphrasing and using quotations

appropriately. The catch? The paper contains almost no original work!

“The Perfect Crime”

In this case, the writer properly quotes and cites sources in some places,

but goes on to paraphrase other arguments from those sources without

citation. This way, the writer tries to pass off the paraphrased material as

his or her own analysis of the cited material.

“I Thought We Didn't Have to Quote Facts”

Because the Internet makes information so readily available, students may

find it difficult to tell the difference between “common knowledge” they

are free to use, and original ideas which are the intellectual property of

others. When in doubt, cite sources.

“Confusion about Expectations”

Students may not be aware of what proper research requires. They may

think they are being asked simply to report critical commentary, or to

“borrow” from a number of sources to show that they have “done their

homework.” In either case, it becomes a problem if what they submit is

predominantly comprised of the work of other scholars and/or analysts.

One of the most common sources of confusion is the ambiguity of terms

such as “analyze” and “discuss.” These words have specific meanings in

academic discourse, and they imply a degree of original thought that goes

beyond mere “reporting.” (Plagiarism.org)

Course schedule

Lecture 1 Introduction and General Discussion on Terrorism

- General introduction

- Overview of the course

- Discuss syllabus and course expectations

- General discussion on terrorism. What is terrorism? Is terrorism new? Why are you

interested in the topic? Lecture will summarize readings.

Required Readings:

- Chaliand, Gerard, and Blin, Arnaud: The History of Terrorism: From Antiquity to al

Qaeda. University of California Press, 2007. Introduction: Pages 1-11. Tentat

ive

- Harmon, Christopher, Pratt, Andrew, and Gorka, Sebastian: Toward a Grand Strategy

Against Terrorism. McGraw-Hill, 2011. Units 1.1 and 1.2, Pages 2-60. - Zarate, Juan:

Treasury’s War. Public Affairs, 2013. Read prologue, introduction, and chapter 1 (ix-45).

Lecture 2 General Discussion on Terrorist Finance

General discussion on terrorist finance and why it Matters: What methods do terrorists

use to raise funds for their activities? How important is financial support to the conduct

of a terrorist attack? Are the costs of terrorist attacks prohibitive? Do governments think

about terrorists’ financial activities differently in the wake of 9/11?

Required Readings:

- Costigan and Gold: Introduction, pages 1-9.

- Biersteker and Eckert: Introduction, pages 1-16.

- Roth, John, Greenburg, Douglas, and Wille, Serena; National Commission on Terrorist

Attacks Upon the United States: Monograph on Terrorist Financing. Staff Report to the

Commission. Introduction and Executive Summary, pages 2-16.

- Freeman, Michael: “The Sources of Terrorist Financing: Theory and Typology,”

Studies in Conflict and Terrorism, 34:6, pages 461-475.

Learning Objectives:

Students will understand the role of the designation of ‘Foreign Terrorist

Organization’ in the United States.

Students will understand the context of financing pathways and methods.

Students will understand the methods governments can utilize to fight terrorism

post 9/11.

Students will understand the restrictions placed on governments when fighting

terrorism.

In Class Lab/Team Exercise: Intuitive and Analytic Thinking and History of

Structured Analytics For this session students should be prepared to understand/discuss the differences

between intuitive and analytic thinking; the different types of bias; and history of

structured analytics.

Required Reading:

- Heuer and Pherson: Chapters 1, 2, and 3.

Learning Objectives:

Students will understand the differences in types of thinking and bias as it relates

to the history of structured analysis.

Students will know the strengths and weaknesses of each type of thinking and

when each can be used best.

Students will understand the differences among appropriate and inappropriate

methods for drawing conclusions.

Tentat

ive

Lecture 3 Case Examples of Terrorist Finance: The Irish Republican Army and Hizballah

A look at historical efforts at raising funds to support terrorist activities; discussions will

center on the Irish Republican Army’s fundraising efforts in the United States and its use

of the Irish mafia to secure funds for its terrorist activity against the United Kingdom.

We will also examine Hizballah’s illicit activity in the United States. How is Hizballah

raising funds illicitly? How is the group using money-laundering techniques to hide the

source of its funding?

Required Readings:

- Adams, James: The Financing of Terrorism. Simon and Schuster, 1986. Chapters 6 and

7, pages 131-184

- Operation Pegasus – Executive Summary of the Drug Enforcement Agency’s operation

to expose Hizballah’s money laundering activity between 2007-2011

- United States of America v. Lebanese Canadian Bank et al. December 15, 2011. Pages

1-75.

- Becker, Jo: “Beirut Bank Seen as a Hub of Hezbollah’s Financing.” The New York

Times, December 13, 2011.

Learning Objectives:

Students will understand the differences between state-sponsored terrorist groups

and non-state-sponsored terrorist groups.

Students will understand the base concept of money laundering and the

mechanisms of how it works to finance terrorism.

Students will understand the intersections between beliefs and motivations of

groups and financing mechanisms.

In Class Lab/Team Exercise - Weighted Rankings and Venn Analysis

For this session students should be prepared to understand (utilize)/discuss (their

mathematical findings through) the use of weighted rankings, and Venn analysis.

Required Readings:

- Heuer and Pherson: Chapter 4, pages 63-67, 72-77.

- Jones, Morgan: “The Thinker’s Toolkit,” pages 139-170.

Learning Objectives:

Students will understand weighted ranking and Venn analysis and when to use

these tools of analysis.

Students will understand how Venn analysis and weighted ranking lead to valid

conclusions.

Students will be able to distinguish between premises and conclusion, or between

data and inferences from data.

Tentat

ive

Lecture 4 Case Example of Terrorist Finance: Al Qa’ida and the Haqqani Network

What are the origins of al Qa’ida (AQ)? What were AQ’s original goals? Why did it

attack the United States? How has AQ changed direction since 9/11? How did AQ

finance its operations? Does AQ matter anymore? How does the Haqqani Network

finance its operations?

Required Readings:

- Chaliand, Gerard, and Blin, Arnaud: The History of Terrorism: From Antiquity to al

Qaeda. University of California Press, 2007. Chapter 13, Pages 314-348

- Roth, John, Greenburg, Douglas, and Wille, Serena: National Commission on Terrorist

Attacks Upon the United States: Monograph on Terrorist Financing. Staff Report to the

Commission. Chapter 2, pages 17-30, Chapter 5, pages 67-86, Chapter 6, pages 87-113.

- Biersteker and Eckert: Chapter 9, Pages 193-206.

- Peters, Gretchen: Haqqani Network Financing: The Evolution of an Industry, West

Point Combating Terrorism Center, July 2012. Read the entire report.

Learning Objectives:

Students will understand the role of the Haqqani network terrorism and how it

wields power.

Students will understand how the progression of a group over time can change

their needs and financial methods.

In Class Lab/Team Exercise - Chronologies, Matrices, and Network Analysis

For this session students should be prepared to understand/discuss the use of chronologies

and timelines, matrices, and network analysis.

Required Readings:

- Heuer and Pherson: Chapter 4, pages 56-62, 68-71, 78-86

- Jones, Morgan: “The Thinkers Toolkit,” pages 106-118.

Learning Objectives:

Students will understand the differences in conclusions drawn from timelines,

matrices, and network analysis.

Students will understand the differences among appropriate and inappropriate

methods for drawing conclusions.

**GROUP LAB EXERCISE ASSIGNMENT DUE JUNE 10

NO LATER THAN 1159PM.

Lecture 5 The Islamic State’s (aka, ISIL, ISIS, DAESH) Finances Tentat

ive

How does the Islamic State finance operations? How does the Islamic State move

money? What methods does the Islamic State deploy to raise money? What is the

relationship between the territory the Islamic State holds and its ability to finance

operations? Is the Islamic State the richest terrorist group in history?

Required Readings:

- Financial Action Task Force: Financing of the Terrorist Organization Islamic State in

Iraq and the Levant, FATF, February 2015

- Hansen-Lewis, Jamie, and Shapiro, Jacob: Understanding the Daesh Economy,

Perspectives on Terrorism, August 2015. Volume 9, Issue 4 ISSN2334-3745.

Lecture 6 Terror Finance Methods – Drugs, Crime, and Money Laundering

How do terrorist organizations finance operations? How do terrorists move their money?

What methods do terrorist groups deploy to raise money? What is money laundering?

What is the intersection between drugs and terrorism? How important are drug profits to

FARC and Taliban operations?

Required Readings:

- Odeh, Ismail: Anti-Money Laundering. Dorrance Publishing Company, 2010. Pages 1-

13, and 59-65

- Biersteker and Eckert: Chapter 6, pages 126-147.

- Begin reading A Season in Hell by Robert Fowler, Parts I and II.

- Peters, Gretchen: Seeds of Terror: How Heroin is Bankrolling the Taliban and Al

Qaeda. Thomas Dunne Books, 2009. Chapter 1, Pages 1-24, and Chapter 4, Pages 103-

144.

- Adams, James: The Financing of Terrorism. Simon and Schuster, 1986. Chapter 9,

pages 215-234.

- Peters, Gretchen: Seeds of Terror: How Heroin is Bankrolling the Taliban and Al

Qaeda. Chapter 3, pages 67-101 and Chapter 6, pages 165-183.

Learning Objectives:

Students will understand intersections between terrorist activity and financing

mechanisms.

Students will recognize the shifting of priorities within terrorist organizations

based on the importance of their illicit funding stream.

In Class Lab/Team Exercise - Causal Flow Diagramming and Morphological

Analysis (your in class exam may also include a Money Laundering Exercise so be

ready for anything!)

For this session students should be prepared to understand/discuss the usefulness of

causal flow diagramming and morphological analysis with a specific emphasis on

Heuer/Pherson’s concept of quadrant crunching.

Required Readings:

- Heuer and Pherson: Chapter 5, pages 119-129 Tentat

ive

- Jones, Morgan: “The Thinkers Toolkit,” pages 94-100.

Learning Objectives:

Students will apply appropriate methods to evaluate inferences and to reason

about complex information.

Students will understand the differences among the appropriate and inappropriate

methods for drawing conclusion through causal flow diagramming and

morphological analysis.

**GROUP LAB EXERCISE ASSIGNMENT DUE JUNE 19 at

1159PM

Lecture 7 Kidnap for Ransom as a terrorist finance method

Kidnapping has long served as a method for funding terrorist operations. Today, ransoms

paid to kidnappers provide a significant source of funding to a number of terrorist

organizations, ranging from al-Qa’ida in the Islamic Maghreb and Abu Sayyaf Group to

the Haqqani Network and FARC.

Required Readings:

-Adams, James: The Financing of Terrorism. Simon and Schuster, 1986. Chapter 8,

pages 187-211.

-Fowler, Robert: Parts III, IV, Aftermath, and Appendix A.

- Benjamin, Daniel: Stop Funding Terrorists. The New York Times, February 17, 2011.

- Brennan, John: Kidnapping for Ransom. Remarks by John Brennan, Assistant to the

President for Homeland Security and Counterterrorism, McLean, VA, March 12, 2012.

- Callimachi, Rukmini: Paying Ransoms, Europe Bankrolls Qaeda Terror. The New

York Times, July 20, 2014.

Learning Objectives:

Students will recognize the role of kidnap for ransom in society and the financing

of terrorism.

Students will analyze the dynamics and dangers at play with kidnap insurance.

Lecture 8 Moving Money – Informal Value Transfer Systems (focus on Hawalas); Non-

Banking Financial Institutions and Money Service Businesses

What are hawalas? How is money moved through non-banking financial institutions and

money service businesses?

Required Readings:

- El-Qorchi, Mohammed: Hawala. Finance and Development, International Monetary

Fund, Vol. 39, No. 4, December 2002. Pages 1-6.

- Passas, Nikos: Informal Value Transfer Systems, Terrorism, and Money Laundering, A

Report to the National Institute of Justice, November 3. Pages 22-59, 86-90. Tentat

ive

- Costigan and Gold: Chapter 3, pages 49-62

Learning Objective:

Students will understand the role of non-banking institutions in society and the

financing of terrorism.

Students will understand and analyze complexity of informal value transfer

networks.

Students will understand the dynamics and consequences of countering all hawala

transfers.

Lecture 9 Terrorist Finance Methods – Role of States; Terrorist Use of the Internet; and

Charities

How and why do countries fund and sponsor terrorism? Which countries sponsor

terrorist groups? How do terrorist groups use charities and work or manipulate diaspora

communities to fund operations? How do terrorists use the Internet to assist the finance

of operations?

- Counter-Terrorism Implementation Task Force Report: Countering the use of the

Internet for Terrorist Purposes, CTITF Publication Series, May 2011. Chapter 1, pages

1-3 and 5-6; Chapter2, pages 17-27 (sections A, B, and C) and pages 31-38 (sections G

and H).

- Byman, Daniel: Deadly Connections: States That Sponsor Terrorism. Cambridge

University Press, 2005. Chapter 3, pages 53-78.

- Biersteker and Eckert: Chapter 5, Pages 93-125.

Learning Objectives:

Students will understand the dynamics at play with state sponsors of terrorism and

the terrorist group being supported.

Students will understand the tools in place to investigate and curtail unintentional

or deceitful terrorist fundraising.

Students will recognize the role charities play in financing terrorism.

Lecture 10

Countering Terrorist Finance – U.S. Terrorist Designations Policy

A popular tool for countering terrorist finance is terrorist designations/sanctions. How

does the United States Government counterterrorist financing through the implementation

of terrorist designations? Which agencies carry out terrorist designations? How does the

U.S. interagency process for terrorist designations work? What are the legal thresholds

for U.S. terrorist designations? What are the differences between Foreign Terrorist

Organization (FTO) designations and designations carried out under Executive Order

(EO) 13224? What are the consequences of terrorist designations under these

authorities?

Required Readings: Tentative

- Review the Department of State website dedicated to Foreign Terrorist Organization

Designations http://www.state.gov/j/ct/rls/other/des/123085.htm

- Review the Department of State website dedicated to its terrorist designations under

E.O. 13224 http://www.state.gov/j/ct/rls/other/des/122570.htm

- Read Executive Order 13224 (Pages 1-6).

- Cronin, Audrey: “Why the Haqqani Network is Not on the Foreign Terrorist

Organization List,” Foreign Affairs, December 21, 2011.

- Supreme Court Opinion: Holder v. Humanitarian Law Project.

- Zusman, Lynne K, editor: The Law of Counterterrorism. American Bar Association,

2012. Chapter 4, pages 91-106.

Learning Objectives

Students will recognize when an organization fits the criteria of a foreign terrorist

organization.

Students will understand the role designation of foreign terrorist organizations

play in countering terrorism.

Students will understand the designation process used to label a group a foreign

terrorist organization.

Lecture 11 Countering State Sponsors of Terrorism

What is the purpose of a “State Sponsor of Terrorism” designation? Why is countering a

state sponsor of terrorism difficult? How does the United States counter state forms of

terrorism? What is the utility of the U.S. State Sponsor of Terrorism List?

Required Readings:

- Byman, Daniel: Deadly Connections: States That Sponsor Terrorism. Cambridge

University Press, 2005. Chapters 9-10, pages 259-311.

- O’Sullivan, Meghan: Shrewd Sanctions. Brookings Institution Press, 2003. Chapter 3

(Influencing Iran). Pages 45-103

Learning Objectives:

Students will understand the role of a state sponsor and the tools given to the US

government to counter their acts when a state is designated as a state sponsor.

Students will be able to analyze if a country should be designated as a state

sponsor of terrorism and what that would mean for the country.

Lecture 12

Countering Terrorist Finance – Multi-lateral Responses

What is the role of the United Nations in countering terrorist finance? Is the UN effective

in countering terrorist financing? What are UN “1267” sanctions? What are the

objectives of the UN Counter-Terrorism Committee? What is the role of the Financial

Action Task Force (FATF) in countering terrorist finance? Is it an effective multilateral Tentative

body? What are the challenges facing the United Nations and FATF in countering

terrorist finance? How does the United States work within the UN and FATF to achieve

its counterterrorism objectives?

Required Readings:

- Gottlieb, Stuart, editor: Debating Terrorism and Counterterrorism. CQ Press, 2010.

Chapter 9, pages 272-303.

- United Nations 1267 Monitoring Team: “Eleventh Report of the Analytical Support and

Sanctions Implementation Monitoring Team,” UN Report Number: S/2011/245. April

13, 2011.

- Taylor, Gillian, and Tladi, Dire: “On the Al Qaida/Taliban Sanctions Regime: Due

Process and Sunsetting,” Chinese Journal of International Law. November 25, 2011

- Forcese, Craig, and Roach, Kent: “Limping Into the Future: The U.N. 1267 Terrorism

Listing Process At The Crossroads,” George Washington International Law Review.

Volume 42, 2010.

- http://www.un.org/en/sc/ctc/aboutus.html (Review the UN’s Counter-Terrorism

Committee’s website)

- Financial Action Task Force (FATF): “An Introduction to the FATF and its Work,”

FATF, 2010.

Learning Objectives:

Students will understand the differences in domestic and international counter

finance methods and the implications for these differences.

Lecture 13 Countering Terrorist Finance – Multilateral Responses; Regulatory Approaches to

Countering Terrorist Financing; Role of Intelligence What are the roles of multilateral regional bodies in countering terrorist finance? How

does the G-8’s Roma/Lyon Group, Organization of American States, Asia Pacific

Economic Cooperation’s Counter-Terrorist Task Force and the ASEAN Regional Forum

and other multilateral regional bodies address terrorist finance? Are these regional

multilateral bodies an effective means of countering terrorist finance? What other

methods are deployed in order to counter terrorist finance? What roles do Financial

Intelligence Units (FIUs) play? Are FIUs effective?

Required Readings:

- Harmon, Christopher, Pratt, Andrew, and Gorka, Sebastian: Toward a Grand Strategy

Against Terrorism. McGraw-Hill, 2011. Unit 4.1, pages 314-327.

- U.S. Department of State: Country Reports on Terrorism 2013 “Multilateral Efforts to

Counter-terrorism.” April 2014, pages 234-238.

- U.S. Department of the Treasury Fact Sheet: Terrorist Finance Tracking Program.

August 2, 2010.

- U.S. Department of the Treasury: Terrorist Finance Tracking Program: Questions and

Answers. August 5, 2011. Tentative

- Levitt, Matthew: “Follow the Money: Leveraging Financial Intelligence to Combat

Transnational Threats,” Georgetown Journal of International Affairs. Winter/Spring

2011, pages 34-43.

- International Monetary Fund and World Bank: Financial Intelligence Units: An

Overview. International Monetary Fund Publications, Washington D.C. July 23, 2004,

pages 1-5 (Introduction).

- Egmont Group: Annual Final 2010-211 Report. The Egmont Secretariat Secretariat,

2011, pages 8-14.

Learning Objectives:

Students will understand how the international community has changed

approaches to counter finance terrorism.

Students will understand the influence and importance of the international

community’s influence.

Lecture 14 Class wrap-up. Will terrorist finance methods change markedly after Usama bin

Laden? How will counterterrorist finance efforts shift in the future?

Required Readings:

- Biersteker and Eckert: Chapter 13, Pages 289-304.

- Fernholz, Tim, and Tankersley: “The Cost of Bin Laden: $3Trillion Over 15 Years,”

The Atlantic. May 7, 2011.

Tentative