Preserving Specialized Capabilities and Identities: Examining Proposals to Merge Army Counterintelligence with Human Intelligence

Special Agent Brad Stockham, Region II, U.S. Army Counterintelligence Command

Special Agent Roy D. Christensen Jr., Senior ACI MICECP Agent, 207th MIB-T, Vicenza, Italy

LTC Kevin Halleran, CI/HUMINT Division Chief, U.S. Army Reserve Command

DISCLAIMER: The opinions in this paper belong solely to the authors and do not necessarily represent the position of the Department of the Army, or any other part of the U.S. Government.

U.S. Army Military Intelligence (MI) leaders have revisited the idea of merging the U.S. Army’s 35L – Counterintelligence (CI) Special Agent and 35M – Human Intelligence (HUMINT) Collector Military Occupational Specialties (MOS), with a pilot program for a combined training course being conducted by the Intelligence Center of Excellence (ICOE). This proposal appears directed at increasing CI support to tactical units at Echelons Corps and Below (ECB). Similarly, a provisional command known as 1st Intelligence Command (1IC) was stood up that obfuscates U.S. Army Counterintelligence (ACI) Command (ACIC), combining elements of advanced HUMINT capabilities within its organizational structure. While similar past proposals were framed as efforts to streamline operations or increase efficiency, a closer analysis suggests that such structural changes could introduce substantial risk to specialized capabilities that currently support U.S. national security (NATSEC) in addition to hindering future successes of ACIC.

From an unclassified standpoint, this paper analyzes the historical context of CI and HUMINT within the U.S. Army, their distinct missions, and the professional frameworks that enable each to operate effectively. It also examines the role of ACIC and the progress achieved since its establishment in 2021. The analysis concludes that CI and HUMINT within the Army represent complementary but fundamentally different disciplines that rely on individually unique specialized training, authorities, and institutional identities. Therefore, any structural consolidation that merges them represents unwarranted risk in diluting their capabilities while also undermining the progress made in professionalizing the ACI Enterprise and Army HUMINT. Overall, this analysis demonstrates that a potential merger of CI and HUMINT disciplines in the U.S. Army is likely to be detrimental to the Army’s efforts in supporting NATSEC and ACIC’s ability to neutralize emerging threats.

Within U.S. Army MI, discussions about merging ACI (35L) and Army HUMINT (35M) MOS specialties have periodically resurfaced. These proposals typically arise from a perception that the two disciplines perform similar functions because they both collect information from human sources. This interpretation, however, oversimplifies the roles and responsibilities of each field. CI and HUMINT operate within different legal frameworks, mission sets, and operational objectives. From a full-spectrum stand point, CI consists of all the measures that a nation takes to protect its citizens, secrets, and technology from foreign spies.1 Specifically, ACI focuses on detecting, identifying, exploiting, and neutralizing Foreign Intelligence Entities (FIE) and Foreign Terrorist Organizations (FTO), in addition insider threats who may have been directed or inspired by them to conduct espionage, sabotage, assassination, acts of terrorism, or other illegal acts targeting the U.S. Army or Department of War (DoW) that have been codified as NATSEC Crimes. HUMINT, by contrast, focuses primarily on the acquisition of intelligence information through the recruitment and handling of sources, conducting debriefings, and conducting intelligence focused interrogations, to inform tactical, operational, and strategic decision-making by commanders and the larger U.S. Intelligence Community (IC).

The creation of ACIC as the Department of the Army’s (DA) Military Department CI Organization (MDCO) in 2021 represented a significant step toward strengthening the Army’s ability to conduct full-spectrum CI activities under Secretary of the Army (SECARMY) authorities. Similar to the other MDCOs: The Naval Criminal Investigative Service (NCIS) and the Air Force Office of Special Investigations (OSI), ACIC established a centralized Army command dedicated exclusively to carrying out all functions of CI (Investigations, Operations, Collections, Analysis/Production, and CI Functional/Technical Services), enabling greater unity of effort and richer partnerships with other federal CI agencies across the globe. This paper evaluates whether merging ACI and Army HUMINT or creating a new combined command, would enhance or diminish these capabilities. By examining operational functions, legal authorities, historical lessons, and comparative models, the paper assesses the potential second and third order effects of such changes.

1 Olson (2019). To Catch a Spy: The Art of Counterintelligence. Georgetown University Press

The proposal to merge ACI with Army HUMINT roles is not new, nor is the idea of combining various intelligence disciplines into a single command, as this was how the U.S. Army Intelligence and Security Command (INSCOM) was formed.2 Throughout Army history, there have been periodic attempts to consolidate intelligence specialties that may have been perceived as overlapping or redundant. In many cases, these proposals stem from efforts to reduce manpower requirements or simplify force structures rather than from demonstrated operational deficiencies. However, with ACI specifically, it is the one intelligence discipline that goes beyond just collection or analysis, while also having a history as an independent organization focused solely on CI. Historical attempts to merge its capabilities outside of the CI mission, or to create organizations that have erased its institutional identity, have all resulted in a degraded CI mission that left the Army and our nation more vulnerable to foreign threats. This was one factor that the creation of ACIC was meant to address. While nuance exists, from an outside perspective, the creation of 1IC along with the proposal to merge ACI and HUMINT appears to be a repeat of flawed proposals that fail to recognize this in ACI history.

The Birth of ACI: ACI itself traces its roots back to World War I with the establishment of the Corps of Intelligence Police (CIP); the original name for ACI that stood up in 1917. The CIP took enlisted men with police experience who could speak French for its initial agent force and they were put to work looking for enemy spies and insider threats to ensure protection of the war effort.3 During World War II after the CIP rebranded itself as the Counter Intelligence Corps (CIC), agents operated at tactical, operational, and strategic levels providing direct CI support from a centralized command that managed agent activities through CIC headquarters, who in-turn reported directly to the Army Assistant Chief of Staff for Intelligence (later known as the DCS G-2). These CIC agents served on the front lines and beyond, often attached to different units. They worked sensitive offensive and defensive projects at home and abroad, conducted raids of enemy intelligence elements, were often partnered with the Federal Bureau of Investigation (FBI) and Office of Strategic Services, and they even worked domestically in undercover roles with police departments to catch Japanese and German spies.4 By all accounts, the CIC was highly successful, and to this day, the full exploits and positive effects these agents had on the war effort is not fully known, as many of their activities remained classified and lost to time.

First Attempted Merger of ACI: It was during WWII that the first concept of a CI merger arose, not from any reported failure of CI or the CIC, but from an Inspector General report highlighting overlaps between the CIC and Military Police (MP). Despite many inside and outside of CIC vocalizing it as a bad idea, the organization was halted and CIC agents within the U.S. were placed under a new Security Intelligence Corps within MP Command, overseen by the Provost Marshal General. Within months, problems arose with the specialized training of replacement agents and decreases in the overall successes of CI missions, all resulting from the decentralization of CIC operations. The decision was quickly reversed, restoring the CIC, and the attempted merger was viewed as a complete failure. However, this did not stop future merger attempts within MI or other attempts to decentralize ACI.5

2 INSCOM: Continuity and Change. US Army Intelligence and Security Command History.

3 Tagg (2017). Intelligence Police Established in WWI. U.S. Army.

4 Tactical Counterintelligence in Support of Large-Scale Combat Operations (2022). Military Intelligence Professional Bulletin, vol. 48, no. 3: 8-14.

5 Stewart (2022). COL Kibler Resurrects the Office of the Chief, CIC. U.S. Army.

ACI becomes Dispersed and De-centralized: Throughout the 1950s and 1960s, different leaders within Army MI attempted to consolidate all intelligence disciplines and authorities into a single agency. Much like today with creation of 1IC that now obscures ACIC, the Army eventually created what was first called the Army’s “Intelligence Corps,” later known as the “U.S. Army Intelligence Agency,” and the CIC was ultimately disbanded as a result, with the new agency taking their CI-specific authorities. For a time, these ACI agents operated in similar fashions with legacy CIC leadership and experience in place. However, the loss of their institutional identity, a lack of priority placed on the CI mission, and the “Intelligence Organization and Stationing Study” of 1975 that led to the creation of INSCOM, ultimately caused degradations in CI operational effectiveness. These changes, along with the entire IC under review in the aftermath of the Church Commission, eventually resulted in a heavily diluted ACI force, a lack of direction in CI investigations and operations, and no unity of effort in the CI mission as a whole.6

ACI agents became dispersed among the force with no centralized command, had much of their training combined with other MI elements that was not fully compatible with CI (as shown in many course critiques by CI Warrant Officers and enlisted agents attending professional military education courses), and were under the direct control of commanders who may or may not have understood the importance of CI. As a result, the Army spent over 40 years with a less aggressive CI force with atrophied law enforcement (LE) authorities, while FIE and FTO activities, penetrations, and other NATSEC crimes, continued to rise.7 This occurred despite the expert ACI agents that MI was still able to produce, as there was still a singular MOS focused on CI alone. Those agents just lacked the full authorities, funding, institutional brand identity, and mission management that comes from a CI-focused command or service. Yet, there were still attempts to merge the now diluted agent-force even more. Examples such as the ill-fated Foreign Intelligence Command (FIC) and the failed 2015 attempt to create an Army CI/HUMINT Command (ACHC), all seem to represent efforts to tackle problems that wouldn’t be solved, or that would create additional issues (at least with ACI). Many agents were aware that a majority of problems within ACI resulted from the Army’s lack of a dedicated CI organization and continued to voice this.

ACIC Stands Up: In 2021, the creation of ACIC changed all of that. For the first time since the CIC, ACI not only had name recognition within the IC and LE partners, but a command that is singular focused on the CI mission alone, which is an absolute necessity in countering foreign adversarial intelligence and terrorist networks. ACIC has demonstrated this in less than five years by making more NATSEC related arrests and even more threat disruptions than the entire ACI Enterprise had accomplished in the previous three decades (as reported by ACIC and senior CI executives at the Pentagon). And this is only a single metric, as additional aspects have also positively improved but cannot be discussed in this unclassified paper. Even in the other full-spectrum CI agencies (NCIS, OSI, FBI), there are now specialized billets for their CI Special Agents, although ACIC not needing to focus on general criminal matters as an organization may have also contributed to its success. For more than a century, ACI has evolved into a complex professional field encompassing NATSEC criminal investigations, advanced collection techniques (which the use of human sources is included), defensive and offensive operations, CI threat analysis, and sensitive counterespionage activities; with the largest share of these activities now being conducted by ACIC. These responsibilities require specialized legal authorities, investigative training, and coordination with other agencies, that now appear to be in jeopardy.

6 Gilbert et al. (2005). In the Shadow of the Sphinx: A History of Army Counterintelligence.

7 Shedd (2020). The Intelligence Posture America Needs in an Age of Great-Power Competition. The Heritage Foundation.

Army HUMINT Historical Contrast: Army HUMINT developed along a different trajectory entirely, focusing on gathering information from human sources to support tactical and operational commanders, along with answering national-level intelligence requirements. While HUMINT collectors also employ tradecraft, their mission emphasis with source operations remains intelligence acquisition answering other’s requirements, in direct contrast to ACI’s use of human sources which is to answer internal requirements and investigative gaps (which can be compared to LE use of informants in general criminal matters).

Additionally, for ACI, source operations are just a capability used to support the CI mission, not the entire focus (and it is just one category of CI collection that also falls into only a single function of CI). Despite these diverging paths, missions, and job functions, there still remains leaders who believe that a merger between ACI and HUMINT is not only possible, but preferable. While there appears to be a variety of reasons for this, this ideology seems most common with those who have served primarily at tactical assignments, and likely because ACI agents have been used as HUMINT collectors by various commanders at several times and units in recent Army history.

In fact, at one time, what is now called a HUMINT collector within the U.S. Army was only known as an Interrogator, conducting interrogations and debriefings only. While the specifics of this history are not clear, many of the changes with the HUMINT MOS appear to have occurred during the 1990s when the Army stood up the FIC which included both advanced CI and HUMINT capabilities.8 However, the Defense Intelligence Agency also created its own Defense HUMINT Service during this time period and many HUMINT authorities were transferred from the various military branches to the DIA along with many civilian HUMINT personnel.9 This decision effectively ended the FIC, while Army HUMINT collectors, along with other military branch’s HUMINT elements, were either decremented or eliminated entirely.10 Within the Army, the remaining military HUMINT personnel were confirmed as being primarily intelligence interrogators and debriefers only.

Meanwhile, ACI agents of this era would often get tasked to conduct HUMINT source operations while still needing to carry out CI duties, due to a lack of dedicated Army HUMINT collectors, which in turn caused dilution in CI mission execution.11 Even after HUMINT got their authorities back, ACI and HUMINT continued to be used interchangeably, and for tactical collection at least, this “either or” utilization was often viewed as being successful by commanders despite the CI mission suffering. As retired CI Warrant Officer Larry Norris states in his 2003 MI Professional Bulletin paper, “Transforming Counterintelligence and Human Intelligence,” the “success of satisfying a combat commander’s need for tactical HUMINT information has resulted in the perception throughout the Army, to include the MI community, that CI equals HUMINT collection or CI and HUMINT are one and the same.” While doctrinally this is no longer done as HUMINT now conducts Military Source Operations (MSO) or Defense HUMINT Activities12, there are still misuses of ACI agents that are rarely questioned by junior agents. The reality sometimes not understood by leaders is that the historical separation of these disciplines reflects the recognition that each field requires deep specialization and attempts to merge them have historically struggled to account for the complexity and scope of both mission sets.

8 Finnegan (1998). Military Intelligence. Army Lineage Series.

9 DIA - A Brief History - 35 Years. Federation of American Scientists Intelligence Resource Program.

10 Norris (2003). Transforming Counterintelligence and Human Intelligence. MI Professional Bulletin, vol. 29, no. 4: 47-50.

11 United States Army (2015). Counterintelligence Volume I: Investigations, Analysis and Production, and Technical Services and Support Activities. Army Techniques Publication 2-22.2-1: 1-1

12 United States Army (2026). Human Intelligence Techniques Volume I. Army Techniques Publication 2-22.1.

The Importance of ACIC: The creation of ACIC represented a major step toward strengthening the Army’s CI capabilities. By centralizing CI operations and investigations, along with providing a dedicated command structure, ACIC has been able to focus on professionalization, investigative standards, and highly productive partnerships with other federal agencies. Efforts to align CI training and authorities with federal investigative partners have improved ACI’s credibility and operational effectiveness of the ACI workforce, not the least of which is ACI agent’s regular attendance at the Federal LE Training Center’s (FLETC) Criminal Investigator Training Program (CITP) colloquially known as the “1811 certification course,” resulting in stronger relationships and acceptance in FBI Joint Terrorism Task Forces (JTTF) and CI Task Forces (CITF), as well as, parity with the other MDCOs. Initiatives such as advanced investigative training, expanded legal authorities for civilian agents, and closer integration with interagency partners contributed to measurable improvements in the ACIC’s ability to identify and disrupt threats.

Structural changes that dilute this focus could reverse progress made over the past several years. CI professionalization requires optimized mission management and sustained emphasis on specialized skills, authorities, and institutional identity. An analysis of the proposed plan to combine the CI/HUMINT Army career fields demonstrates that it would introduce competing priorities that undermine the depth of expertise required for NATSEC investigations and operations. However, the forces driving this potential merger are not necessarily incorrect regarding the problems they are trying to address, they may just be unaware of the negative second and third order effects as they largely appear to be outside of ACIC. Providing feedback while clearly outlining why CI and HUMINT within the Army are not currently compatible without a larger force structure change may be necessary to inform decision makers.

Continued Outside Influence: Even with an understanding that CI and HUMINT are different and that ACIC has been successful despite not being fully matured, there appears to be continued outside influence to further restructure ACI and merge it with HUMINT, or to combine responsibilities of both into a single organization. In addition to other factors already discussed, there are leaders outside of ACI who look at CI as primarily being a counter-HUMINT force, despite the purpose of CI being to counter all adversarial intelligence, not just HUMINT. This sometimes reinforces the idea that CI and HUMINT are compatible, when the reality is it narrows the focus of CI. The truth is, although CI and HUMINT both operate within the human domain, ACI is not bound by it, and the purposes for CI and HUMINT differ significantly. HUMINT collectors primarily obtain intelligence through MSO, debriefings, interrogations, and liaison activities. Their work supports operational intelligence and unit-level requirements, while also contributing to the broader situational awareness of the IC.

ACI, in contrast, focuses on identifying and neutralizing threats posed by FIEs, FTOs, and insider threat actors. This work often involves investigations, counterespionage operations, security assessments, and coordination with both U.S. and allied partners, all of which can be hindered by a commander who may not understand the bigger CI picture or that has competing priorities. CI requires specialized training while the mission demands investigative authorities, legal expertise, experienced CI mission management, and professional standards consistent with federal LE agencies. Maintaining these capabilities requires a professionalized workforce trained and focused specifically for CI investigations and operations, suggesting that combining CI and HUMINT introduces serious risk in reducing the depth of expertise required to perform these functions effectively or in a timely manner.

In order to fully evaluate potential positive and negative effects of a CI/HUMINT merger within the Army, it is helpful to examine models in other organizations that may be similar to ACI. When doing so, an obvious reality sets in: Outside of the Army, ACI is far more compatible with the other MDCOs, and within the Army, is far less compatible with HUMINT (when compared to other Army roles).

The Marine Corps Misconception: A common argument in favor of merging ACI and Army HUMINT comes from the comparison to the U.S. Marine Corps, where the collector roles of CI and HUMINT are combined. While this may appear to validate the argument for a merger in the Army, the Marine Corps model is not an applicable comparison, as ACI alone has far more responsibilities than Marine CI/HUMINT. More importantly, Marine CI/HUMINT is not an MDCO. This means they are not a full-spectrum CI agency like ACI, NCIS, OSI, and the FBI. This also means they have no direct NATSEC criminal investigation mission, which is arguably the largest function conducted by full-spectrum CI agencies. In fact, the only time these CI/HUMINT specialists assist on such matters is when they are attached to an MDCO (such as NCIS, who is the designated MDCO for the Department of the Navy – including the Marine Corps).13

The fact that Marine CI/HUMINT specialists are not designated LE agents, means they also have no need to fully train on or understand the legalities of LE investigations and operations, or to follow the professional standards of other federal agencies (training, probation, age requirements, clean backgrounds, etc.). Marine CI/HUMINT specialists are primarily just collectors, making them experts in that particular function, but it is in fact just one function of CI that only encompasses a small portion of the CI mission that full-spectrum CI agencies do every day. When the full range of activities are carefully reviewed, it is clear that combining ACI with Army HUMINT would not provide adequate CI coverage for the Army as it would introduce competing priorities while deeper expertise is lost. The only way a potential merger could work is if you completely restructured ACIC to only include Special Agents with limited support to tactical collection and then change Army HUMINT Soldiers into a tactical CI/HUMINT Collector force. However, even with this option, there is still a risk of competing priorities while Advanced HUMINT practitioners would likely be reduced and weakened. This comparison illustrates the importance of organizational context. A structural model that functions effectively in one service does not necessarily translate to another service with different authorities, missions, and responsibilities.

The Truth Regarding Army CID: Another comparative organization model to consider is the DA Criminal Investigation Division (CID). Like ACI, CID conducts investigations, handles LE sources/informants to answer investigative gaps, serves on LE task forces, briefs Army leaders on cases, puts agents through legal/LE training, and maintains LE credentials. The difference is that CID has no NATSEC mission, does not conduct offensive operations specifically targeting FIEs or FTOs, does not reside within the IC, and does not have jurisdiction over NATSEC crimes withing the DA. Despite these differences, when broken down by general/cursory activities and training standards that ACI and CID agents are actually doing and/or are trained on as a whole (not by Critical Task Lists as those change unit-to-unit and may be out-of-date with recent reforms in both ACI and CID), it is clear that ACI and CID actually have more in common with each other than ACI does with Army HUMINT (reference Annex A). However, this fact should not directly advocate for an ACI and CID merger either as this is outside the scope of this paper. Additionally, given the Army’s size, having an organization that specializes in CI (including NATSEC crimes and offensive activities) fosters greater expertise beyond what might be easily achievable in the other MDCOs.

13 United States Marine Corps (2025). Counterintelligence and Human Intelligence. MCRP 2-10A.2, 4-4

It is important to note that in 2020, CID underwent its own reform process similar to ACI. While the reasons for CID’s reform differ from ACI’s, there are parallels that can be drawn in that CID had its own command prior to its reform: U.S. Army Criminal Investigation Command (USACIDC), with the Provost Marshal General dual-hatted as the USACIDC Commander. Problems were identified with a Commanding General who was not an agent (in contrast to OSI), and a CID agent force that was (although under USACIDC), still dispersed in its priorities and investigative capabilities (to include a lack of investigative support such as crime analysts). This was changed during its reform process and today, CID operates under a civilian agent chain of command with a civilian Senior Executive Service (SES) director who reports directly to the Under Secretary for the Army, and with military CID agents being decremented over the last five years. While this decision was disagreeable to some Army leaders, the truth is that under a unified name-brand organization with civilian leadership, CID has been able to cut through bureaucracy to make immediate changes that have resulted in better investigative capabilities and outcomes.

Outside MDCO Comparisons: Going outside of the Army, similar comparative analysis has been done between ACI and the other MDCOs: NCIS and OSI. When breaking down the duties, activities, and training of NCIS and OSI, it is clear that ACI/ACIC is aligned with them more than any other organization in the U.S. military (reference Annex A). This is understandable as the MDCOs are driven by DoW policies and have similar, if not identical, CI missions (with NCIS and OSI also having a general criminal investigative mission as well). However, the biggest difference between the other MDCOs and ACIC appears to be the all-encompassing, streamlined nature of NCIS and OSI. The obvious question then becomes, whose model is more effective in conducting CI activities?

For all intents and purposes, ACIC, NCIS, and OSI all have the same CI mission with similar capabilities. The caveat here is that OSI and NCIS operate as independent organizations that do not appear to have the same problems related to its agent work force as ACI does. OSI agents ultimately belong to OSI, as NCIS agents ultimately belong to NCIS, regardless of where they are attached or assigned. This includes training oversight, career management, and global coordination/deconfliction. In contrast, ICOE along with Army Transformation and Training Command (T2COM – formerly TRADOC) manages the initial training of ACI agents and a variety of different organizations manage the assignments and careers of ACI’s military and civilian agents. These different organizations include (but are not limited to): Army Human Resources Command, Civilian Human Resources Agency, Office of the Chief MI (OCMI), the MI Civilian Excepted Career Program (MICECP), and additional sensitive programs.

Additionally, Theater MI Brigades (MIB-T), along with the Army Service Component and Combatant Commands retain and utilize organic ACI agents for their own theater-specific purposes adding more confusion (in a single theater you could have multiple ACI elements causing perplexity of who to report to and who allies should coordinate with). In fact, only about 20% of the badged and credentialed ACI agents in the Army reside in ACIC even though ACIC handles the most critical CI tasks, to include CI Support to Research, Development, and Acquisition (CIRDA) which helps to provide the U.S. Army with overmatch capabilities on the battlefield. This leaves roughly 80% outside the control of ACIC handling matters that are theater-specific or in other assignments that may not contribute to the overall CI mission.

All of this forces ACIC to have to coordinate with many different entities in order to build an effective CI-force, while ACI agents have to rely more on outside organizations for training such as FLETC and the Joint CI Training Activity (JCITA). NCIS and OSI do not have these problems as they manage these things in-house, while the competing elements steering ACI agents in different directions is not conducive to a more capable CI organization.

Many discussions and papers have been written regarding ACI and Army HUMINT restructuring that are often framed around the concept of Large-Scale Combat Operations (LSCO). It has been a recurring theme in recent years within Army MI, focusing on how MI elements support LSCO. Often these discussions begin with a statement that we have been focused on Counter-Insurgency (COIN) operations for too long and need to shift. While true, leaders often take every intelligence discipline and apply similar solutions to them all, especially with CI and HUMINT. An example can be found in the 2025 MI Digest Paper by CW4 Dane Rosenkrans, “Doing More with Less: Restructuring Army CI and HUMINT Capabilities for LSCO” which states that separate CI and HUMINT Army MOS’s are “ill-suited to meet the demands” of LSCO. However, this statement is not justified and reveals a pervasive legacy belief that combining capabilities is always the best solution.

For ACI specifically, this perspective does not fully account for the fact that ACI supports the Protection Warfighting Function as much as the Intelligence Warfighting Function. The reality is, while this line-of-thought may work in modernizing other MOS's, it does not properly describe the real problems facing ACI and specifically how ACI can target and neutralize threats quicker and more effectively. As such, these merger proposals become a distraction that ACI cannot afford to be concerned with. When reviewing other full-spectrum CI organizations and activities along with evolving foreign threats, a clear picture of the actual problems and potential solutions emerge. In addition to needing a "name brand" agency like ACIC to be flat, fast, and focused, the sobering truth is that we have not done a good job emphasizing the importance of having experienced CI investigators in the right places and obtaining or training advanced investigative tools and tactics enough in the larger ACI Enterprise. We have also not done a good job in developing next-generation counter-technical capabilities to be employed by those specializing in multi-discipline CI (MDCI).14

With regards to how ACI should be postured in a LSCO fight, an often-overlooked fact is that CI functions would remain essential regardless of the operational environment. ACI is a force already in contact at Phase “0,” and in large-scale conflicts, adversary intelligence activity targeting U.S. forces is expected to increase across all domains, making CI activities more critical. As such, ACI would still be conducting the same functions it always has. The difference being - especially with near peer-adversaries - is that ACI would be “deepening” in those functions, conducting them with greater weight placed on tradecraft, skill, and technology. This does not mean ACI would no longer run operations against or wouldn’t investigate potential acts of International Terrorism/FTOs (often grouped with a mentality that ACI is still in a "COIN fight"), as this has always been firmly within the ACI investigative lexicon regardless of environment. To reinforce this, the recent conflict in Iran should give every leader pause, as we saw it mobilize or create FTO-inspired Homegrown Violent Extremists (HVE) which the FBI, NCIS, OSI, and ACIC are still investigating.

Ultimately, the belief that merging CI and HUMINT would posture them in a more effective way in a LSCO environment falls short when you apply the loss of specialization and CI mission consolidation. While adapting intelligence capabilities for future conflicts is necessary, it is important to ensure that any proposed changes address real operational challenges rather than perceived structural inefficiencies. Addressing these challenges requires interagency cooperation, deeper expertise in investigative techniques, and giving a CI-focused organization like ACIC the ability to research and develop new MDCI capabilities. Expanding all of these to better neutralize FIEs and FTOs requires investment in training, technology, and personnel rather than structural consolidation (such as a combined CI/HUMINT MOS) that would dilute specialized expertise.

14 Halleran (2026). Beyond HUMINT: Redefining Army Counterintelligence for Modern Warfare. MI Digest.

Another driving force behind many suggestions for an Army CI/HUMINT merger has been the perception that ACI is not providing enough support for tactical units in addition to other elements at ECB. A common saying among senior ACI Case Officers and those who have worked in Field Offices for a majority of their careers is, “there is no such thing as tactical CI.” While true from the perspective of the larger CI mission purpose, it does not change the belief among commanders who perceive ACI as not adequately providing CI support to force protection (FORCEPRO), or ACI is not ensuring their CI reporting requirements are met, or ACI is not collecting enough on things that is of direct interest to them, which can easily lead to organic ECB agents being directed to conduct HUMINT-focused activities. As such, a better way to frame this is that CI is defined by mission, not by echelon. In order to address a perceived lack of CI support by some commanders, we have to break down the exact types of activities ACI agents are responsible for (a troop-to-task), in addition to examining how the other MDCOs manage this issue. In doing so, it is apparent that ACI agents are often burdened with tasks (whether CI related or not) that take them away from the larger CI mission.

Not every task that ACI has been assigned requires a badged and credentialed agent. In fact, a large portion of activities expected by commanders at ECBs (e.g. screenings, assessments, threat briefings, etc.) can be accomplished by non-agents if given permission. Further, ACI agents organic to ECB units are regularly assigned duties not CI related (e.g. guard duty, security manager, etc.) as noted frequently in command climate surveys and anecdotally by agents. This is despite an unclassified portion of Army Regulation 381-20 – The Army Counterintelligence Program, titled, “Duty Limitations” aimed at preventing misuse, as it also contains “work arounds” such as “except as required by the commander of the unit to which they are assigned.” This misuse is not necessarily the fault of the commander or the organic agents; however, the end result of a less protected unit (from a FIE/FTO perspective) still highlights ACI as a whole, seen as not providing adequate CI support. So how is this problem fixed? NCIS and OSI appear to have fewer issues in this realm which reinforces the idea that actual agents should not be needed organically at ECBs. For the Departments of the Air Force and Navy (to include Space Force and the Marine Corps), many tactical-level CI support requirements appear to be delegated to other elements. However, when an actual special agent is required for more than a short period of time, both NCIS and OSI seem to have the ability to attach agents to those outside elements from a centralized organizational structure, via a Memorandum of Understanding (MOU), or some other mechanism. An example of this is the NCIS “agent afloat” program which puts NCIS agents on Navy vessels during long deployments, providing direct CI support to the Sailors aboard. NCIS also has a “Contingency Response Field Office” at FLETC (with agents on three-year rotations), that operates like a “fly team” providing personnel, management, and oversight to deployment and contingency operations, and whose agents teach when not deployed.15

This method of providing CI support appears optimal, as it allows those outside units and commanders to have the direct CI support they need, while still ensuring there is a unity of effort across the force with the larger CI mission. Further, if you removed the agents at ECB, and allowed them to be attached as-needed from ACIC, you could greatly streamline the agent force (and even reduce it) while providing tailored CI support to specific units. This would include eliminating unneeded positions with multiple “agents at rest” not doing anything CI related while providing units with additional specialized CI capabilities, such as those that may be developed for MDCI by ACIC. This may be supplemented by non-agents at ECB who are authorized to conduct basic CI tasks such as screening operations or other general/tactical-level CI support to FORCEPRO activities.

15 NCIS (2025). Contingency Response Field Office. Locations.

Institutional identity also plays a significant role in how organizations operate within the broader NATSEC community. Since its establishment, ACIC has worked to establish a clear identity as the Army’s dedicated CI organization. This identity has enriched partnerships with allies and other federal agencies responsible for NATSEC investigations and CI operations. Federal LE and intelligence partners now recognize ACI or ACIC as the “go to” element within the DA for NATSEC investigative and other CI matters. Clear organizational roles and professional standards facilitate cooperation across agencies and ensure that responsibilities are clearly understood. While perhaps unintentional, introducing a new command structure and name such as with 1IC, or merging the core occupation of ACI with another element, not only dilutes its specialization but it also obscures its identity, which would very likely complicate these relationships.

Organizational branding and recognition are not merely symbolic; they influence how agencies coordinate operations, share information, and allocate responsibilities. The historical lesson of the CIC disbanding with the failures that followed should not be overlooked, as it effectively handicapped ACI regarding future operations and emerging threats. While the creation ACIC began to correct this (and has already demonstrated its success), it has not been allowed to operate under its original concept – to encompass all ACI agents world-wide. Most ACI agents still exist largely outside of ACIC, with a large majority of those at ECB doing nothing related to CI beyond occasional training. Despite this, and despite ACIC not yet being fully matured, it is still a proven model for success, having a high positive impact in the CI mission.

Part of that success is no doubt the pride felt by agents within that command. For too long ACI was disjointed, and many times agent successes went unrecognized, while their counterparts in the FBI, NCIS, and OSI, had an organization backing them, name-brand identity to share with federal partners, and a job they could focus on without fear of being misused or disregarded by units that didn’t understand their mission. Additionally, replacing ACIC (at least in name) with yet another multi-intelligence discipline command under INSCOM appears redundant.

These are not arbitrary things. ACI agents within ACIC have shown significant improvements in job satisfaction alone since the command stood up, while ACIC itself can trace its lineage directly back to 13 August 1917 with the creation of the CIP – A history that many agents are proud of, especially now with the re-consolidation of the CI mission within ACIC. Not taking these factors into account when proposing a CI/HUMINT merger, or creating a “1IC” that obscures ACIC (and may eventually also decrement it as other similar efforts once did), introduces unnecessary risk during a time period where ACIC is now gaining ground in imposing cost on our adversaries.

The disciplines of CI and HUMINT are fundamentally distinct. Each requires specialized training, authorities, and professional frameworks that enable personnel to operate effectively within complex operational environments. Over the past several years, the establishment of ACIC has strengthened the Army’s ability to conduct CI investigations and operations. However, continued progress in this area depends on maintaining a clear and aggressive focus, an established CI organizational identity, and preservation of the specialized expertise developed within the ACI workforce. While organizational reforms are sometimes necessary to address evolving operational requirements, proposals to merge CI and HUMINT or fundamentally restructuring their command relationships should be evaluated carefully. In addition, preserving specialized capabilities, maintaining effective partnerships with other federal agencies, and sustaining professionalization within the ACI Enterprise remain essential to protecting U.S. NATSEC interests and the U.S. Army from emerging threats.

Despite these realities, there are still problems with ACI “agents at rest” outside of ACIC, CI support to ECB, and advancing the specialization and professionalization of ACI to meet the demands of an increasingly challenging threat landscape (such as how to counter advanced technical collection capabilities of our adversaries). To address these without diminishing existing capabilities or progress made by ACIC, and without requiring more ACI agents in the U.S. Army, there are several potential effective solutions. While all of these solutions require a removal of ACI Special Agents at ECB, they still provide CI support via other means (either directly or indirectly by ACIC or 1IC).

As previously established, it does not appear that ACI agents belong in units at ECB organically, as this only results in an ineffective CI program while not contributing to the larger CI mission. Likewise, commanders should not be expected to understand how to best utilize ACI Special Agents, as they have other concerns to focus on, especially in combat theaters. Providing CI support via a centralized CI-focused organization such as ACIC, utilizing a combination of delegating certain CI activities and attaching actual agents as necessary, would alleviate the responsibility of agent utilization on commanders, along with some of the pressures of trying to understand what they need to do from a CI-perspective, thereby allowing them to focus on their mission.

One of the factors not discussed in this paper is the use of ACI agents within the Army National Guard and Army Reserves (compos 2 and 3). While this is also beyond the scope of this paper, if one of the recommended courses of action presented here is implemented, it would likely require further CI transformation in those components which could include removal of Army National Guard ACI billets permanently or transferred to the Army Reserves. This is due to many of the same issues with ACI agents at ECB also applying here, in addition to part-time ACI agents within the guard having no authorities to conduct CI activities (even under MOU) unless they are federalized to Title 10 service (National Guard typically fall under Title 32 where no CI authorities exist). However, within the Reserves, additional CI transformation could also include consolidating all the ACI agent billets into a brigade or group, commanded by an ACI agent in the O6 pay grade, under the MI Readiness Command (MIRC), that is patch-to-patch aligned with ACIC.

The author and contributors recommend the following potential courses of action that could all be effective in addressing the previously described issues (in order of preference):

Preserve specialization and strengthen ACIC through force structure realignment and centralized CI management.

Convert Army HUMINT to a hybrid CI/HUMINT tactical collector to serve primarily at ECB preserving a dedicated CI investigative force under ACIC.

Retain current structural changes under a broader intelligence command while attempting to preserve CI specialization within a subordinate framework.

Braden "Brad" Stockham has almost 27 years of experience in the U.S. Army between the National Guard, Reserves, and on numerous federal missions and combat deployments while attached to active-duty units. 16 of those years were as an ACI Special Agent where Brad has served in tactical, operational, and strategic assignments to include Field Office agent, Operations Management Teams, CI staff positions, CI Operations Officer, Deputy G-2X, Special Agent in Charge (SAC), Assistant SAC (ASAC), and as an agent with Special Operations Forces. Prior to becoming an agent, Brad served as an enlisted soldier as both a 19K – Armor Crewman, and later 11B – Infantryman. On the civilian-side while serving as a reservist, Brad accumulated almost 15 years of experience as a civilian law enforcement officer and detective at two different agencies. Currently, Brad still serves in the Army Reserves as a CI Warrant Officer while simultaneously being a MICECP civilian agent, where he is currently assigned to the FBI Austin Joint Terrorism Task Force under Region II, ACIC. Brad has attended numerous advanced CI and LE schools and also holds a Master of Science in Forensic Science.

Roy D. Christensen Jr. has more than 35 years of experience in the U.S. Army, Army Reserves, and as a MICECP employee. His more than 31 years of ACI (Active and MICECP) knowledge, skills, and abilities were developed from advanced CI training and extensive experiences in EUCOM (Strategic Operations & Deployments), AFRICOM (Staff Management, Strategic Operations), CENTCOM (Deployments), NORTHCOM (Strategic Operations), and NATO Allied Command Operations (Strategic Operations, Deployments, and Staff Management). These assignments allowed for opportunities to serve as a Special Agent, Liaison Officer, and Operations Officer, 66th MIB; Supervisory Special Agent and SAC, MI Detachment, 66th MIB and 902d MIG; Region Operations Officer, 650th MIG; ASCC Senior Civilian Advisor and Deputy Chief G-2X, USARAF; Senior Civilian Advisor, 650th MIG and 207th MIB; Acting Director of Operations 650th MIG; Deputy Director, Joint CI Unit-Iraq; Chief and Deputy, Military Liaison Office Rome; Strategic CI Operations, USA Foreign CI Activity; Team Leader, Operations NCO, Special Agent, 66th MIB and 650th MIG. Roy was the architect of the 207th MIB portion of the highly successful ACI X5 CI Transformation Pilot and currently serves as the GG-15 MICECP Senior Civilian Agent, 207th MIB, Vicenza, Italy.

LTC Kevin Halleran has served in the U.S. Army Reserves for over 20 years since enlisting in 2003. Commissioned as an MI Officer, he specializes in CI and HUMINT and has been actively involved in both CI reform, and now CI transformation efforts, providing feedback and authoring papers that have informed on both. LTC Halleran’s career has spanned numerous assignments, including command and staff roles. He has significant operational experience from deployments to Afghanistan and Kuwait, and he previously served as the CI Coordinating Authority for the NORTCOM JFLCC COVID response. Currently, he serves as the CI/HUMINT Division Chief for the U.S. Army Reserve Command (USARC). In his civilian capacity, LTC Halleran is an Enterprise Architect with Ernst and Young, specializing in Data Architecture and Engineering. He holds a Master of Science in Cybersecurity and is currently enrolled in the U.S. Army War College.

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