- Frank A. S. Campbell, Founder and CEO of Highland Strategies and Highland Screening Resources
Frank A. S. Campbell is the Founder and Chief Executive Officer of Highland Strategies, LLC and Highland Screening Resources. Frank's professional career covers a broad range of public policy and legal experience, including 14 years in the federal government and 14 years in private law practice. His background ranges from developing high-level government and legal policy at the United States Department of Justice (DOJ), to providing general counsel advice to the Director of the Federal Bureau of Investigation (FBI), to white collar defense and civil litigation in an AV Rated, Washington, D.C.-based law practice.
Frank served for nearly a decade (1999-2008) as a Deputy Assistant Attorney General and Senior Counsel in the DOJ Office of Legal Policy during both the Clinton and Bush Administrations. He began his government service in 1994 as an Assistant General Counsel for the FBI. Throughout his government service, Frank played a key role in developing policy initiatives and programs relating to background screening and risk assessments, identity management using biometrics, counterterrorism and information sharing, and the development and use of enhanced forensic technologies by law enforcement. He appeared before congressional committees as the DOJ expert on the subject of background checks. He also was one of DOJ's key advisors on issues relating to firearms and explosives regulation and enforcement.
Gun Buyer Background Checks
Frank is regarded as the one of the key architects of the National Instant Check System (NICS), the background check system for gun buyers established by the Attorney General and implemented by the FBI under the 1993 Brady Handgun Violence Prevention Act. He helped guide the NICS through legal and policy challenges in the politically sensitive field of firearm regulation to its success as a national background check program. In the sixteen years since it began serving federally licensed gun dealers in 1998, the NICS has processed more than 200 million background checks and prevented over 2 million transfers of firearms to persons prohibited by law from receiving a gun. The system also met the requirement of doing the checks quickly - ninety-one percent of NICS checks are completed while the gun dealer is still on the phone.
Frank was one of the original designers of the NICS, wrote the privacy and security regulations governing the information in the system, and developed the protocols for handling NICS checks that hit on records in the terrorist watch list. Frank wrote the DOJ testimony explaining to Congress how the NICS works and the continuing need to improve the state records upon which the system relies, delivered at a hearing held shortly after the Virginia Tech tragedy. Frank also spearheaded the Department's initial efforts to implement the NICS Improvement Act, a law passed in the wake of the Virginia Tech tragedy that aims to improve the completeness of automated information needed by the NICS to successfully keep guns out of the hands of prohibited persons, including individuals with disqualifying mental health adjudications or commitments.
Criminal History Background Checks
Frank also provided legal and policy guidance on the security, privacy, and dissemination of information in the FBI's national criminal history record system. He authored the Attorney General's Report on Criminal History Background Checks, a comprehensive review of the legal and policy issues in this area. The report makes detailed recommendations to Congress for changes in the law to make FBI criminal history data more broadly available to private sector employers and in a way that harmonizes with the privacy and fair information practice requirements of the Fair Credit Reporting Act and applicable equal employment opportunity laws and regulations. The report also made recommendations for improving the completeness of records in the national criminal history system, some of which are reflected in the NICS Improvements Act. Required by the Intelligence Reform and Terrorism Prevention Act of 2004 (IRTPA), the report was submitted to Congress in June 2006 and has been the subject of a congressional hearing on the need for efficiency and accuracy in background checks, at which Frank was the DOJ witness. The report's recommendations were endorsed by the President's National Infrastructure Advisory Council in its April 2008 Report to the President on the Insider Threat to Critical Infrastructures. Based on the report, Frank developed the DOJ position on proposed amendments to the National Child Protection Act that seek to establish a national background check system for providers of care to children.
Frank also wrote the regulations implementing the Private Security Officer Employment Authorization Act of 2004, a law that was enacted as part of IRTPA and authorized states to conduct national fingerprint background checks on applicants for private security guard employment. Frank testified before Congress as the DOJ witness at a hearing on the implementation of that law.
National Crime Prevention and Privacy Compact
Frank served for seven years as the principal DOJ advisor to the Compact Council, a body of state and federal officials appointed by the Attorney General to govern the implementation of the National Crime Prevention and Privacy Compact. The interstate Compact was adopted by Congress in 1998 and now has 28 state members. Frank helped guide the Council in carrying out its role of developing policies and establishing rules relating to the interstate exchange of criminal history data in the FBI national system for non-criminal justice purposes, such as background checks for employment and licensing. Frank worked with the Council in developing its key rule authorizing and establishing standards for the outsourcing to vendors of administrative functions in support of background checks.
In the area of counterterrorism, Campbell drafted the Prevention of Terrorist Access to Destructive Weapons Act of 2004 (enacted as part of IRTPA), a law that substantially increased the penalties for private possession of MANPADS (shoulder-fired missiles intended to destroy aircraft) and other weapons of mass destruction, including atomic weapons, dirty bombs, and variola virus. He also drafted the proposed bill to allow the Attorney General the discretion to deny firearms transfers and firearms and explosives licenses or permits to dangerous terrorists which has been introduced in each Congress since it was sent as a proposal to the Hill in 2008 by the Bush Administration.
Information Sharing and Intelligence Systems
Frank led the effort to develop the Attorney General's implementation guidelines for the information sharing provisions of the USA PATRIOT Act, including guidelines for the sharing with the intelligence community and homeland security officials of foreign intelligence acquired in the course of criminal investigations. Frank authored the July 2008 proposed revision of the DOJ privacy and civil liberty guidelines and regulations governing federally-funded state criminal intelligence systems to bring them in line with the new, post-9/11 information sharing environment and investigative policies aimed at preventing terrorism. He also provided legal and policy advice on DOJ's joint effort with the Department of Homeland Security (DHS) on the interoperability of each department's fingerprint identification system so that criminal justice and immigration information can be shared between DOJ, DHS, the State Department, and other appropriate government agencies.
Advanced Identification, Biometric, and Forensic Technologies
Frank spearheaded the initiative by several federal departments, including DOJ, DHS, State, and DOD, that led to the R&D grants by the National Institute of Justice (NIJ) and DHS for the development of a fingerprint fast-capture device for use in government identity enrollment and background screening applications. He assisted in efforts to define government-wide approaches to using biometrics to enhance identification in law enforcement and national security applications, including participating in the development of the joint National Security and Homeland Security Presidential Directives (NSPD-59/HSPD-24) titled, "Biometrics for Identification and Screening to Enhance National Security."
Frank worked on legislation, regulations, and research and grant initiatives supporting the further development and expansion of the FBI Combined DNA Index System (CODIS), including the December 2008 DOJ rule requiring DNA-sample collection and biological evidence preservation in federal jurisdiction. He also led the DOJ effort to define the requirements for the NIJ-funded study by the National Research Council of the National Academy of Sciences that, based on the limitations of current technology, advised against creating a "national ballistics fingerprint system" (a national database of ballistics markings from all new and imported guns sold in the United States).
Firearms, Explosives, and Destructive Devices
Frank's responsibilities at DOJ also included general firearms and explosives regulation and enforcement issues. He played a key role in the integration of the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) into DOJ from the Treasury Department, as required by the Homeland Security Act of 2002. Frank drafted the Department's proposals, adopted by the U.S. Sentencing Commission, to increase the sentencing guidelines for offenses involving firearms trafficking or destructive devices. He assisted in establishing ATF's licensing program under the Safe Explosives Act. He also coordinated, in conjunction with the Nuclear Regulatory Commission, the development of the guidelines for allowing the use of automatic weapons and other regulated firearms by security guards at nuclear facilities.
Private Law Practice
Before his service in government, Frank practiced law for 14 years in Washington, D.C., engaging in a wide range of civil litigation and white collar defense work and receiving an AV Rating from Martindale-Hubbell. His white collar work involved the defense of public officials, including Members of the United States House of Representatives in federal criminal investigations and prosecutions and House ethics and disciplinary actions.
Frank received his B.A. from Lafayette College and his law degree from the George Washington University.