The Federal Trade Commission (FTC) issued a unanimous ruling against Cambridge Analytica on Friday, saying the company engaged in “deceptive practices” by harvesting personal data from millions of Facebook users leading up to the 2016 election.

In its official opinion, approved by FTC commissioners in a 5-0 vote, the agency determined that Cambridge Analytica violated federal law by deceiving Facebook users about what data would be collected and how it would be used. The data was collected via an app built by the company to survey U.S.-based Facebook users.

The FTC ordered the company to stop making “misrepresentations” about how data is collected and said it needs to delete the personal data it gathered through the app.

FTC Commissioner Noah Phillips tweeted on Friday that “this enforcement action reflects our ongoing commitment to hold firms accountable to their privacy promises to American consumers.”

But the practical impact of the FTC’s order is unclear given that Cambridge Analytica closed its doors in 2018 shortly after filing for bankruptcy.

The New York Times and The Guardian first reported in early 2018 that Cambridge Analytica had mined the data of around 50 million Facebook users without their permission to build profiles to pinpoint voters, part of the firm’s role as consultants for President Trump’s 2016 campaign.

The data collection ended up becoming one of the largest data breaches of customer information in Facebook’s history.

Shortly after the story broke in 2018, Facebook CEO Mark Zuckerberg posted an update on his Facebook page listing steps the social media giant intended to take to ensure a similar incident did not occur again. Zuckerberg vowed that Facebook would “learn from this experience.”

Facebook settled with the FTC in July, and was ordered to pay $5 billion stemming from its failure to adequately protect user data. The company was then ordered to pay a separate $645,000 fine to the British government in October, also due to data privacy concerns stemming from the Cambridge Analytica incident.

The opinion and final order were issued as a result of an administrative complaint FTC staff filed about Cambridge Analytica in July, alleging the firm engaged in deceptive practices.

At the same time the complaint was filed, the FTC settled with former Cambridge Analytica CEO Alexander Nix and app developer Aleksandr Kogan for their involvement with the data mining. Nix and Kogan agreed to delete or destroy any personal data they acquired.

The FTC said Friday that Cambridge Analytica never responded to the complaint filed by FTC staff earlier this year.

Nix and other executives for Cambridge Analytica could not immediately be reached for comment.

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Speculation is rife concerning the possibility that President Donald Trump will replace Director of National Intelligence Dan Coats with Fred Fleitz, a former CIA analyst. According to these reports Fleitz’s mission will be to preside over the downsizing of the Office of the Director of National Intelligence (ODNI) and, if possible, its complete elimination. Let’s hope these reports are true.

The ODNI was created in the aftermath of the 9/11 attacks based on the enduring belief in Washington that all problems are solved by throwing money and people at them. We suffered a surprise attack on our soil because we did not have the human sources we needed inside Al Qaida. The Washington logic therefore was that the addition of layers of bureaucracy, the building of new office buildings and the awarding of hundreds of millions of dollars in contracts for computers, desks, meeting rooms and flat screen tv’s would solve the problem.

The ODNI has added nothing but process, expense and confusion to a giant bureaucracy already suffering heavily from all three. It needs to go away now. And then we need to get to the real work at hand: reforming the Central Intelligence Agency (CIA), or perhaps more accurately, getting it back to its roots.

Bureaucrats believe that all problems can be solved by adding a few lines to a wiring diagram and spending more money. We have seen this approach in CIA since 9/11 — in spades. One Director after another — none with any real field operational experience, including the current one — has shuffled desks, changed the names of headquarters components and indulged the belief that the best way to catch terrorists is with PowerPoint presentations. The results are manifest. It took us ten years to find Bin Laden. Baghdadi is still on the run.

I have heard it said within CIA that the best way to stop the next terror attack on the United States would be to convince our enemies to adopt our bureaucratic procedures.

Truth be told, if Osama Bin Laden had been forced to contend with anything like the process our system generates, he would likely still be attempting to get approval for the 9/11 attacks.

What we need in CIA is the simplest, flattest structure possible, with authority and capability delegated to the lowest possible level. The road we have been on since 9/11, one which requires ever greater degrees of coordination, hesitation and deliberation prior to the initiation of any significant action must be reversed. We do not need more meetings, discussion or complexity.

We need good plans. We need approval to move. We need to get out the door.

Windows of opportunity open. They also close.

We also need to clear the playing field. Since 9/11 everybody in Washington has decided they have a mandate to play in the field of human intelligence. First and foremost, the Department of Defense — never a friend of CIA — has stumbled onto the playing field and trained vast numbers of individuals to function as the equivalent of CIA case officers. Most of these people are good, patriotic Americans trying to make a difference. Only a precious few have anything like the skills necessary for success in the world of espionage. The bulk of them never come anywhere near recruiting quality sources of significant value. They do, however, suck up resources and crowd the operational environment.

If you are involved in the conduct of human intelligence operations at the strategic level, you should work for the CIA, as was the clear intent when the organization was created in 1947. If you don’t work for CIA, you should get out of the way.

One would presume that a Department of Defense already fighting multiple wars and tasked to prepare for possible conflicts with Iran, Russia and China would have plenty to occupy its time.

Within CIA we must restore the focus on speed, agility and audacity. We must take it back, if not organizationally, then spiritually, to the ethos of the Office of Strategic Services (OSS), CIA’s World War II predecessor. Richard Harris, who wrote one of the best histories of the OSS, had this to say about the state of CIA (and his comments remain spot on to this day):

“OSS was more than a little wacky. But underlying the wackiness was a sustaining ‘spirit’ that had already begun to disappear in the 1960’s when I served my federal peonage emptying classified wastebaskets. Without that spirit, what is left is a CIA that suffers from organizational hardening of the arteries. Even the best of secret servants would be hampered by a pervasive culture of inertia, lack of imagination, smug self-satisfaction, and that infectious curse of the bureaucratic mandarin, the incessant need to CYA: Cover Your Ass.”

When General “Wild Bill” Donovan formed the OSS, he promised President Franklin D. Roosevelt an organization filled with men and women who were “calculatingly reckless,” demonstrated “disciplined daring” and were trained for “aggressive action.” Inside CIA, despite our best efforts to drive them out with mind numbing bureaucracy and process, there are thousands of such men and women today praying for the change that will set them free to do the work they know needs to be done.

PowerPoint presentations, memos and paperwork don’t stop terrorists, help you crawl inside the North Korean nuclear program or explain what the Iranian Revolutionary Guard Corps intends next. We need to put aside form and process and get back to basics.

Espionage is a tough business. We need an equally tough organization to carry it out.

Charles “Sam” Faddis is a retired CIA operations officer with decades of experience undercover abroad. He took the first CIA team into Iraq in advance of the 2003 invasion and retired in 2008 as head of the CIA counterterrorism unit tracking weapons of mass destruction. He is also a former U.S. Army officer and trial attorney. Faddis is currently a senior partner with Artemis, LLC and the senior editor for AND Magazine. He’s also the author of “Beyond Repair: The Decline and Fall of the CIA” and (with Mike Tucker) “Operation Hotel California: The Clandestine War Inside Iraq.”

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