A classified CIA document released under a Freedom of Information Act request gives the agency's Director of Central Intelligence (DCI) the right to "approve, modify, or disapprove all proposals pertaining to human subject research." At the same time, the "Law and Policy Governing the Conduct of Intelligence Agencies" provided to the outlet by the American Civil Liberties Union (ACLU) requires the research subject's "informed consent."
The Guardian cites several medical experts arguing that the CIA's internal limits on human research may have been violated by the post-September 11, 2001, program of extraordinary renditions, detentions and interrogations.
"There is a disconnect between the requirement of this regulation and the conduct of the interrogation program. They do not represent consistent policy," the head of the Federation of American Scientists Project on Government Secrecy, Steven Aftergood, told the publication.
"If they were abiding by this policy when EIT [enhanced interrogation techniques] came up, they wouldn’t have been allowed to do it," Raymond told the outlet.
He further argues that "anyone in good faith" could see that the program conducts human subject research.
Human subject research is one of many potential violations in the CIA's so-called anti-terror program, which also included intentional harm on detainees and failing to document evidence of torture.