suspicions that he had been involved in the 2004 Madrid train bombings. Background The Patriot Act made a number of changes to U.S. law. Key acts changed were the Foreign Intelligence Surveillance Act of 1978 (FISA), the Electronic Communications Privacy Act of 1986 (ECPA), the Money Laundering Control Act of 1986 and Bank Secrecy Act (BSA), as well as the Immigration and Nationality Act. Title II of the Patriot Act made a number of significant changes to the laws relating to foreign intelligence surveillance, of which the main two Acts that were affected were FISA and the ECPA. FISA came about after the Watergate scandal and subsequent investigations by the Church Committee, which discovered and criticized abuses of domestic spying by the National Security Agency (NSA), Federal Bureau of Investigation (FBI) and Central Intelligence Agency (CIA). This led to widespread congressional and public outcry, resulting in Congress passing FISA in 1978. FISA governs the way in which U.S. intelligence agencies may conduct wiretaps and the interception of communications in order to gather foreign intelligence. FISA established the Foreign Intelligence Surveillance Court (FISC) and a FISC Court of Review which administer foreign intelligence related applications for access to business records, wiretaps, microphone "bugging," physical searches and the use of pen registers and trap and trace devices. The Act does not apply to U.S. citizens, but is limited to dealings with foreign powers and nationals. The ECPA was an amendment to Title III of the Omnibus Crime Control and Safe Streets Act of 1968, which is sometimes known as the "Wiretap Statute." The Wiretap Statute was mainly the result of two Supreme Court cases — Katz v. United States and Berger v. New York — and from criticism by the Church Committee of the actions of COINTELPRO (Counter Intelligence Program). The Supreme Court found in both Katz v. U.S. and Berger v. New York that Fourth Amendment search and seizure protections prohibited warrantless wiretaps. COINTELPRO was a program of the FBI that was aimed at investigating and disrupting dissident political organizations within the United States. COINTELPRO's operations during 1956 to 1971 were broadly targeted against organizations that were (at the time) considered to have politically radical elements. These included those whose stated goal was the violent overthrow of the U.S. government (such as the Weathermen), non-violent civil rights groups such as Martin Luther King Jr.'s Southern Christian Leadership Conference and violent groups