Some argue that the Smith-Mundt Act, adopted in 1948, explicitly forbids information and psychological operations aimed at the US public. However, Emma L. Briant points out that this is a common confusion: the Smith-Mundt Act only ever applied to the State Department, not the Department of Defense and military PSYOP, which are governed by Article 10 of the US Code. Nevertheless, the current easy access to news and information from around the globe, makes it difficult to guarantee PSYOP programs do not reach the US public. Or, in the words of Army Col. James A. Treadwell, who commanded the U.S. military psyops unit in Iraq in 2003, in "The Washington Post":