15 Years of Anti-Terrorist Financing: Why One Size Does Not Fit All

Author: Jochen Best, CAMS-Audit

Almost 15 years after the terrorist attacks on September 11, 2001, and the implementation of countless United Nations Resolutions, international standards from government and private organizations as well as national legislation anti-money laundering/anti-terrorist financing (AML/ATF) compliance professionals around the globe still struggle with successfully mitigating the risks posed to their financial institution or financial services providers. Screening watch and sanctions lists and freeze assets as a consequence was and probably never will be the silver bullet in the fight against sophisticated terrorist groups like the Iranian Qods Force or the Islamic State of Iraq and Syria (ISIS), since they are still very much in business despite the Financial Action Task Force’s (FATF) assessment in its 2008 report that state-sponsored terrorism is in the decline. In its most recent report, the FATF even confirmed the author’s view that the most common countermeasures are not suitable to undermine ISIS’ funding.

In order to strengthen an AML/ATF compliance regime, the author advocates to categorize terrorist groups into three distinct groups: (i) state sponsored, (ii) traditional and (iii) self-sufficient, since terrorist groups are not created equal and not all rely on Zakat as their primary source of funding. This categorization would open the opportunity to conduct a comprehensive risk assessment, which would subsequently lead to the development and implementation of suitable countermeasures for each specific category.

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