Disrupting Terrorist Financing on Social Networks and Video Game Platforms – A Guide for Non-Traditional Financial Institutions and the Banks That Hold Their Accounts

Scott F. Butler

Transaction monitoring-based and geography-based counter-terrorist finance regimes are not adequate to protect 21st century financial companies from extremist exploitation. A new methodology is required by which non-traditional financial institutions can monitor for “small scale” terrorist finance transactions and guard against radicalization via their platforms. Specifically, this analysis applies to social networks with a money transmission component (like Facebook or Snap) and video game companies that allow their users to interact and transact within virtual environments (Riot Games, Blizzard). Those entities are referred to as “social-financial companies.”

There are myriad ways to prevent known extremists from holding accounts at banks, money transmitters and other legacy financial institutions. That class of companies has also received adequate guidance about how to monitor for terrorist financing transactions. However, those efforts will need to be reconsidered for the new social-financial landscape.

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