- Internationally recognized expert on Terrorist Financing with client banks ranging from small (Regions Bank, Ally Bank) to multi-national (J.P. Morgan Chase, Bank of America, Goldman Sachs, Merrill Lynch)
- As the FBI's Chief of Terrorist Financing Operations Section, conceived of and directed the initiative that identified the funding of the 9/11 attacks
- Provides topical insights to Congressional committees and to media outlets including: The Wall Street Journal, CNBC, and CBS
- Expertise in delivering investigative intelligence, risk advisory consultations, litigation support services, compliance risk and assessment, and educational seminars and training
- All 7 Best Practices
- Pre-Call Discovery Process
- One-on-One Call with Expert
- Session Summary Report
- Post-Session Engagement
Counter-Terrorist Financing - Compliance Program
Terrorist financing is the raising and processing of funds to support terrorism.
It is closely related to money laundering: Both are crimes that obscure financial assets for criminal purposes. Both have proliferated to the extent that the government requires preventive measures and strict regulatory compliance not only from financial institutions, but even non-financial entities like casinos, real estate dealers, lawyers and accountants.
There is an important distinction between money laundering and terrorism financing:
- The intent of money laundering is to make "dirty money" legitimate. Criminals use the financial system to hide the source of funds gained from illegal activities such as drug trafficking, bribery, extortion, embezzlement and theft.
- Terrorist financing involves both legitimate and illegitimate funds: It takes "clean money" and directs it to illegitimate purposes, supporting terrorism. It also takes "dirty money" from criminal activity that terrorists engage in and cleans it to support their mission.
Terrorist and transnational criminal organizations rely on money channeled through financial institutions because they need immediate and continuous access to funds in order to succeed; they must have the ability to raise, move, store and spend money.
Usually, funds for supporting terrorism are directed first to what appear to be legitimate activities. Often, it is channeled through charities or front companies. But it can be any form of institution. As seemingly legitimate funding sources have dried up, terrorists are engaging more in criminal activity as a funding mechanism. Terrorists typically rely on financial facilitation tools to move money. This includes the use of shell companies, wire transfers, correspondent accounts, payable through accounts, bulk cash shipment or smuggling, illegal money remitters, money laundering and trade-based money laundering.
Those who finance terrorism succeed by exploiting vulnerabilities in financial systems, differences in sovereign laws and the inability of weak nation states to impede the flow of money to criminals and terrorists. They manipulate assets in ways that undermine the integrity and stability of financial systems and institutions. Furthermore, they divert financial flows away from legitimate investments and otherwise productive use.
Worst, of course, is that when financiers of terrorism succeed, acts are carried out that kill or injure innocent people and have destructive consequences for societies and whole economies.
Disrupting the financial streams of terrorist and transnational criminal organizations diminishes their ability to carry out such acts. And it is critical for maintaining the integrity of any financial system.
The Best Practices included here will help financial institutions understand their responsibilities in identifying and reporting on suspicious activities. They will help institutions and others who must comply with the Bank Secrecy Act take steps to ensure compliance and protect themselves from potential penalties and reputational damage. In so doing, they will also play an important role in preventing terrorism.