10 tips for businesses to avoid financing terrorNovember 24, 2014
If you run or work for a medium or small business that can’t afford to have an entire compliance department, or even a compliance officer, here are a few tips that will help your business reduce its risk of inadvertently funding a terrorist organization, running afoul of federal authorities, or both:
- Conduct due diligence before taking on new accounts, and do not rely exclusively on Internet searches for due diligence.
- For international accounts it is doubly important to carry out thorough due diligence (including overseas business partners, banks, security providers, and charities) before signing agreements with them. You will probably have to contract out for investigation services, but it’s worth the expense.
- If your business promotes or authorizes employee payroll deductions to make charitable contributions, review the list of participating charities. Do not offer payroll deductions for donations to charities suspected of financing terrorism or charities known to have worked with designated terrorists. This would include Islamic Relief USA and the Zakat Foundation (see here and here).
- If your business requires or offers diversity or equal opportunity training, do not make payments to any organization or person to conduct the training who has been implicated in terrorist financing schemes such as members of the Council on American-Islamic Relations or the Islamic Society of North America, both of which were unindicted co-conspirators in the Holy Land Foundation Hamas-financing case.
- Think twice before offering sharia-compliant investment accounts to employees or allowing a conventional retirement brokers to offer sharia funds to your employees. These financial products are less transparent with respect to fund management by sharia advisory boards whose members often share close ties with the international Muslim Brotherhood and are not subject to disclosure requirements on where they channel their profits.
- Do not buy corporate fruit baskets or other gift baskets from Edible Arrangements. Their CEO operates a foundation out of his office at Edible Arrangements allegedly linked to Pakistani front charities that fund Islamist militants.
- Do not have business lunches, meetings, or conferences catered by halal food providers such as IFANCA and Crescent Foods, which have been endorsed by or have catered events for entities that are suspected to have financed terrorism.
- If you are asked by an importer whether your business can ship to or “enter an Arab Port?” do not answer the question. That is code language used to ascertain your business’s willingness to participate in the Arab League’s boycott against Israel. Answering the question helps those who oppose the existence of Israel and will lead to fines by the U.S. Office of Antiboycott Compliance.
- Don’t let your data or your employees be held for ransom. Ask your IT department or technology provider about their security protocols against ransomware. Make adequate plans to protect your employees from abduction during overseas travel. Paying ransoms will serve to enrich criminal or terrorist groups which will be costlier and less secure for your industry in the long run.
- Bookmark and read blogs such as Money Jihad, Kenneth Rijock’s Financial Crime Blog, and Shariah Finance Watch for the latest threat trends in terror finance risk management. These websites are free unlike some of the other specialized news sites which are informative but fee-based.