Posts Tagged ‘CFT’

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Gaps found in Malaysia’s terror finance policies

September 22, 2015

Malaysia has made progress in countering the financing of terrorism, but still has a long way to go according to a new report from the international financial watchdog FATF. Shortcomings include a derth of prosecutions, a failure to identify specific offenses under Malaysian law such as fundraising for terrorist causes, and extreme slowness in enforcing sanctions against UN-designated terrorists. From FATF’s “Mutual Evaluation Report” (h/t El Grillo):

Malaysia has undertaken over 40 TF investigations of which 22 are ongoing, however no prosecutions have been taken forward. Malaysia successfully uses other criminal justice and administrative measures to disrupt terrorist and TF activities when a prosecution for TF is not practicable. These include various domestic terrorist plots, terror groups and foreign terrorists. Malaysia also uses these other measures to address the most relevant emerging TF risk – individuals travelling to conflict zones to participate in or advocate terrorist activity. Malaysian authorities identify and investigate different types of TF in each counter-terrorism investigation, and counter-terrorism strategies have successfully enabled Malaysia to identify and designate terrorists, terrorist organisations and terrorist support networks. In the absence of TF prosecutions, Malaysia has not demonstrated that it has sanctioned different types of TF offences, such as the collection of funds for TF, or the financing of terrorist acts or individual terrorists.

Malaysia demonstrates many of the characteristics of an effective system for targeted financial sanctions (TFS). A key area of effectiveness is in the direct implementation of TFS against UN designated persons and entities. Malaysia has also domestically listed individuals and entities pursuant to UNSCR 1373 representing a range of domestic and international terror threats. Many of the elements of the legal system and processes for implementing TFS related to UNSCRs represent a best practice for other countries. Effectiveness of TFS is supported by supervision of the FI and some DNFBP sectors, outreach and awareness raising, and government agencies checking their own databases. In absolute terms the amounts frozen under TFS are relatively small, reflecting to some extent the cash economy nature of TF in the SE Asian region and the detention of a number of Malaysian designees. Recently more freezing actions have taken place outside of the banking sector and covering property indirectly owned or controlled by designated entities.

Malaysia’s approach to preventive measures, oversight and outreach to the NPO sector has improved significantly in recent years and demonstrates many of the characteristics of an effective system. Outputs reflect targeted approaches to TF risk mitigation, with outcomes achieved to a large extent. This includes RoS and other regulators as well as the RMP.

Despite good inter-agency cooperation on PF (policy and operational), Malaysia’s technical gaps in relation to R7 are significant and major improvements are required to make the process more effective. The long delays in transposing designations made by the UN into Malaysian law undermine effectiveness. RIs have increasingly good awareness of obligations, particularly in Labuan and the major FIs. Supervision of obligations is taking place, but implementation could be deepened and further supported with additional guidance. Two Malaysian banks have frozen over USD29 million of assets related to the one Labuan domiciled Iranian bank designated under UNSCR 1737. No entities or assets related to UNSCR 1718 have been detected. Vigilance measures adopted by Malaysia add to effectiveness.

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Terror money news: suggested reading

March 5, 2015
  • France arrests 6 Chechens for raising funds and recruiting jihadists… more>>
  • Only military force, not conventional counter-terror finance techniques, can bankrupt ISIS… more>>
  • Saudi Arabia is building a neo-Maginot Line to defend against the same jihadist forces that they bankrolledmore>>
  • Hamas is doubling its stockpile of missiles and rockets for no reason in particular… more>>
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10 red flags over Dahabshiil

February 28, 2015

Does the international remittance company Dahabshiil finance terrorism? Are its anti-money laundering and counter-terror finance programs adequate? Here are 10 warning signs to keep in mind:

  1. Mohammed Sulaymon Barre, a Somali citizen and former Guantanamo Bay detainee, was alleged by U.S. officials to have worked in Osama bin Laden’s compound in Sudan in 1994 and 1995. He later worked at a Dahabshiil office in Pakistan before his detention. During a 2005 hearing at Guantanamo, a military judge told Barre, “I am convinced that your branch of the Dahabshiil company was used to transfer money for terrorism.” (Source: Washington Post).
  2. In early 2011, Somali music star and future member of Somalia’s parliament, Saado Ali Warsame, released a protest song entitled, “Dhiigshiil ha dhigan” (which translates as “Don’t Deposit with Dahabshiil” or “Don’t send your money through Dahabshiil”). The song called Dahabshiil a “blood-smelter,” “the enemy of Somalia,” and implored Somalis: “do not deposit your money” with Dahabshiil. (Source: Money Jihad)
  3. In late 2011, the Bell Pottinger public relations and lobbying firm cited its success in “manipulating Google rankings” on behalf of its client Dahabshiil to ensure that the Guantanamo Bay detainee story about Mohammed Sulaymon Barre didn’t appear on the first 10 pages of Google search results. (Source: The Independent)
  4. Amina Farah Ali and Hawo Mohamed Hassan were convicted in October 2011 on federal charges of providing material support to the terrorist group al-Shabaab. The indictment had alleged that “Ali and others acting at her direction transmitted funds to al-Shabaab through the hawala money remittance system” using Dahabshiil and other remitters. (Source: U.S. v. Amina Farah Ali)
  5. In December 2011, Minneapolis-based Franklin Bank and St. Paul-based Sunrise Community Banks ceased doing business with Somali hawala dealers and money transfer organizations including Dahabshiil over “concerns that the accounts put them at risk of violating federal rules designed to halt terror financing.” (Source: Minneapolis Star Tribune).
  6. The British banking giant Barclays announced its intentions to sever ties with Dahabshiil in 2013 over regulatory compliance and terror financing concerns. (Source: Associated Press.) Litigation ensued which delayed Barclays’s plans, but a deal to end their business relationship was finally reached in April 2014. (Source: Financial Times)
  7. In April 2014, U.S. Bancorp backed out of a long-planned deal with Dahabshiil after “an independent review of Dahabshiil and the inherent risk of doing business in Somalia.” (Source: American Banker)
  8. Danish regulators found Dahabshiil offices in Copenhagen, Kolding, Aalborg, and Aarhus to be “completely inadequate” in their compliance with anti-money laundering and terrorist financing laws in Denmark, and referred the case to police for further investigation in July 2014. (Source: Danish Financial Supervisory Authority)
  9. Somali news outlets reported in July 2014 that several Dahabshiil offices in Middle and Lower Juba were ordered by al-Shabaab to be closed after failing to make payments to al-Shabaab on time. (Sources: Radio Kulmiye, Shiniile News, and Dayniile)
  10. Merchants Bank of California announced this month that it is ending its Somali remittance services including Dahabshiil accounts amidst “concerns that some money could be making its way to Islamic militants.” (Source: KARE 11)

Dahabshiil denies all allegations of financing terrorism.

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New moves afoot to choke off terror money

November 7, 2014
  • The U.S. takes aim at ISIS’s black market oil buyers… more>>
  • Britain grants more powers to its charity regulator, including the power to remove dubious trustees from charitable boards (h/t @ConorMLarkin)… more>>
  • Austrian law will ban foreign funding of imams… more>>
  • The U.S. Rewards for Justice program of paying informants is still helping catch and kill terrorists… more>>
  • Bulk cash smugglers beware–there’s a new system to detect the presence of excessive currency at border checkpoints… more>>
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Terror funding news: recommended reading

March 6, 2014

Thanks to Gisele, Sal, El Grillo and all those who sent in tips.

  • Turkey has become a principal financial hub for terrorists under the leadership of Prime Minister Recep Tayyip Erdogan,” writes Adam Kredo… more>>
  • Cultural property like art and antiquities are susceptible to exploitation in money laundering and terror finance schemes, but federal law doesn’t quite make the connection. Rick St. Hilaire explains… more>>
  • British sanctions target Pakistani jihad financiers and millionaire terrorist Dawood Ibrahimmore>>
  • Ten thousand dollars in farm subsidies have gone to a terror funding co-conspirator that grows no crops… more>>
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Illicit transfer news: recommended reading

February 20, 2014
  • Palestinian Islamic Jihad “receives between $100-$150 million dollars annually from Iran,” says an Iranian expert… more>>
  • FinCEN shuts down a Michigan-based hawala dealer who sent 8,000 wires to Yemen and never checked a single customer’s ID… more>>
  • We don’t know how much money is financing terrorism, and we don’t know how much it costs to combat its financing either, so how do we know if what we’re doing is working?  More>>
  • A New Jersey company illegally shipped $70,000 worth of protective gloves to Iranmore>>
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What’s really behind the Saudi rewards program

February 16, 2014

Saudi Arabia says it will offer rewards to people within the kingdom who provide evidence about terrorist financing that leads to a conviction (hat tip to El Grillo).

It has been rumored that the maneuver is designed to reign in Saudi-backed elements among the Syrian rebels whom Saudi Arabia can no longer control.

Money Jihad suspects that the initiative, which resembles the U.S. Rewards for Justice program, is a Saudi smokescreen designed to placate Western diplomats, U.S. Treasury officials, and international financial watchdog FATF.

Unfortunately, this wouldn’t be the first instance of Saudi deception about a counter-terror finance initiative.

In 2008, Saudi Arabia announced that its central bank, SAMA, would review charitable contributions from Saudi Arabia overseas (which are rife with donations to terrorist causes), but meaningful oversight has never occurred.  Saudi public statements about the SAMA program have been documented to be false.

In 2010, Saudi Arabia’s ulema council issued a ruling against terrorism, but the very same ruling defended zakat, which has often been used by wealthy Saudis to finance terrorist causes.  Saudi pronouncements against terrorism have often focused on protecting its own oil and gas infrastructure, and have pointedly excluded suicide bombers in Israel or Iraq from its definition of terrorism.

In 2014 we are told that Saudi Arabia will pay rewards to those who provide information about terror finance.  If this is actually enforced, Money Jihad predicts that it will be used against Shia dissidents, particularly in its oil rich, Shia-dominant Eastern Province (see related commentary by Amy Myers Jaffe here), or against those who transfer money to Shias in Bahrain or Syria.

It will not be used to curtail Saudi money flowing to Somalia, Bangladesh, Chechnya, or any of the other countries where Saudi Arabia has strategic interests.