Financing of terrorism

Terrorist activities take place in many different forms ranging from isolated acts to planned activities of organised groups. The forms of financing of terrorism therefore vary accordingly. It comprises not only the financing of the terrorist acts as such, but also any support to the criminal network. Terrorist organisations require significant funding, both for the actual undertaking of terrorist acts, but also to other issues: to maintain the functioning of the organisation, to provide for its basic technical necessities, as well as to cover costs related to spreading related ideologies.

The sources of terrorist funding vary. Firstly, they may originate from illegal activities, ranging from low-scale criminality to organised crime (e.g. trafficking in drugs, weapons or human beings). The origin of the funds might, however, also be legitimate, being provided for example by the members of the organisation (including newcomers) or obtained through the abuse of non-profit organisations. New funding techniques of terrorist organisations have been identified in recent years, including the use of virtual assets, exploitation of online platforms, and abuse of crowdfunding. In past conflicts, groups such as Da’esh relied on quasi-state methods of funding such as levying taxes or exploiting natural resources.

The funding of terrorist activities often requires funds to be moved within or across jurisdictions. This might be done through official channels of the financial market and money remittances, through unregulated channels or with the use of cash couriers. A clear similarity can be identified between terrorist financing and money laundering, as in both cases efforts are made to hide the funds from the scrutiny of state authorities. The techniques to do so are also often similar. The FATF broadened in 2001 its mandate and expanded the application of its Standards also to financing of terrorism. After initial consideration of counter-terrorist financing measures together with the AML measures, the FATF has increasingly focused on identifying the differences between the two phenomena, with the view of adapting its Standards to the particularities of terrorist financing (for example, based on the fact that not all terrorist financing sources are from illicit origin, such as the emphasis set on the abuse of NPOs).

The FATF Standards are based on several aspects. Primarily, they reiterate the requirements of international instruments concluded or issued in this area, requesting countries to adopt legislative measures which would ensure criminalisation of the offence of terrorist financing as a separate offence, covering all the elements as provided for by the Terrorist Financing Convention, as well as to put in place mechanisms to transpose the requirements of the UNSC resolutions issued in this respect (for further information on the UNSCRs adopted in this respect, please see the section Targeted financial sanctions). Further requirements are related to the application of preventive measures by the private sector, mirroring the measures established for the purpose of countering money laundering. Finally, particular requirements are formulated based on the specificities of terrorist financing, concretely the measures to be taken in respect of NPOs.

Overall, the initiatives of the international network have increased their focus on terrorism and related terrorist financing in recent years, including measures to address foreign terrorist fighters, abuse of virtual assets, and the use of new payment technologies. Further attention has also been given to measures adopted at the national level against the payment of ransoms.

MONEYVAL participates actively in the global activities against financing of terrorism. It undertakes evaluations of its Member States and territories with regard to the compliance of their implementation of the FATF Standards in this respect, as well as horizontal studies on particular issues to increase the understanding of the measures in place at national level and to identify potential difficulties in their implementation. It closely monitors measures put in place at national level against the payment of ransoms. It also participates in the global exercises initiated by the FATF on the overall assessment of the implementation of CFT measures by individual jurisdictions. In addition, MONEYVAL experts participate regularly in international conferences and workshops concerning combatting terrorism and terrorist financing.