National Terrori

Financing Risk Asse

2015




National Terrorist Financing Risk Assessment 

TABLE OF CONTENTS 

EXECUTIVE SUMMARY .......................................................................................................................... 

INTRODUCTION ........................................................................................................................................ 

PARTICIPANTS ...................................................................................................................................... 5 

SOURCES ................................................................................................................................................ 6 

METHODOLOGY ................................................................................................................................... 8 

SECTION I: GLOBAL TERRORIST FINANCING THREAT ................................................................. 10 

A. OVERVIEW OF TERRORISM THREAT FACING THE UNITED STATES ......................... 1

B. GLOBAL SOURCES OF TERRORIST FINANCING .............................................................. 1

SECTION II: COUNTERING TERRORIST FINANCING ...................................................................... 1

A. LAW ENFORCEMENT EFFORTS ........................................................................................... 20 

B. FINANCIAL/REGULATORY EFFORTS ................................................................................. 22 

C. INTERNATIONAL ENGAGEMENT ....................................................................................... 23 

D. EXAMPLE OF SUCCESSFUL INTERAGENCY COORDINATION: RESPONSE TO THE 

ATTEMPTED TIMES SQUARE BOMBING ....................................................................................... 24 

SECTION III: TERRORIST FINANCING VULNERABILITIES AND RISKS IN THE UNITED 

STATES ...................................................................................................................................................... 25 

A. RAISING FUNDS: VULNERABILITIES AND RISKS ........................................................... 26 

B. MOVING AND PLACING FUNDS: VULNERABILITIES AND RISKS ............................... 46 

C. POTENTIAL EMERGING THREATS ...................................................................................... 56 

CONCLUSION ........................................................................................................................................... 59 
Executiv

Summar

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National Terrorist Financing Risk Assessment 

EXECUTIVE SUMMARY 

After the September 11, 2001 terrorist attacks, the United States adopted a preventive approach to 

combating all forms of terrorist activity. Efforts to combat the financing of terrorism (CFT) are a central 

pillar of this approach.1

 Cutting off financial support to terrorists and terrorist organizations is essential to 

disrupting their operations and preventing attacks. To that end, the U.S. government has sought to 

identify and disrupt ongoing terrorist financing (TF) and to prevent future TF. The law enforcement 

community, including various components of the U.S. Departments of Justice, Homeland Security, and 

the Treasury, along with the intelligence community and the federal functional regulators, applies robust 

authorities to identify, investigate, and combat specific TF threats, enforce compliance with applicable 

laws and regulations, and prosecute supporters in order to deter would-be terrorist financiers. The U.S. 

Department of the Treasury (Treasury), which leads financial and regulatory CFT efforts for the U.S. 

government, employs targeted financial sanctions, formulates systemic safeguards, and seeks to increase 

financial transparency to make accessing the U.S. financial system more difficult and risky for terrorists 

and their facilitators. All of these efforts involve extensive international engagement to try to prevent any 

form of TF, particularly financing that does not necessarily originate in the United States, from accessing 

the U.S. financial system. 

These efforts have succeeded in making it significantly more difficult for terrorists and their facilitators to 

access and abuse the regulated U.S. and international financial systems. At the time of the September 11, 

2001 attacks, Al-Qaida (AQ) was relying on both a web of wealthy supporters that practically operated in 

the open and a financial system that let money for terrorists flow with minimal scrutiny.2

 Operating such 

a financial network would be substantially more difficult today in the United States because of robust 

anti-money laundering (AML)/CFT standards. Additionally, several of the most significant sources of 

TF—such as the ability of terrorists to derive financial benefit through the control of territory—result 

from weak governance that the United States does not experience. 

However, the threat from terrorism and terrorist financing is constantly evolving and requires adaptation 

by law enforcement, financial regulators, intelligence services, and policy makers. When examined over 

time, several fundamental lessons emerge: first, a wide range of terrorist organizations have sought to 

draw upon the wealth and resources of the United States to finance their organizations and activities; 

second, just as there is no one type of terrorist, there is no one type of terrorist financier or facilitator; and 

third, terrorist financiers and facilitators are creative and will seek to exploit vulnerabilities in our society 

and financial system to further their unlawful aims.3

Thus, even with the safeguards described above, the U.S. financial system continues to face residual TF 

risk. The central role of the U.S. financial system within the international financial system and the sheer 

 

1 See White House, National Strategy for Counterterrorism, June 2011. Available at 

http://www.whitehouse.gov/sites/default/files/counterterrorism_strategy.pdf. 2 See National Commission on Terrorist Attacks upon the United States, Kean, T. H., & Hamilton, L. (2004). The 

9/11 Commission report: Final report of the National Commission on Terrorist Attacks upon the United States, 

p.169. Washington, D.C.: National Commission on Terrorist Attacks upon the United States. 

3 See Michael Taxay, United States Attorneys’ Bulletin, Vol. 62, No.5 (September 2014), “Terrorist Financing: 

Trends in the Prosecution of Terrorist Financing and Facilitation.” Available at 

http://www.justice.gov/usao/eousa/foia_reading_room/usab6205.pdf. 

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volume and diversity of international financial transactions that in some way pass through U.S. financial 

institutions expose the U.S. financial system to TF risks that other financial systems may not face. As 

Treasury Secretary Jacob Lew has observed, “The dollar is the world’s reserve currency and, for over 200 

years, we have established ourselves as the backbone of the global financial system.”4

 While U.S. 

counterterrorism (CT)/CFT efforts have resulted in better identification and faster action than prior to 

September 11, 2001, information obtained from financial institution reporting, TF-related prosecutions, 

and enforcement actions against financial institutions in the United States are powerful reminders of the 

TF risk that remains in the United States. 

As described in detail in Section III, multiple terrorist organizations and radicalized individuals seek to 

exploit several vulnerabilities in the United States and in the U.S. financial system to raise and move 

funds, that despite ongoing efforts by the U.S. government to mitigate, still pose a residual risk of TF. 

Terrorist financiers use various criminal schemes to raise funds in the United States, and they continue to 

attempt to exploit the generosity of American citizens. Although coordinated law enforcement and 

regulatory efforts by the U.S. government, working with charitable organizations, has improved the 

resiliency of the charitable sector to abuse by TF facilitators, the large size and diversity of the U.S. 

charitable sector and its global reach means the sector remains vulnerable to abuse. A notable trend 

identified in the charitable sector involves individuals supporting various terrorist groups seeking to raise 

funds in the United States under the auspices of charitable giving, but outside of any charitable 

organization recognized by the U.S. government. Additionally, the growth of online communication 

networks, including social media, has opened up new avenues for terrorists and their supporters to solicit 

directly, and receive funds from, U.S. residents. 

 

In terms of moving and placing funds, while the United States has reduced the ability of terrorist groups 

to use regulated financial institutions to move funds through the U.S. financial system through effective 

regulation, supervision, investigations and enforcement, some residual risks remain, due to correspondent 

banking relationships with foreign financial institutions and the acts of complicit money services business 

(MSB) employees in the United States. Unlicensed money transmitters may also be used to send funds 

abroad, and there are aggressive investigation, prosecution, and regulatory efforts underway to detect and 

disrupt such activity. 

Because other more effective funds transmission routes are disrupted, the use of cash smuggling to move 

funds across U.S. borders — while slower, less efficient, and more expensive than regulated or 

unregulated financial institutions — continues to be employed by a variety of terrorist groups. 

The U.S. government is also closely monitoring several emerging TF threats and vulnerabilities, 

including the use of cybercrime and identity theft schemes by terrorist groups and individuals to raise 

funds, as well as the use of new payment systems to move and place funds. 

 

4

 Jacob J. Lew, Secretary of the Treasury, “Lessons From a Crisis,” New York Times, October 20, 2013. 

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National Terrorist Financing Risk Assessment 

INTRODUCTION 

The National Terrorist Financing (TF) Risk Assessment identifies the TF risks that are of priority concern 

to the United States. The purpose of the National TF Risk Assessment is to identify and understand the 

TF threats and vulnerabilities in the United States, assess current efforts to combat these threats and 

vulnerabilities, and understand the remaining risk to the U.S. financial system and national security. 

 

The National TF Risk Assessment complements the 2015 National Money Laundering (ML) Risk 

Assessment in order to provide a similar depiction of the threat posed by TF. In particular, the 

assessment: 

 Examines methods used in TF-related federal prosecutions; 

 Draws from the work of the interagency Working Group on Combating Terrorist Financing, led 

by Treasury, which assesses threats, trends, and risks in the United States; and 

 Identifies priority residual TF risks. 

PARTICIPANTS 

The National TF Risk Assessment was drafted by Treasury’s Office of Terrorist Financing and Financial 

Crimes (TFFC). In preparing the National TF Risk Assessment, TFFC consulted with the following 

offices and agencies: 

 Department of the Treasury 

o Terrorism and Financing Intelligence (TFI) 

 Financial Crimes Enforcement Network (FinCEN) 

 Office of Foreign Assets Control (OFAC) 

 Office of Intelligence and Analysis (OIA) 

 Treasury Executive Office of Asset Forfeiture (TEOAF) 

o Internal Revenue Service (IRS) 

 Criminal Investigation (CI) 

 Tax Exempt & Government Entities Division (TE/GE) 

 Small Business/Self Employed Division (SB/SE) 

 Department of Justice (DOJ) 

o National Security Division (NSD) 

o Tax Division 

o Drug Enforcement Administration (DEA) 

o Federal Bureau of Investigation-Terrorist Financing Operations Section (FBI-TFOS) 

 Department of Homeland Security (DHS) 

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o Immigration and Customs Enforcement (ICE), Homeland Security Investigations (HSI) 

o Customs and Border Protection (CBP) 

o Office of Intelligence and Analysis 

 Department of State (DOS) 

o Bureau of Counterterrorism 

o Bureau of Economic and Business Affairs 

o Bureau of International Narcotics and Law Enforcement 

 National Counterterrorism Center (NCTC) 

 Staff of the Federal functional regulators (FFR)5

SOURCES 

The National TF Risk Assessment is compiled from agency-specific, interagency, and Congressional 

advisories; analysis, guidance, reports, speeches, and testimony published since 2001; new domestic 

research and analysis; and relevant international studies. A significant number of the findings that 

produced the National TF Risk Assessment were informed by intelligence reporting and analysis. 

Although these reports cannot be made public, the risk assessment has endeavored to capture strategic, 

declassified aspects in order to provide a comprehensive assessment. 

Public sector reports published since 2006, and referenced in footnotes throughout the National TF Risk 

Assessment, include: 

 Agency-specific reports: 

o United States Attorney’s Bulletin 

 Interagency studies and strategies: 

o Country Reports on Terrorism 

o 2011 National Strategy for Counterterrorism 

 Congressional reports & testimony: 

o Annual Congressional Threat Briefings by Departments of Justice and Homeland 

Security, Office of the Director of National Intelligence, and National Counterterrorism 

Center 

o 2014 Terrorist Assets Report 

 

5

 This includes staff of: the Commodity Futures Trading Commission (CFTC); Board of Governors of the Federal 

Reserve System (FRB); Federal Deposit Insurance Corporation (FDIC); National Credit Union Administration 

(NCUA); Office of the Comptroller of the Currency (OCC); and the Securities and Exchange Commission (SEC). 

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National Terrorist Financing Risk Assessment 

An analysis was conducted by the Department of the Treasury on terrorism and terrorism-related 

convictions between 2001 and 2014. Cases were flagged in which the defendant was charged with one or 

more of the below offenses: 

 Title 18 of the U.S. Code, Section 2339A, which prohibits the provision of material support or 

resources knowing or intending that they are to be used in committing certain predicate violations 

associated with terrorism. Material support has been broadly defined to be any property, tangible 

or intangible, or service, and is not limited to physical transfers of assets (e.g. via a loan or 

something of value). 

 Title 18 of the U.S. Code, Section 2339B, which prohibits knowingly providing material support 

or resources to an entity designated by the Secretary of State as a “foreign terrorist organization” 

(FTO), which currently includes 59 groups.6

 

 Title 18 of the U.S. Code, Section 2339C, which prohibits the unlawful and willful provision or 

collection of funds with the intention or knowledge they are to be used to carry out a terrorist 

attack. 

 Title 18 of the U.S. Code, Section 2339D, which prohibits persons from receiving military-type 

training from, or on behalf of, an FTO. Under an aiding or abetting theory, anyone who finances 

another in receiving such training would be liable as a principal. 

 Title 21 of the U.S. Code, Section 960a, which prohibits persons who have engaged in certain 

drug offenses from knowingly providing anything of pecuniary value to terrorists. 

 Title 50 of the U.S. Code, Section 1705, which prohibits engaging in financial interactions with a 

person or entity that has been named as a Specially Designated Global Terrorist (SDGT), unless 

OFAC has issued a license permitting the transaction. This also prohibits making or receiving any 

contribution of funds, goods, or services to or for the benefit of an SDGT. 

 Title 18 of the U.S. Code, Section 1960, which prohibits operating a money transmitting business 

without obtaining a state license, if one is required, or without registering with FinCEN. 

Using publicly available documents (indictments, sentencing memoranda, law enforcement press releases, 

media reports, etc.), the cases were examined more closely in order to determine their key financial 

components. In the 229 cases surveyed, 96 included information on the financial component of the 

investigation, either raising or moving funds, or both. These cases were then further analyzed to 

determine what specific method or channel was used to raise or move funds. Despite the flaws inherent 

in this type of study, the data provides a revealing glimpse into TF in the United States.7

 

 

6 See Department of State, Foreign Terrorist Organizations. Available at 

http://www.state.gov/j/ct/rls/other/des/123085.htm. 7

 A review of case documents and follow up discussions with law enforcement and prosecutors indicates that there 

are a number of additional cases in which the underlying criminal conduct may have some connection to TF, but 

where demonstrating a nexus to terrorist activity, which is often based on classified information, is unnecessary 

when much of the underlying activity is already criminalized by statute (e.g., drug trafficking or fraud). As a result, 

the nexus to terrorist activity may not be disclosed in public charging documents or sentencing memorandum. 

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In addition, Bank Secrecy Act (BSA) reporting was cross-referenced with ongoing CT investigations by 

the FBI to provide a current picture of the risks as detected by financial institutions and shared with law 

enforcement. 

METHODOLOGY 

As in the National ML Risk Assessment, the terminology and methodology of the National TF Risk 

Assessment is based on the guidance of the Financial Action Task Force (FATF), the international 

standard-setting body for AML and CFT safeguards.8

 The FATF guidance prescribes a process for 

conducting a risk assessment at the national level. This approach uses the following key concepts: 

 Threat: A threat is a person or group of people, or activity with the potential to cause harm to, for 

example, the state, society, the economy, etc. In the TF context this includes terrorist groups and 

their facilitators, as well as radicalized individuals that seek to exploit the United States and U.S 

financial system to raise and move funds. Threats are discussed in Section I. 

 Vulnerability: A vulnerability is something that can be exploited to facilitate TF, both in the 

raising of funds for terrorist networks and the moving of funds to terrorist organizations. It may 

relate to a specific fundraising method or financial product used to move funds, or a weakness in 

regulation, supervision, or enforcement, or reflect unique circumstances in which it may be 

difficult to distinguish legal from illegal activity. Vulnerabilities are addressed in Section III. 

 Consequence: Not all TF methods have equal consequences. The methods that allow for the 

greatest amount of money to be raised or moved most effectively present the greatest potential TF 

consequences.9

 

 Risk: Risk is a function of threat, vulnerability, and consequence. 

Throughout the National TF Risk Assessment, potential TF threats, vulnerabilities and residual risks were 

identified, analyzed and evaluated in the following manner: 

 Using the 2011 National Strategy for Counterterrorism and Congressional testimony from senior 

U.S. government officials, identifying the terrorist groups that the U.S. government has 

determined pose the most significant threat to the United States and the prime ways that these 

groups are financed, particularly where the United States and its financial system were involved; 

 Cataloging the TF methods disclosed in criminal investigations and prosecutions and violations of 

OFAC sanctions for supporting individuals and entities designated for their support of terrorist 

groups; 

 Analyzing financial institution reporting and cross-referencing with law enforcement CT 

investigations and/or OFAC designations; 

 

8

 FATF Guidance, National Money Laundering and Terrorist Financing Risk Assessment, February 2013. 

9

 As noted in the FATF Guidance, given the challenges in determining or estimating the consequences of TF, 

countries may instead opt to focus primarily on achieving a comprehensive understanding of their threats and 

vulnerabilities. Id at 8. Therefore, this National TF Risk Assessment focuses on threats and vulnerabilities in 

determining residual TF risks. The financing of terrorist acts and of terrorists and terrorist organizations is typically 

described as a three stage process requiring the raising, moving and using of funds. 

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 Comparing the above information with intelligence reporting to validate or refute the information; 

 Assessing the extent to which domestic laws and regulations, law enforcement investigations and 

prosecutions, regulatory supervision, and enforcement activity and international outreach and 

coordination mitigate identified TF threats and vulnerabilities; and 

 Using the aforementioned research and analysis to identify residual TF risks facing the United 

States. 

The National TF Risk Assessment begins with an overview of the global terrorism threat facing the 

United States, the importance of financing to these organizations and their activities, and the main 

methods these groups use to raise and move funds. 

After discussing the scope of the TF threat, the next section provides a brief overview of U.S. government 

efforts to mitigate the threat. This includes law enforcement efforts to investigate and prosecute terrorist 

supporters and legal/regulatory action to make it more difficult for terrorist financial facilitators to use the 

U.S. financial system. 

The third section identifies the specific TF vulnerabilities in the United States that terrorist groups exploit 

to raise, move and place funds, the efforts made by the U.S. government to mitigate such threats and 

vulnerabilities, and the residual risks facing the United States and the U.S. financial system. The 

discussion of vulnerabilities and residual risks includes case examples from investigations and 

prosecutions, relevant analysis of BSA data, and preventive measures taken by the U.S. government. 

Despite the significant efforts invested to mitigate these vulnerabilities, residual TF risk remains. 

 

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SECTION I: GLOBAL TERRORIST FINANCING THREAT 

A thorough analysis of the TF risks facing the United States today first requires identifying the groups 

posing the most significant terrorism threat to the United States and the primary ways these groups are 

financed. As described in detail below, the United States faces threats from an array of terrorist groups 

that have gained traction in areas of instability, limited opportunity, and broken governance. They 

include globally oriented groups like AQ and its affiliates, as well as a growing number of regionally 

focused and globally connected groups. To finance their activities, these groups rely on multiple revenue 

streams, including criminal activity, such as kidnapping for ransom (KFR), extortion, and drug 

trafficking; donations directly from individuals and those funneled through charitable organizations; and 

state sponsorship. In addition, there is a growing threat of terrorist acts committed by radicalized 

individuals who are inspired by particular terrorist groups, such as AQ and the Islamic State of Iraq and 

the Levant (ISIL). 

A. OVERVIEW OF TERRORIST THREAT FACING THE UNITED STATES 

As President Obama stated in May 2014, “for the foreseeable future, the most direct threat to America at 

home and abroad remains terrorism.”10 But, as the President noted, the nature of the threat has changed. 

The threat today “comes from decentralized Al-Qaida affiliates and extremists, many with agendas 

focused in countries where they operate. And this lessens the possibility of large-scale [September 11, 

2001]-style attacks against the homeland, but it heightens the danger of U.S. personnel overseas being 

attacked, as we saw in Benghazi.”11 Indeed, some terrorist groups targeting the United States may not be 

focused solely on directly attacking the territorial United States, but on U.S. national security interests 

abroad, including U.S. citizens, facilities, and allies.12 

The U.S. government’s overall counterterrorism strategy is guided by the National Strategy for 

Counterterrorism, prepared by the National Security Council. As the 2011 National Strategy for 

Counterterrorism explained, “[t]he preeminent security threat to the U.S. continues to be from Al-Qaida 

and its affiliates and adherents.”13 These groups have attempted several attacks on the United States, 

including the failed Christmas Day airline bombing in 2009, the attempted bombing of U.S.-bound cargo 

planes in October of 2010, and a disrupted plot to conduct a suicide bomb attack on a U.S.-bound airliner 

in April 2012.14 Moreover, although the death or arrest of dozens of mid- and senior-level AQ 

operatives—including Osama bin Laden in May 2011—have disrupted communication, financial, and 

facilitation nodes, and a number of terrorist plots, the terrorist threat posed by AQ has evolved.15 

 

10 President Barack H. Obama, “Remarks by the President at the United States Military Academy Commencement 

Ceremony,” May 28, 2014. 

11 Id. 12 See White House, National Strategy for Counterterrorism, June 2011. 

13 Id. 14 See James Comey, FBI Director, Testimony before the Senate Committee on Homeland Security and 

Governmental Affairs, “The Homeland Threat Landscape and U.S. Response,” November 14, 2013. 

Availablehttp://www.hsgac.senate.gov/download/?id=38830fb8-ce29-4542-9748-250b69d17383. 

15 See Department of State, “Country Reports on Terrorism 2014,” p. 374, June 2015. 

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Remaining members will continue to pose a threat to Western interests in South Asia and will attempt to 

strike the U.S. homeland should an opportunity arise.16 

However, the threat posed by AQ extends beyond the degraded core leadership. Affiliated movements 

have taken root in the Middle East, East Africa, the Maghreb and Sahel regions of northwest Africa, 

Central Asia, and Southeast Asia. Although each group is unique, all aspire to advance AQ’s regional 

and global agenda by destabilizing the countries in which they train and operate, attacking U.S. and other 

Western interests in the region, and in some cases plotting to strike the U.S. homeland.17 For example, 

over the past five years, AQ in the Arabian Peninsula (AQAP) has repeatedly attempted to detonate 

explosives on airliners bound for the United States, while AQ in the Lands of the Islamic Maghreb 

(AQIM) and its allies remain focused on local and regional attack plotting, including targeting Western 

interests.18 Al-Shabaab, another AQ affiliate, is mainly focused on undermining the Somali Federal 

Government and combating regional military forces operating in Somalia.19 But recent attacks in Kenya, 

including the April 2015 attack on a college and the September 2013 attack and hostage crisis at a mall, 

have been linked to Al-Shabaab, and demonstrate that the group continues to support targeting regional 

and Western interests across East Africa.20

The ongoing conflict in Syria and Iraq is reshaping the nature of the terrorist threat. Since mid-2014, 

ISIL, with its ambitious vision, quick territorial expansion, extreme violence and brutality, and innovative 

use of social media, has rapidly risen to challenge AQ for primacy within the global terrorist movement. 

ISIL has exploited the conflict in Syria and sectarian tensions in Iraq to entrench itself in both countries. 

The group’s strength and expansionist agenda pose an ongoing threat to U.S. regional allies and to U.S. 

facilities and personnel in both the Middle East and the West.21 Along with the threat posed by ISIL, 

Syria and Iraq have also become magnets for over 22,500 foreign terrorist fighters, and the preeminent 

location for independent or AQ-aligned groups to recruit, train, and equip these individuals, including 

more than 180 U.S. persons and at least 4,000 Westerners.22 Compounding the threat, veteran AQ 

fighters have travelled to Syria to take advantage of the permissive operating environment and easy 

 

16 Matthew G. Olsen, Director of the National Counterterrorism Center, Testimony before the Senate Committee on 

Homeland Security and Governmental Affairs, “The Homeland Threat Landscape and U.S. Response,” November 

14, 2013, http://www.hsgac.senate.gov/download/?id=4832a095-4fb4-4686-a689-0e14fc665ce9. 

17 White House, National Strategy for Counterterrorism, June 2011. 

18 See Matthew G. Olsen, Director of the National Counterterrorism Center, Testimony before the Senate Committee 

on Homeland Security and Governmental Affairs, “The Homeland Threat Landscape and U.S. Response,” 

November 14, 2013. 

19 See id. 20 See id; see also Department of State, Media Note, “Terrorist Designations of Ahmed Diriye and Mahad Karate,” 

April 21, 2015. Available at http://www.state.gov/r/pa/prs/ps/2015/04/240932.htm.

21 See Nicholas J. Rasmussen, Director, National Counterrorism Center, Testimony before the Senate Select 

Committee on Intelligence titled “Current Terrorist Threats to the United States,” February 12, 2015. Available at 

http://www.nctc.gov/docs/Current_Terrorist_Threat_to_the_United_States.pdf. 22 See Nicholas J. Rasmussen, Director, National Counterrorism Center, Testimony before the House Committee on 

Homeland Security “Countering Violent Islamist Extremism: The Urgent Threat of Foreign Fighters and 

Homegrown Terror,” February 11, 2015. Available at 

http://www.nctc.gov/docs/Countering_Violent_Islamist_Extremism.pdf. The number of foreign terrorist fighters is 

updated to reflect U.S. government analysis as of May 2015. 

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access to foreign terrorist fighters.23 These foreign terrorist fighters who travel to Syria and Iraq have 

become more radicalized, gained combat skills, made violent extremist connections, and, as demonstrated 

by recent attacks in Europe in early 2015, conducted organized or “lone-wolf” style attacks that target 

Western interests.24 Returning foreign terrorist fighters also pose an emerging threat to the United States, 

as U.S. authorities have identified U.S. persons who have engaged in attack plotting following their return 

to the United States after traveling to and receiving military training in Syria.25 

Beyond AQ, AQ affiliates, and ISIL, other foreign terrorist organizations threaten U.S. national security 

interests. These groups seek to undermine the security and stability of allied and partner governments, 

incite regional conflicts, traffic in drugs, or otherwise pursue agendas that are inimical to U.S. interests. 

In the Middle East, Hizballah remains committed to conducting terrorist activities worldwide, and the 

group’s activities could either endanger or target U.S. and other Western interests.26 The Islamic 

Resistance Movement (Hamas), which has intentionally killed hundreds of civilians, including U.S. 

citizens, continues to threaten U.S. interests and those of U.S. allies, notably Israel.27 

In South Asia, Pakistani and Afghan militant groups—including Tehrik-e Taliban Pakistan (TTP), the 

Haqqani Network, and Lashkar-e Tayyiba (LT)—continue to pose a direct threat to U.S. interests and 

allies in the region, where these groups probably will remain focused.28 TTP has carried out and claimed 

responsibility for numerous terrorist acts against Pakistani and U.S. interests, including a December 2009 

suicide attack on a U.S. military base in Khowst, Afghanistan, which killed seven U.S. citizens, an April 

2010 suicide bombing against the U.S. Consulate in Peshawar, Pakistan, which killed six Pakistani 

citizens, as well as the May 2010 attempted car bombing in Times Square.29 The Haqqani Network has 

conducted numerous high-profile attacks against U.S., NATO, Afghan government, and other allied 

nation targets, and is likely to carry out additional high-profile attacks against Western interests in 

Afghanistan.30 LT—the organization responsible for the rampage in Mumbai in 2008 that killed more 

than 150 people, including six Americans, constitutes a formidable terrorist threat to U.S. interests in 

 

23 Francis Taylor, Under Secretary for Intelligence and Analysis, Department of Homeland Security, Testimony 

before the House Committee on Homeland Security “Countering Violent Islamist Extremism: The Urgent Threat of 

Foreign Fighters and Homegrown Terror,” February 11, 2015. Available at 

http://www.dhs.gov/news/2015/02/11/written-testimony-ia-under-secretary-house-committee-homeland-securityhearing. 

24 See James R Clapper, Director of National Intelligence, Opening Statement before the Senate Armed Services 

Committee “Worldwide Threat Assessment of Hearing,” February 26, 2015. Available at 

http://www.dni.gov/files/documents/2015%20WWTA%20As%20Delivered%20DNI%20Oral%20Statement.pdf . 

25 See id; see, e.g.,United States v. Abdrirahman Shiek Mohaumd, No. 2:15-cr-00095, (Indictment) (S.D. Ohio, April 

16, 2015). 

26 Matthew G. Olsen, Director of the National Counterterrorism Center, Testimony before the Senate Committee on 

Homeland Security and Governmental Affairs, “The Homeland Threat Landscape and U.S. Response,” November 

14, 2013. 

27 See Department of the Treasury, Press Release, “Treasury Designates Gaza-Based Business, Television Station 

for Hamas Ties,” March 18, 2010. 

28 Matthew G. Olsen, Director of the National Counterterrorism Center, Testimony before the Senate Committee on 

Homeland Security and Governmental Affairs, “The Homeland Threat Landscape and U.S. Response,” November 

14, 2013.

29 See Department of State, “Country Reports on Terrorism 2014,” p.385, June 2015. 

30 See Matthew G. Olsen, Director of the National Counterterrorism Center, Testimony before the Senate Committee 

on Homeland Security and Governmental Affairs, “The Homeland Threat Landscape and U.S. Response,” 

November 14, 2013. 

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South Asia and potentially elsewhere.31 LT has attacked Western interests in South Asia, and also 

provides training to Pakistani and Western militants, some of whom could plot terrorist attacks in the 

West without direction from LT leadership.32

B. GLOBAL SOURCES OF TERRORIST FINANCING 

In order to operate, however, each of these groups requires significant funding. While the cost of an 

individual terrorist attack can be quite low, maintaining a terrorist organization requires large sums. 

Organizations require significant funds to create and maintain an infrastructure of organizational support, 

to sustain an ideology of terrorism through propaganda, and to finance the ostensibly legitimate activities 

needed to provide a veil of legitimacy for terrorist organizations. As deceased AQ financial chief Sa’id 

Al-Masri put it: “without money, jihad stops.”33 Although financial activities can vary significantly 

among different terrorist groups, several areas of commonality exist. 

1. CRIMINAL ACTIVITY

a. Kidnapping for Ransom 

Terrorist groups engage in a range of criminal activity to raise needed funds. Extensive revenue from 

kidnapping for ransom (KFR) and other criminal activities such as extortion have permitted AQ affiliates 

and other terrorist groups to generate significant revenue.34 KFR remains one of the most frequent and 

profitable source of illicit financing, and an extremely challenging TF threat to combat.35 The U.S. 

government estimates that terrorist organizations collected approximately $120 million in ransom 

payments between 2005 and 2012.36 In 2014 alone, ISIL acquired at least $20 million and as much as $45 

million in ransom payments.37 In addition, AQAP, AQIM, and Boko Haram are particularly effective 

with KFR and are using ransom money to fund the range of their activities. Kidnapping targets are 

usually Western citizens of countries with governments that have established a pattern of paying ransoms, 

either directly or through third party intermediaries, for the release of individuals in custody.38 AQAP 

used ransom money it received for the return of European hostages to finance its over $20 million 

 

31 White House, National Strategy for Counterterrorism, June 2011.

32 See Matthew G. Olsen, Director of the National Counterterrorism Center, Testimony before the Senate Committee 

on Homeland Security and Governmental Affairs, “The Homeland Threat Landscape and U.S. Response,” 

November 14, 2013.

33 Daniel L. Glaser, Assistant Secretary for Terrorist Financing, Department of the Treasury, Testimony before the 

House Financial Services Subcommittee on Oversight and Investigations, September 6, 2011. Available at 

http://www.treasury.gov/press-center/press-releases/Pages/tg1287.aspx. The speeches and testimony of Treasury 

officials cited in the National TF Risk Assessment contain information that is derived from U.S. government 

analysis. 

34 See Department of State, “Country Reports on Terrorism 2014,” pp. 9, 158, June 2015. 

35 See David Cohen, Under Secretary for Terrorism and Financial Intelligence, Department of the Treasury, Remarks 

before the Center for a New American Security, “Confronting New Threats in Terrorist Financing,’” March 4, 2014. 

Available at http://www.treasury.gov/press-center/press-releases/Pages/jl2308.aspx. 

36 David Cohen, Under Secretary for Terrorism and Financial Intelligence, Department of the Treasury, Remarks at 

Chatham House, “Kidnapping for Ransom: The Growing Terrorist Financing Challenge,” October 5, 2012. 

Available at http://www.treasury.gov/press-center/press-releases/Pages/tg1726.aspx. 

37 Derived from U.S. government analysis. 

38 See Department of State, “Country Reports on Terrorism 2014,” p. 377, June 2015. 

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campaign to seize territory in Yemen between mid-2011 and mid-2012.39 AQIM is believed to have 

obtained a €30 million ransom payment in October 2013 for the release of four French hostages who 

worked for the French government-owned nuclear firm Areva.40 Also in 2013, Boko Haram kidnapped 

eight French citizens in northern Cameroon and obtained a substantial ransom payment for their release.41 

Similarly, Al-Shabaab-affiliated groups received an approximately five million dollar ransom in exchange 

for the release of two Spanish hostages who were kidnapped in Kenya in October 2011.42

b. Extortion 

The exploitation of local populations and resources has become a key revenue source for numerous 

terrorist groups worldwide. Pioneered by groups such as Hamas and Al-Shabaab, this form of pseudosovereignty-based fundraising has spread to other un- or under-governed territories around the world, 

most recently Iraq and Syria. Not only does territorial occupation allow for fundraising from the theft of 

natural resources, but it also creates the opportunity to extort, under the threat of violence, local 

populations and businesses and generate funds from the seizure of public utility services and their 

accompanying revenues. Unlike taxation by local governing authorities, whereby tax revenue is used to 

pay for basic public services, terrorist groups extort funds from local populations with minimal 

corresponding provision of services in exchange, and under the threat of physical harm for non-payment. 

For example, Al-Shabaab, Al-Nusrah Front (ANF) and ISIL are all able to leverage their occupation of 

territory and the threat of violence to extort funds from the local population, as well as conduct criminal 

activity such as robbery and trafficking in stolen goods. ISIL generates significant revenue, up to several 

million dollars per week, from the sale of stolen and smuggled energy resources it controls inside Iraq and 

Syria.43 ISIL also operates sophisticated extortion rackets throughout Iraq and Syria, including extracting 

payments for the use of public highways and cash withdrawals from banks by depositors in cities such as 

Mosul.44 Through these schemes, ISIL can receive upwards of several million dollars a month of 

revenue.45 Despite losing control of the port of Kismayo, which was its key revenue source, Al-Shabaab 

continues to generate at least hundreds of thousands of dollars per month, primarily through extortion and 

the threat of violence, in its remaining strongholds in southern Somalia.46 Similarly, Hamas can also raise 

revenue from control of border crossings and avenues of commerce, as well as businesses and local 

populations.47

 

39 David Cohen, Under Secretary for Terrorism and Financial Intelligence, Department of the Treasury, Remarks 

before the Center for a New American Security, “Confronting New Threats in Terrorist Financing,’” March 4, 2014. 

40 Id. 41 See Department of State, “Country Reports on Terrorism 2014,” p.341, June 2015. 42 See David Cohen, Under Secretary for Terrorism and Financial Intelligence, Department of the Treasury, Remarks 

before the Center for a New American Security, “Confronting New Threats in Terrorist Financing,’” March 4, 2014. 

43 David Cohen, Under Secretary for Terrorism and Financial Intelligence, Department of the Treasury, Testimony 

before the House Committee on Financial Services, “The Islamic State and Terrorist Financing” November 13, 

2014. Available at http://financialservices.house.gov/uploadedfiles/hhrg-113-ba00-wstate-dcohen-20141113.pdf. 44 Id. 45 Id. 46 David Cohen, Under Secretary for Terrorism and Financial Intelligence, Department of the Treasury, Remarks 

before the Center for a New American Security, “Confronting New Threats in Terrorist Financing,” March 4, 2014. 

47 Derived from U.S. government analysis. 

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c. Drug trafficking and other criminal activity 

In addition, various terrorist groups derive significant financial benefit from other criminal activities, 

including through drug trafficking. Both the Revolutionary Armed Forces of Colombia (FARC) and the 

Taliban have utilized drug trafficking operations to finance their terrorist operations.48 The Haqqani 

Network is also financed by a wide range of revenue sources including businesses and proceeds derived 

from criminal activities such as smuggling, extortion, and KFR in Afghanistan and Pakistan.49 Hizballah 

supporters are often engaged in a range of criminal activities that benefit the group financially, such as 

smuggling contraband goods, passport falsification, drug trafficking, money laundering, and a variety of 

fraudulent schemes, including credit card, immigration, and bank fraud.50 BSA reporting specifically 

implicates individuals currently being investigated by the FBI for ties to Hizballah and Hamas in a wide 

variety of money laundering activity within the U.S. financial system, most prominently trade-based 

money laundering (TBML) activities including through the export of used cars.51

2. PRIVATE DONATIONS AND MISUSE OF CHARITABLE52 ORGANIZATIONS 

Private donations from individuals and charitable organizations have continued to provide terrorist groups 

with a consistent flow of funds. Private donations from individuals in the Persian Gulf remained a major 

source of funding for several Sunni terrorist groups, particularly for those operating in Syria, as charitable 

fundraising networks in the Gulf have collected hundreds of millions of dollars through regular 

fundraising events held at homes or mosques and through social media pleas.53 In particular, fundraisers 

operating in more permissive jurisdictions in the Gulf—particularly in Kuwait and Qatar—solicit 

donations ultimately destined for terrorist groups, including ANF.54 These networks then use couriers, 

wire transfers, hawalas, and exchange houses to move those funds to Syria, often to extremists.55 Some of 

this fundraising activity has occurred under the auspices of charitable giving and has involved the use of 

social media to reach potential donors.56 Regarding ISIL, as the State Department noted in August 2014, 

“private fundraising networks increasingly rely upon social media to solicit donations and communicate 

 

48 See Hearing before the House Committee on Foreign Affairs, Subcommittee on Terrorism, Nonproliferation and 

Trade, “Narcoterrorism and the Long Reach of U.S. Law Enforcement, Part II,” November 17, 2011. Available at 

http://www.gpo.gov/fdsys/pkg/CHRG-112hhrg71265/html/CHRG-112hhrg71265.htm. 

49 Derived from U.S. government analysis. 

50 Department of State, “Country Reports on Terrorism 2014,” p.351, June 2015. 

51 Information derived from an analysis of financial institution BSA reporting cross-referenced with law 

enforcement investigations. 

52 The term “charitable” as used herein is intended in its broadest sense, to include charitable, humanitarian, 

religious, educational, and other organizations and philanthropic individuals, and unless otherwise indicated, is not 

limited to organizations that the IRS has determined are tax-exempt charitable organizations under Section 501(c)(3) 

of the Internal Revenue Code (IRC). 

53 See Department of State, “Country Reports on Terrorism 2014,” p.373, June 2015. 

54 See David Cohen, Under Secretary for Terrorism and Financial Intelligence, Department of the Treasury, Remarks 

before the Center for a New American Security, “Confronting New Threats in Terrorist Financing,’” March 4, 2014. 

55 Id. 56 See Department of the Treasury, Press Release, “Treasury Designates Three Key Supporters of Terrorists in Syria 

and Iraq,” August 6, 2014. Available at http://www.treasury.gov/press-center/press-releases/Pages/jl2605.aspx. For 

example, Shafi Sultan Mohammed al-Ajmi, one of the designated individuals, operates regular social media 

campaigns seeking donations for Syrian fighters and is one of the most active Kuwaiti fundraisers for ANF. In July 

2014, he publicly admitted that he collected money under the auspices of charity and delivered the funds in person 

to ANF. 

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with donors and recipient opposition groups or terrorist organizations.”57 

 

For funding, AQ receives donations from like-minded supporters as well as from individuals who believe 

that their money is supporting a humanitarian cause.58 Some funds have also been diverted from Islamic 

charitable organizations.59 In past years, they received the majority of their funds from sympathizers in 

the Persian Gulf, followed by supporters based in Pakistan and Turkey.60

LT receives the majority of its funds from within Pakistan, including by using its charitable front 

organizations, Jamaat-ud-Dawa (JUD) and Falah-i-Insaniyat Foundation (FIF), to solicit donations.61 As 

is the case with other terrorist groups, LT generates additional funds from private donations and 

commercial ventures.62 The group’s two largest financial hauls come from private donations during 

Ramadan and profits associated with the collection and sale of animal skins during the Eid-ul-Adha 

holiday, each of which nets the group millions of dollars.63 

In addition to private donations from the Persian Gulf, the provision of financial support from witting and 

unwitting members of key diaspora communities worldwide has also been a source of revenue for 

numerous terrorist groups. For example, because Al-Shabaab is a multi-clan entity, it receives donations 

from individuals in the Somali diaspora; however, the donations are not always intended to support 

terrorism, but also to support family members.64 Similarly, Hizballah receives financial support from 

Lebanese Shia communities in Europe, Africa, South America, North America, and Asia, and Hamas 

receives donations from Palestinian expatriates around the world, including in the United States, through 

its charities, such as the umbrella fundraising organization, the Union of Good.65 

3. STATE SPONSORSHIP

Despite ongoing diplomatic efforts and economic sanctions by the United States and its allies, some states 

continue to directly fund terrorist groups. Iran continues to provide Hizballah with hundreds of millions 

 

57 Marie Harf, Deputy Spokesperson, Department of State, Daily Press Briefing, August 21, 2014. Available at 

http://www.state.gov/r/pa/prs/dpb/2014/08/230798.htm#ISIL. In the case of ISIL, external donations raised from 

individuals have been used to facilitate the travel of foreign terrorist fighters to Syria and Iraq. See FATF, Financing 

of the Terrorist Organization Islamic State in Iraq and the Levant, February 2015. 

58 Department of State, “Country Reports on Terrorism 2014,” p.375, June 2015. 

59 Id. 60 See David Cohen, Under Secretary for Terrorism and Financial Intelligence, Department of the Treasury, Remarks 

before the Center for a New American Security, “Confronting New Threats in Terrorist Financing,’” March 4, 2014. 

61 Derived from U.S. government analysis. LT coordinates charitable activities through its U.S.- and UN-designated 

front organizations, JUD, which spearheaded humanitarian relief to the victims of the October 2005 earthquake in 

Kashmir, and FIF, which was widely reported to have provided aid to flood victims in Pakistan in 2010. To raise 

awareness regarding this activity, as well as to provide guidance as to how charities and donors can avoid directly or 

indirectly providing assistance to terrorist organizations, Treasury issued specific guidance in the wake of the 

October 2005 earthquake, which is available at http://www.treasury.gov/resource-center/terrorist-illicitfinance/Documents/charities_post-earthquake.pdf. 

62 Derived from U.S. government analysis. 

63 Id. 64 Department of State, “Country Reports on Terrorism 2014,” p.384, June 2015. 

65 Id. at 346, 351. 

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of dollars in aid each year, which makes up a significant portion of the group’s funding.66 As with 

Hizballah, state sponsorship has played a significant role in Hamas’ financing. Historically, Hamas has 

received funding, weapons, and training from Iran, but the relationship suffered after Hamas refused to 

follow Iran’s lead in supporting Syrian President Bashar al-Asad.67 

As described above, the terrorist organizations that pose a threat to the United States employ a variety of 

methods to raise funds necessary to carry out terrorist acts. To combat these groups and the threat they 

pose, the U.S. government has developed and implemented a comprehensive CT strategy, which includes 

disrupting financing for these terrorist organizations. Domestically, several U.S. government agencies 

play critical roles in the effort to combat TF in the United States. Section II provides an overview of the 

interagency effort to disrupt domestic sources of TF. 

 

66 Derived from U.S. government analysis. 

67 See Department of State, “Country Reports on Terrorism 2014,” p.285, June 2015. 

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SECTION II: COUNTERING TERRORIST FINANCING 

Although all of the groups in Section I pose threats to U.S. national security interests, every TF method 

they employ does not necessarily pose an immediate TF risk in the United States. After the September 

11, 2001 terrorist attacks, the U.S. government aligned its efforts to prevent future terrorist attacks. As 

President Obama recently noted, in the wake of the September 11, 2001 terrorist attacks “we demanded 

that our intelligence community improve its capabilities, and that law enforcement change practices to 

focus more on preventing attacks before they happen than prosecuting terrorists after an attack.”68 

Prevention and early detection is at the core of U.S. government threat mitigation efforts and remains the 

U.S. government’s top priority. Preventing terrorists from raising, moving, placing and using funds is 

central to this effort. As noted in the 2011 National Strategy for Counterterrorism, one of the U.S. 

government’s eight overarching CT goals is to deprive terrorists of their enabling means, which includes 

financial support, by expanding and enhancing “efforts aimed at blocking the flow of financial resources 

to and among terrorist groups and to disrupt terrorist facilitation and support activities, imposing 

sanctions or pursuing prosecutions to enforce violations and dissuade others.” These efforts fall into three 

broad categories: (i) law enforcement efforts; (ii) financial/regulatory measures; and (iii) international 

engagement. 

A. LAW ENFORCEMENT EFFORTS 

The ongoing work of the law enforcement agencies (LEAs) has been and remains central to U.S. CFT 

efforts. Since the September 11, 2001 terrorist attacks, LEAs have undertaken a fundamental 

reorientation of their institutions, processes, resources, and apparatuses to enhance their ability to disrupt 

and prevent acts of terrorism before they occur.69 The DOJ, the principal government entity responsible 

for overseeing the investigation and prosecution of TF offenses at the federal level, uses its authorities to 

investigate and dismantle terrorist financiers and thus deter future supporters.70 To advance this mission 

and in recognition of the importance of tracking the financial underpinnings of terrorist activity, FBITFOS was established immediately after September 11, 2001 to identify and disrupt all TF activities.71 

FBI-TFOS is charged with managing FBI’s investigative efforts into TF facilitators and ensuring financial 

investigative techniques are used, where appropriate, in all FBI CT investigations to enhance the 

investigations.72 For example, to the extent that funds affiliated with individuals being investigated by the 

FBI for ties to AQ and other terrorist groups still transit through the U.S. financial system, FBI and its law 

enforcement partners make extensive use of Suspicious Activity Reports (SARs) and Currency 

 

68 President Obama, “Remarks by the President on Review of Signals Intelligence,” 1/17/2014. Available at 

http://www.whitehouse.gov/the-press-office/2014/01/17/remarks-president-review-signals-intelligence. 

69 See generally Department of Justice, “FY 2013 Annual Performance Report and FY 2015 Annual Performance 

Plan,” March 2014. 

70 See Office of the Inspector General, Department of Justice, “Audit of the Federal Bureau of Investigation’s and 

the National Security Division’s Efforts to Coordinate and Address Terrorist Financing,” Audit Report 13-17, March 

2013. Available at http://www.justice.gov/oig/reports/2013/a1317.pdf. 

71 See id. 72 Ralph S. Boelter, Acting Assistant Director, FBI Counterterrorism Division, Statement Before the Senate 

Judiciary Committee, Subcommittee on Crime and Terrorism, September 21, 2011. 

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Transaction Reports (CTRs) related to TF in order to interdict and seize such funds.73 FBI-TFOS works 

in close coordination with the National Joint Terrorism Task Force (JTTF), which coordinates CT efforts 

of federal, state and local law enforcement agencies through local JTTFs in 104 cities nationwide, foreign 

partners, and the financial industry. These efforts have reduced the funding available for terrorist 

operations and have made the concealment and transfer of terrorism related funds more difficult.74 In 

addition to FBI-TFOS, other DOJ components play a key role in TF investigations. DEA’s drug 

trafficking and money laundering enforcement initiatives seek to deny drug trafficking and money 

laundering routes to terrorist organizations, while the Bureau of Alcohol, Tobacco, Firearms and 

Explosives (ATF) investigates the illegal sale of explosives and tobacco products.75 When an 

investigation produces sufficient evidence for a criminal prosecution, the U.S. Attorneys’ Offices, 

working closely with the DOJ’s National Security and Criminal Divisions, leverage multiple federal 

criminal statutes to prosecute cases involving TF. 

In addition to the DOJ, other LEAs play important roles in furthering U.S. CFT efforts. Within DHS, 

Customs and Border Protection (CBP) detects the movement of bulk cash across U.S. borders and 

maintains data about the movement of commodities and persons in and out of the United States, while 

Immigration and Customs Enforcement-Homeland Security Investigations (ICE-HSI) initiates 

investigations of terrorist financing involving transnational crimes to include smuggling and TBML. The 

IRS, a bureau within Treasury which administers and enforces U.S. tax laws, also plays a supporting role 

in the U.S. government’s CFT efforts, in particular through the work of IRS-CI, which investigates 

criminal violations of U.S. tax law, as well as money laundering and other financial crimes, and IRSTE/GE, which administers IRS regulations related to tax-exempt charitable organizations.76 When 

authorized to assist in a TF investigation, these IRS components can provide unique expertise and 

authorities to support U.S. government CFT efforts. 

 

These efforts are supported by the financial intelligence and analytical work of FinCEN. FinCEN grants 

more than 10,000 agents, analysts, and investigative personnel from more than 350 agencies across the 

U.S. government direct access to BSA reporting. There are about 30,000 searches of the data taking place 

daily. This financial intelligence allows LEAs to identify significant relationships, patterns and trends. 

The reporting unmasks the relationships between possible terrorist groups and their financing networks, 

enabling law enforcement to target the underlying conduct of concern, and to use forfeiture and sanctions 

to disrupt their ability to operate and finance their activities. 

The significant number of TF cases brought by various LEAs and the whole of government approach 

exemplifies the active role LEAs take in prosecuting terrorist support networks. Since 2001, more than 

229 cases have either led to convictions or are still pending judgment against individuals who were 

charged with supporting—or conspiring to support—terrorism or terrorist groups through material 

support, transmitting money without a license, narco-terrorism, and economic sanctions violations. 

 

73 Information derived from an analysis of financial institution BSA reporting cross-referenced with law 

enforcement investigations. 

74Id. 75 DEA, Department of Justice, “FY 2014 Performance Budget Congressional Submission.” Available at 

http://www.justice.gov/jmd/2014justification/pdf/dea-justification.pdf. 

76 See IRS, Department of the Treasury: “The Budget in Brief: Internal Revenue Service FY 2015.” 

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B. FINANCIAL/REGULATORY EFFORTS 

As part of the broader post-September 11, 2001 CT efforts, the U.S. government focused increasingly on 

the importance of disrupting the finances and funding networks that fueled terrorist organizations and on 

the importance of financial intelligence collected and disseminated by domestic financial institutions.77 

Treasury’s Office of Terrorism and Financial Intelligence (TFI) was established in 2004 to lead the U.S. 

government’s CFT efforts.78 TFI seeks to mitigate TF risk through both systemic and targeted actions. 

Targeted actions, usually in the form of targeted financial sanctions administered and enforced by OFAC, 

are used to identify, disrupt, and prevent terrorists from accessing the U.S. financial system. 

These actions are complemented by the efforts of FinCEN and the federal functional regulators that 

evaluate and enforce a financial institution’s compliance with the appropriate regulatory requirements. 

For example, as administrator of the BSA, FinCEN, a component of TFI, promulgates implementing 

regulations for the BSA to reduce the potential for abuse by various illicit finance threats, including TF. 

To develop these regulations FinCEN and other offices within TFI regularly engage all the appropriate 

stakeholders to understand these threats. FinCEN works with the federal functional regulators and law 

enforcement to develop guidance, administrative rulings and advisories for the financial industry to aid 

financial institutions in identifying priority threats such as TF. 

Additionally, U.S. government CFT initiatives have benefited from and contributed to long-standing 

efforts to protect the financial system against all forms of illicit finance. These laws, rules, regulations 

and guidance have aided financial institutions in identifying and managing risk, provided valuable 

information to law enforcement, and created the foundation of financial transparency required to deter, 

detect, and punish those who would abuse the U.S. financial system to launder the proceeds of crime and 

move funds for illicit purposes.79 For example, controls instituted to combat money laundering have also 

strengthened our ability to identify, deter, and disrupt TF.80 

 

77 See Jacob J. Lew, Secretary of the Treasury, Remarks at the Center for Strategic and International Studies, 

“TFI@10: The Evolution of Treasury's National Security Role,” June 2, 2014. For example, as of June 2012, 37 

percent of the FBI’s pending CT cases had associated BSA records. David Cohen, Under Secretary for Terrorism 

and Financial Intelligence, Department of the Treasury, Testimony before the Senate Committee on Banking, 

Housing and Urban Affairs “Patterns of Abuse: Assessing Bank Secrecy Act Compliance and Enforcement,” March 

7, 2013. Available at http://www.treasury.gov/press-center/press-releases/Pages/jl1871.aspx. 

78 TFI is composed of: TFFC, TFI’s policy development and outreach office; OFAC which is charged with 

administering and enforcing all U.S. economic sanctions programs, including those targeting TF; OIA, TFI’s inhouse intelligence office; and FinCEN, the financial intelligence unit (FIU) for the United States, which is also 

charged with administering and enforcing the BSA. See Department of the Treasury, Organizational Structure. 

Available at http://www.treasury.gov/press-center/press-releases/Pages/hp361.aspx. 

79 David Cohen, Under Secretary for Terrorism and Financial Intelligence, Department of the Treasury, Testimony 

before the Senate Committee on Banking, Housing and Urban Affairs “Patterns of Abuse: Assessing Bank Secrecy 

Act Compliance and Enforcement,” March 7, 2013. 

80 Of the individuals being investigated by law enforcement for ties to terrorist organizations who has associated 

BSA records, 58 percent were identified in financial institution BSA reporting as having engaged in suspected 

money laundering, including structuring, according to information derived from an analysis of financial institution 

BSA reporting cross-referenced with law enforcement investigations. 

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C. INTERNATIONAL ENGAGEMENT 

As described earlier, the scope and reach of the U.S. financial system makes it vulnerable to TF abuse. 

Moreover, because many of the terrorist groups and foreign terrorist fighters described above pose a 

direct threat to the U.S. homeland and U.S. national security interests abroad, the United States has a 

vested interest in disrupting their financial activity even if it never actually reaches the U.S. financial 

system. In recognition of this and of the increasing interconnectedness of the global financial system, a 

secure global framework is essential to effectively mitigate TF risk within the U.S. financial system. To 

that end, the U.S. government engages bilaterally and multilaterally to globalize its CFT efforts by: (i) 

supporting the development of strong international AML/CFT standards and working towards robust 

implementation of them through the FATF and the United Nations (UN) as well as other bodies; (ii) 

raising international awareness of the nature and characteristics of TF as well as calling attention to 

specific threats; and (iii) providing training and technical assistance to bolster national CFT regimes and 

enforcement mechanisms. Helping to strengthen global AML/CFT regimes has a direct benefit to the 

safety and integrity of the U.S. financial system, given the global nature of money laundering and TF and 

the relationships between banks abroad.81 The U.S. government considers strong international AML/CFT 

regimes critical in advancing its efforts to prevent TF from touching the U.S. financial system in the first 

place. Moreover, this global AML/CFT architecture assists the U.S. government in systematically 

identifying and addressing TF vulnerabilities in the international financial system on an ongoing basis. 

Such a global architecture in turn enhances our ability to both protect the integrity of the international 

financial system and undermine the financial networks that support terrorist organizations.82

D. EXAMPLE OF SUCCESSFUL INTERAGENCY COORDINATION: 

RESPONSE TO THE ATTEMPTED TIMES SQUARE BOMBING 

In addition to its focus on preventing future attacks to the homeland, in the event that a terrorist plot 

develops, the U.S. government makes extensive use of financial intelligence to identify, investigate, and 

prosecute the network involved in plotting the attack. 

On May 1, 2010, Faisal Shahzad, a naturalized U.S. citizen born in Pakistan, drove a Nissan Pathfinder 

loaded with explosives to Times Square, began the detonation process and fled the Pathfinder. A street 

vendor noticed smoke coming from the Pathfinder and alerted police, who evacuated Times Square and 

sent in the bomb squad. Following the attempted attack, multiple U.S. government agencies rapidly 

coordinated an expansive investigation into the potential suspects. On May 3, 2010, Shahzad was pulled 

off a flight at JFK airport set to depart for Dubai by the Department of Homeland Security. Shahzad 

received explosives training in Waziristan, Pakistan from explosive trainers affiliated with TTP.83 In June 

 

81 David Cohen, Under Secretary for Terrorism and Financial Intelligence, Department of the Treasury, Testimony 

before the Senate Committee on Homeland Security and Governmental Affairs Permanent Subcommittee on 

Investigations, “U.S. Vulnerabilities to Money Laundering, Drugs, and Terrorist Financing: HSBC Case History,” 

July 17, 2012. Available at http://www.hsgac.senate.gov/download/?id=55d94bbb-cbee-4a35-89ca-5493a12d73dd. 

82 See Daniel L. Glaser, Assistant Secretary for Terrorist Financing, Department of the Treasury, Testimony before 

the U.S.-China Economic and Security Review Commission, Hearing on Macau and Hong Kong, June 27, 2013. 

Available at http://www.uscc.gov/sites/default/files/Glaser%20Testimony.pdf. 

83 See FBI, Press Release, “Faisal Shahzad Pleads Guilty in Manhattan Federal Court to 10 Federal Crimes Arising 

from Attempted Car Bombing in Times Square,” June 21, 2010. 

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2010, Shahzad pleaded guilty to ten counts, and in October 2010 he was sentenced to life in prison 

without possibility of parole.84 

A review and analysis of financial records and information provided to law enforcement by financial 

institutions played a key role in the investigation, successful identification, and prosecution of Shahzad, 

including his link to TTP. To fund the bombing, Shahzad in February 2010 received about $4,900 in cash 

(sent from a TTP supporter in Pakistan) in Massachusetts, which he picked up from a gas station 

attendant named Aftab Ali Khan acting as a unlicensed money transmitter.85 Six weeks later, he received 

another $7,000 in cash (sent by the same conspirator in Pakistan) in Ronkonkoma, New York, from a 

Pakistani businessman named Mohammed Younis who was also acting as an unlicensed money 

transmitter.86 Khan pleaded guilty to immigration and unlicensed money transmitter charges and was 

deported to Pakistan in May 2011. Younis pleaded guilty to operating as an unlicensed money transmitter 

in August 2011 was sentenced to 3 years’ probation and ordered to forfeit $12,000. 

 

84 See FBI, Press Release, “Faisal Shahzad Sentenced in Manhattan Federal Court to Life in Prison for Attempted 

Car Bombing in Times Square,” October 5, 2010. 

85 See FBI, Press Release, “Pakistani Man Sentenced on Unlicensed Money Transmitting and Immigration Fraud 

Charges,” April 11, 2011. 

86 See United States v. Mohammad Younis, 10 Cr. 813 (Sentencing Memorandum), (S.D.N.Y. filed November 23, 

2011). 

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SECTION III: TERRORIST FINANCING 

VULNERABILITIES AND RISKS IN THE UNITED STATES 

This section is intended to expand upon the specific vulnerabilities that terrorist organizations and 

radicalized individuals can exploit to raise, move, and place funds, and which the U.S. government has 

determined pose a residual risk to the United States and U.S. financial system. The United States faces 

residual risk from vulnerabilities associated with criminal activity, including narcotics trafficking and 

other criminal acts, misuse of charitable organizations and individuals raising funds under the auspices of 

charitable giving, and direct financial support from individuals to terrorist organizations. As noted above, 

in part due to the central role of U.S. financial institutions in the international financial system and the 

attractiveness of the U.S. dollar as a globally accepted medium of exchange, the United States faces some 

residual TF risk from vulnerabilities associated with various types of regulated and unregulated financial 

institutions, as well as cash smuggling, which are being addressed through ongoing U.S. government 

outreach, regulation, and law enforcement activities. Additionally, the U.S. government continues to 

monitor emerging TF threats and vulnerabilities, including the use of cybercrime and identify theft 

schemes by terrorist groups to raise funds, as well at the use of new payment systems to move and place 

funds.

A. RAISING FUNDS: VULNERABILITIES AND RISKS 

1. CRIMINAL ACTIVITY 

 

The U.S. government has observed that numerous terrorist organizations worldwide engage in criminal 

activity to fund their organizations and operations. Globally, AQ, ISIL, the Haqqani Network and ANF, 

for example, are known to be financed in part by proceeds derived from smuggling, robbery, and 

extortion.87 Based on an analysis of U.S. criminal investigations leading to prosecutions, terrorist 

organizations continue to rely on criminal activities88 in the United States to finance their operations. Of 

the cases reviewed, about 24 percent involved some criminal activity, such as smuggling, drug trafficking 

or fraud, being used to fund terrorist activity.89 

The U.S. government has observed that both criminal organizations and terrorist groups continue to 

develop international networks and establish alliances of convenience.90 Moreover, looking forward, as 

terrorist groups increasingly reveal a willingness to engage in criminal activities to raise funds, the risk 

 

87 Derived from U.S. government analysis. 

88 While providing funds to terrorists and terrorist organizations is itself a criminal act, regardless of the source of 

those funds, the reference to “criminal activity” refers to criminal acts other than providing financial support to a 

terrorist organization. 

89 As described above, an analysis was conducted by Treasury on terrorism and terrorism-related convictions 

between 2001 and 2014. Using publicly available documents (indictments, sentencing memoranda, law enforcement 

press releases, media reports, etc.) the cases were examined more closely in order to determine key financial 

components. In the 229 cases surveyed, 96 included information on the financial component to the investigation, 

either raising or moving the funds. These cases were then further analyzed to determine what specific method or 

channel was used to raise or move funds. 

90 Karen P. Tandy, Administrator, DEA, Statement Before the House Committee on Armed Services U.S. House of 

Representatives, “Status of Security and Stability in Afghanistan,” June 28, 2006. Available at 

http://www.dea.gov/pr/speeches-testimony/2006t/ct062806p.html. 

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that they will collaborate with international criminal organizations increases.91 Collaboration can serve as 

a force multiplier for both criminal and terrorist groups, bolstering their capabilities, strengthening their 

infrastructure, and increasing their wealth. Often, the potential profits associated with criminal activity 

are a motivating factor for both organized crime and terrorist groups.92 

To the extent that this criminal activity occurs in the United States, it is subject to a range of U.S. 

government action including targeted financial sanctions and law enforcement actions. Although the FBI 

is the lead investigative agency for material support-related investigations as well as for those cases in 

which criminal activity is used as a TF method, the DEA plays a significant role in those cases that 

involve drug trafficking. Given the substantial resources the U.S. government commits to combating the 

threat posed by transnational organized crime, other U.S. government agencies also support these TF 

investigations where there is a nexus with particular types of transnational organized crime, such as crossborder smuggling of goods.93 As with all TF-related activity, DOJ attorneys prosecute these cases. 

Although the number of TF prosecutions for such activity in the United States may be relatively lower 

than for other types of activity, criminal activity remains a residual TF risk in part due to the high-revenue 

nature of the activity.94 For example, although an individual terrorist financier raising money under the 

auspices of charitable giving may provide hundreds or thousands of dollars’ worth of material support, the 

benefit provided to a terrorist organization from drug trafficking activity may be significantly greater, and 

a single KFR payment can run into the millions. Cases included in this section, for example, involve the 

movement of multi-ton quantities of drugs either belonging to or for the benefit of terrorists and the 

smuggling of hundreds of thousands of dollars’ worth of electronics and cash. 

a. Kidnapping for Ransom 

As discussed in Section I, the magnitude and scale of terrorists relying on criminal proceeds has reached 

new heights with the spread of KFR as a fundraising strategy. KFR has become one of the most frequent 

and profitable sources of TF.95 Despite the significant TF risk posed by KFR globally, abuse of the U.S. 

financial system to KFR-related TF is relatively low. As a matter of long-standing policy, the U.S. 

government does not pay ransoms or make other concessions to terrorist organizations holding U.S. 

citizens hostage.96 

 

91 David Cohen, Assistant Secretary for Terrorist Financing, Remarks to the ABA/ABA Money Laundering 

Enforcement Conference, October 12, 2009. Available at http://www.treasury.gov/press-center/pressreleases/Pages/tg317.aspx. 

92 See id. 93 See White House, Strategy to Combat Transnational Organized Crime: Addressing Converging Threats to 

National Security, July 2011. 

94 The lower number of prosecutions for criminal activity in support of terrorist financing may be due to the fact that 

demonstrating a nexus to terrorist activity, which is often based on classified information, is unnecessary where 

much of the underlying activity is already criminalized by statute (e.g. drug trafficking or fraud), and thus the nexus 

to terrorist activity may not be disclosed in public charging documents or sentencing memorandum. 

95 Department of State, Fact Sheet “Country Reports on Terrorism 2013,” April 30, 2014. Available at 

http://www.state.gov/r/pa/prs/ps/2014/04/225406.htm. 

96 See White House, Office of the Press Secretary, Press Briefing by the Press Secretary, November 18, 2014. 

Available at https://www.whitehouse.gov/the-press-office/2014/11/18/press-briefing-press-secretary-11182014. 

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However, given the significant TF risk globally of KFR, the U.S. government has focused its efforts 

internationally, using a multifaceted approach to prevent terrorist groups from successfully using 

kidnapping to raise money. These efforts focus primarily on (i) preventing kidnappings, (ii) reducing the 

incentive to take hostages by encouraging governments to refrain from making concessions to terrorists, 

and (iii) denying terrorist kidnappers the benefits of their crime by working with international partners to 

locate, arrest and prosecute hostage takers and locate, freeze, and recover their assets. These efforts in 

coordination with international partners have resulted in a number of multilateral initiatives on KFR.97 

Despite these efforts, KFR continues to be a significant TF risk globally. Thus, the U.S. government will 

continue to engage global partners and the private sector to endeavor to reduce the availability of KFR as 

a source of TF. 

b. Drug Trafficking 

Another lucrative criminal activity that has benefited some terrorist organizations is drug trafficking. As 

demonstrated by a review of publicly available information on U.S. law enforcement cases (particularly 

investigations led by the DEA) involving terrorism and TF offenses and financial and intelligence 

reporting, ongoing links between drug trafficking networks and terrorist organizations and their 

facilitators continue to present a residual TF risk to the United States through “narco-terrorism.” 

Approximately seven percent of the TF-related law enforcement cases reviewed involved drug 

smuggling.98 Illicit drugs have long been attractive commodities to smuggle due to their high pecuniary 

value, as well as the ease with which they can be appropriated, processed, stored, and transported. 

Additionally, despite the success of various U.S. government initiatives in combating illegal drug sales 

and use domestically, the United States continues to be a source of demand for the global drug trade.99 

Multiple terrorist groups have benefited from the global drug trade and drug sales to the United States to 

finance their operations. In one case, a group of drug traffickers in West Africa agreed to receive and 

store multi-ton shipments of Taliban-owned heroin in Benin and to transport the heroin to Ghana, from 

where they understood portions of the heroin would be sent on a commercial airplane to the United States 

to be sold for the financial benefit of the Taliban.100 The case also demonstrates the nexus between narcotrafficking and other forms of material support, such as weapons trafficking. The links between drug 

traffickers and terrorist facilitators can extend beyond a single terrorist organization. Several of these 

same drug traffickers agreed to arrange the sale of weapons for the Taliban’s use in Afghanistan, and 

indicated they also facilitated weapons trafficking for Hizballah.101 

 

97 For example, UN Security Council Resolution 2199, passed in February 2015, reaffirmed (1) previous calls on 

states to prevent terrorists from benefiting from ransom payments or from political concessions; (2) that UN 

sanctions prohibit ransom payments to UN-listed groups (including ISIL and ANF); and (3) the need for states to 

cooperate closely during kidnapping incidents. UN Security Council Resolution 2199 (2015). Available at 

http://www.un.org/press/en/2015/sc11775.doc.htm. Additionally, the multinational Counter-ISIL Financing Group 

identified as one of its key objectives denying ISIL the use of KFR as a source of revenue. See Department of State, 

Media Note, “Establishment of the Counter-ISIL Finance Group in Rome, Italy,” March 20, 2015. 

98 See Footnote 89. 

99 See White House, Office of National Drug Control Policy, National Drug Control Strategy, p.35, 2014. 

100 See United States v. Saade et al., Case No. 1:11-cr-00111 (Indictment) (S.D.N.Y. February 2011). 

101 See id. 

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In another case, a drug trafficker agreed to arrange the importation of hundreds of kilograms of highquality heroin into the United States and was led to believe that the profits would be used, among other 

things, to purchase weapons for Hizballah.102 Another individual also arranged for the sale of six assault 

rifles and an additional 10 kilograms of heroin that he believed was destined for the United States, and 

would fund the Taliban from the proceeds of the sale of the heroin.103 

In accordance with overall CT/CFT priorities, the United States takes a proactive approach to combating 

the TF vulnerability posed by narco-terrorism, including through sting operations and aggressive 

prosecutions under post-September 11, 2001 authorities. The USA PATRIOT Act which, with related 

successor bills, significantly augmented DEA’s authority in narco-terrorism investigations and 

prosecutions, specifically in regards to 21 U.S.C. § 959 and § 960a.104 21 U.S.C. § 959 expands the reach 

of DEA to acts of manufacture or distribution outside of the United States.105 This section makes it 

unlawful for any person to manufacture or distribute a controlled substance or listed chemical intending 

or knowing that it will be unlawfully imported into the United States.106 21 U.S.C. § 960a allows for 

prosecution of terrorist-related, extra-territorial drug offenses and provides DOJ with a particularly 

powerful tool to prosecute, disrupt, and dismantle narco-terrorist groups worldwide.107 Of the cases 

surveyed since 2006, there have been 17 cases in which an alleged narco-terrorist has been indicted or 

convicted of drug-related crimes or for providing direct material support to a terrorist organization.108 

These individuals were associated with a variety of terrorist organizations, including the FARC, 

Hizballah, AQ, and the Taliban.109 In 12 of these 17 cases, the individuals were also charged with 

providing material support to terrorist groups.110

DEA enforcement efforts work to disrupt and dismantle entire drug trafficking networks by targeting their 

leaders for arrest and prosecution, confiscating the profits that fund continuing drug operations, and 

eliminating international sources of supply. DEA’s drug trafficking and money laundering enforcement 

initiatives support and augment U.S. government CT/CFT efforts by reducing the availability of drug 

trafficking and/or money laundering routes to terrorist organizations and by employing measures to 

prevent the use of illicit drugs as barter for munitions to support terrorism.111 In order to pursue 

transnational narco-terrorism cases against high-level, often foreign or foreign-located targets, DEA 

established the Counter-Narco-Terrorism Operations Center (CNTOC) within its Special Operations 

Division to manage its worldwide activities.112 CNTOC is a multi-agency section with the primary 

 

102 See United States v. Henareh, et al., Case No. 1:11-cr-00093 (Indictment) (S.D.N.Y. July 2011). 

103 See United States v. Taza Gul Alizai, 10 Cr. 799 (Indictment) (S.D.N.Y. July 2011). 

104 See DEA, Department of Justice, “FY 2014 Performance Budget Congressional Submission.” Available at 

http://www.justice.gov/sites/default/files/jmd/legacy/2014/05/16/dea-justification.pdf. 

105 Id. 106 Id. 107 Id. 108 See Footnote 89.

109 Id. 110 Id. 111 DEA, Department of Justice, “FY 2014 Performance Budget Congressional Submission.” 112 Derek S. Maltz, Special Agent in Charge of the Special Operations Division, DEA, Statement before the House 

Foreign Affairs Subcommittee on Terrorism, Non-proliferation, and Trade, “Narcoterrorism and the Long Reach of 

U.S. Law Enforcement, Part II,” November 17, 2011. Available at http://www.justice.gov/dea/pr/speechestestimony/2012-2009/111117_testimony.pdf. 

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mission of coordinating all DEA investigations and intelligence related to narco-terrorism and money 

laundering linked to terrorist organizations by sharing intelligence with its domestic and foreign 

offices.113 It forms the central hub for addressing the increase in narco-terrorism related issues and 

investigations.114 Additionally, the U.S. Attorney’s Office in the Southern District of New York (USAOSDNY) created a combined Terrorism and International Narcotics Unit to target and prosecute global 

transnational threats.115 The U.S. Attorney’s Office for the Eastern District of Virginia (USAO-EDVA) 

has also similarly restructured its office to combine units for maximum impact.116

The details of several publicly reported investigations and prosecutions, including for violations of 21 

U.S.C. §§ 959 and 960a, exemplify how terrorist organizations generate revenue from drug trafficking as 

well as the proactive whole-of-government approach of the U.S. government to combat narco-terrorism 

globally and domestically. On June 12, 2012, an international drug trafficker was sentenced to life in 

prison for conspiring to distribute heroin in the United States and using drug proceeds to fund, arm, and 

supply the Taliban.117 The defendant had been convicted on numerous narco-terrorism-related charges, 

including violations of 21 U.S.C. § 959 and § 960a. The defendant manufactured heroin in clandestine 

laboratories along Afghanistan’s border region with Pakistan and led one of the largest heroin trafficking 

organizations in the world.118 The defendant sent the drug to more than 20 countries, including the United 

States.119 Proceeds from his heroin trafficking were then used to support high-level members of the 

Taliban in furtherance of their insurgency in Afghanistan.120 

Another example of a terrorist organization benefiting from drug trafficking as well as from maintaining 

physical control over territory involves the FARC. To facilitate the movement of its cocaine into and out 

of FARC-controlled territory, the one defendant’s organization made regular payments to the FARC.121 

On April 26, 2013, the USAO-SDNY announced the extradition from Colombia of the defendant on 

charges that he conspired to import ton-quantities of cocaine into the United States, to provide material 

support to the FARC and to engage in narco-terrorism under 21 U.S.C. § 960a.122 The defendant, a 

Colombian citizen, had previously been designated a Consolidated Priority Organization Target 

 

113 Id. 114 Id. 115 Id. 116 Derek S. Maltz, Special Agent in Charge of the Special Operations Division, DEA, Statement before the House 

Foreign Affairs Subcommittee on Terrorism, Non-proliferation, and Trade, “Narcoterrorism and the Long Reach of 

U.S. Law Enforcement, Part II,” November 17, 2011. Available at http://www.justice.gov/dea/pr/speechestestimony/2012-2009/111117_testimony.pdf. 

117 Department of Justice, Press Release, “Haji Bagcho Sentenced to Life in Prison on Drug Trafficking and NarcoTerrorism Charges,” June 12, 2012. 

118 Id. 119 Id. 120 See id.; see also United States v. Haji Bagcho, Case No. 1:06-cr-00334-ESH (Sentencing Memorandum) (D.D.C. 

June 2012). 

121 See United States v. Jose Evaristo Linares Castillo, 11 Cr. 1054 (Indictment) (S.D.N.Y. March 2013). 122 Department of Justice, Press Release, “Manhattan U.S. Attorney Announces Extradition Of Alleged International 

Narcotics Trafficker Charged With Conspiring To Engage In Narco-Terrorism And To Support The FARC,” April 

26, 2013. 

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(CPOT)123 and Treasury designated him as a Specially Designated Narcotics Trafficker (SDNT) in 

February 2013 to build upon DEA’s and DOJ’s actions.124

U.S. law enforcement and regulators have also sought to penalize foreign financial institutions that are 

used to launder the proceeds of drug sales and allow terrorist organizations to benefit. For example, in 

January 2011, Treasury designated Lebanese drug trafficker Ayman Joumaa, as well as nine individuals 

and 19 entities—including three Lebanon-based exchange houses—connected to his drug trafficking and 

money laundering organization as SDNTs pursuant to the Foreign Narcotics Kingpin Designation Act 

(Kingpin Act).125 Joumaa coordinated the transportation, distribution, and sale of multi-ton shipments of 

cocaine from South America and laundered the proceeds from the sale of cocaine in Europe and the 

Middle East.126 Importantly, Hizballah derived financial support from the criminal activities of the 

Joumaa network.127 In February 2011, Treasury followed up on these actions under the Kingpin Act by 

identifying Lebanese Canadian Bank SAL (LCB) as a financial institution of “primary money laundering 

concern” under Section 311 of the USA PATRIOT Act for the bank’s role in facilitating the money 

laundering activities of the previously-designated Joumaa drug-trafficking and money laundering 

network.128 Joumaa and his Lebanon-based drug network, along with several other individuals, used LCB 

to launder drug proceeds—as much as $200 million per month – as part of its international money 

laundering network. The proceeds were laundered through various methods, including bulk cash 

smuggling operations and use of several Lebanese exchange houses that utilize accounts at LCB 

branches.129 LCB managers were also linked to Hizballah officials outside of Lebanon.130 

These targeted financial measures paved the way for additional actions taken by DOJ, which used its 

authorities to go after relevant assets it could target with law enforcement tools. In December 2011, 

Joumaa was indicted by the USAO-EDVA.131 Additionally, in December 2011, the USAO-SDNY filed a 

civil complaint seeking forfeiture of the assets of both the financial institutions involved in Joumaa’s 

scheme (including LCB) and approximately 30 U.S. car buyers and a U.S. shipping company that 

 

123 The CPOT List is a multi-agency target list of “command and control” elements of the most prolific international 

drug trafficking and money laundering organizations. 

124 See Department of Justice, Press Release, “Manhattan U.S. Attorney Announces Extradition Of Alleged 

International Narcotics Trafficker Charged With Conspiring To Engage In Narco-Terrorism And To Support The 

FARC,” April 26, 2013. Under E.O. 12978, an individual can be designated a SDNT and, as a result, have his/her 

property and interests in the U.S. blocked, for meeting the following criteria: plays a significant role in international 

drug trafficking centered in Colombia; materially assists in, or provide s financial or technological support for or 

goods or services in support of, the drug trafficking activities of SDNTs; or is owned or controlled by, or act s for or 

on behalf of, any other SDNT. 

125 Department of the Treasury, Press Release, “Treasury Targets Major Lebanese-Based Drug Trafficking and 

Money Laundering Network,” January 26, 2011. 

126 See FinCEN, Finding That the Lebanese Canadian Bank SAL Is a Financial Institution of Primary Money 

Laundering Concern,” Notice of Finding, 76 Fed. Reg. 9403, February 17, 2011. 

127 Id. 128 Id. 129 Id. 130 FinCEN, Finding That the Lebanese Canadian Bank SAL Is a Financial Institution of Primary Money 

Laundering Concern,” Notice of Finding, 76 Fed. Reg. 9403, February 17, 2011. 

131 United States v. Joumaa, Case No. 1:11-cr-00560 (Indictment) (E.D. Va. November 2011). 

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facilitated the scheme, as the proceeds of violations of IEEPA and of money laundering offenses.132 As 

part of a settlement, LCB was ordered to forfeit $102 million to the U.S. government.133 Treasury 

continued to pursue this network with additional Section 311 actions in April 2013 against two Lebanese 

exchange houses—Kassem Rmeiti & Co. For Exchange and Halawi Exchange Co.—which continued the 

Joumaa network’s money laundering work, including TBML schemes involving used car dealerships in 

the United States and consumer goods from Asia, after Treasury’s actions against LCB.134

The various law enforcement and regulatory actions involving Joumaa, LCB and Lebanese exchange 

houses described above also highlight how terrorist organizations have financially benefited from TBML 

schemes originating in the United States. As detailed in the National ML Risk Assessment, TBML is 

used to disguise the origin of criminal proceeds through trade-related financial transactions, and includes 

a variety of schemes that can involve moving illicit goods, falsifying trade documents, and 

misrepresenting trade-related financial transactions with the purpose of disguising the origin of criminal 

proceeds and integrating the funds into the international financial system. Ayman Joumaa and other 

individuals involved in the drug trafficking and money laundering scheme described above used LCB and 

various Lebanese exchanges houses to facilitate wire transfers in furtherance of TBML schemes 

originating in the United States 135 As noted above, Hizballah indirectly derived financial support from 

the criminal activities of the Joumaa network, and members of this network were known to be supporters 

of Hizballah.136 

Risk Summary 

Given the important role that U.S. domestic demand plays in the global drug market, drug trafficking as a 

source of funding for terrorist groups, including the Taliban, FARC and Hizballah, presents a residual risk 

for TF. 

c. Additional Criminal Activity: Extortion, Fraud and Smuggling 

Aside from narco-trafficking and KFR, terrorists and terrorist organizations also engage in criminal 

activities for financial benefit. While such broad criminal activity occurs on a global scale, DOJ 

prosecutions demonstrate a U.S. nexus in some instances, as approximately 17 percent of the TF-related 

prosecutions and cases surveyed involved smuggling or fraudulent activity being used to raise funds for a 

terrorist organization.137 Specifically, a cross reference of BSA reporting linked to FBI CT investigations 

has demonstrated that some established terrorist groups, especially Hizballah, are more involved in 

 

132 United States v. Lebanese Canadian Bank SAL et al., Case No. 1:11-cv-09186 (Complaint) (S.D.N.Y, December 

2011). 

133 Department of Justice, Press Release, “Manhattan U.S. Attorney Announces $102 Million Settlement Of Civil 

Forfeiture And Money Laundering Claims Against Lebanese Canadian Bank,” June 25, 2013.

134 See FinCEN, Notice of Finding That Kassem Rmeiti & Co. Is a Financial Institution of Primary Money 

Laundering Concern, Notice of Finding, 78 Fed. Reg. 24593, April 25, 2013; see also FinCEN, Notice of Finding 

That Halawi Exchange Co. Is a Financial Institution of Primary Money Laundering Concern, Notice of Finding, 78 

Fed. Reg. 24596, April 25, 2013. 135 FinCEN, Finding That the Lebanese Canadian Bank SAL Is a Financial Institution of Primary Money 

Laundering Concern, Notice of Finding, 76 Fed. Reg. 9403, February 17, 2011. 

136 Id. 137 See Footnote 89. 

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criminal activity in the United States than other groups.138 For example, Hizballah supporters in the 

United States historically used interstate cigarette smuggling to generate revenue that they then provided 

to Hizballah.139 These cases involved the highly profitable but illegal business of smuggling cigarettes 

across state lines, from a state with a low cigarette tax to a state with a high cigarette tax.140 Also, U.S. 

law enforcement has observed that as some terrorist groups find success with a criminal scheme, other 

groups will copy that scheme and use it for fund-raising purposes. 

Terrorists and terrorist organizations may also use legitimate commercial enterprises in the United States 

to raise funds. Several law enforcement investigations and prosecutions have found a nexus between a 

commercial enterprise, including used car dealerships and restaurant franchises, and terrorist 

organizations, where revenue by the commercial enterprise was being routed to support a terrorist 

organization. However, given that these criminal cases are based around criminal conduct not involving 

terrorist organizations, such as bank or tax fraud, the connection to the terrorist organization may not be 

disclosed in the public charging documents. 

The following case provides an example of smuggling being used to provide financial support to a 

terrorist organization, specifically Hizballah, and demonstrates how criminal activity can be a lucrative 

source of TF. In February 2010, U.S. authorities indicted four men and three businesses on charges 

relating to the export of hundreds of thousands of dollars’ worth of electronics to Hizballah. The four 

men were indicted on charges for conspiring to smuggle goods to an import-export business located in the 

Galeria Page mall in Ciudad de Este, Paraguay.141 Galeria Page serves as a source of fundraising for 

Hizballah and is locally considered to be the central headquarters for Hizballah members in the tri-border 

area between Paraguay, Brazil, and Argentina.142 As such, the mall and all businesses inside were 

designated as SDGTs in 2006.143 Three of the defendants were owners of freight-forwarding companies 

based in Florida and a fourth man owned the import-export business in Paraguay. One defendant used 

wire transfers to move funds to a bank in New Jersey from which he could pay for orders of videogame 

consoles. These wire transfer payments were routed through various financial institutions in order to 

mask their true origin. The three other defendants attempted to export the video game consoles by 

concealing the contents and destination of the shipments through falsified documents.144 

Although less prevalent, fraud has also been used in the United States as a way to raise funds in support 

of terrorist organizations. In 2007 and 2008, for example, Khalid Ouazzani, a Moroccan-born U.S. 

 

138 Information derived from an analysis of financial institution BSA reporting cross-referenced with law 

enforcement investigations. 

139See Michael Taxay, United States Attorneys’ Bulletin, Vol. 62, No.5 (September 2014), “Terrorist Financing: 

Trends in the Prosecution of Terrorist Financing and Facilitation.” Available at 

http://www.justice.gov/usao/eousa/foia_reading_room/usab6205.pdf. A recent review of law enforcement 

investigations and cases found that Hizballah no longer employs interstate cigarette smuggling in the United States 

as a major fundraising tool. 

140 See, e.g, United States v. Hammoud, 381 F.3d 316, 331–34 (4th Cir. 2004) (conviction for providing material 

support or resources to Hizballah). 141 See United States v. Mehdi et al., Case No. 1:09-cr-20852-ASG-3,5,7 (Indictment) (S.D. Fla. October 2009). 142 Department of the Treasury, Press Release, “Treasury Targets Hizballah Fundraising Network in the Triple 

Frontier of Argentina, Brazil, and Paraguay,” December 6, 2006. 

143 Id. 144 See United States v. Mehdi et al., Case No. 1:09-cr-20852-ASG-3,5,7 (Indictment) (S.D. Fla. October 2009). 

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citizen living in Kansas City, Missouri, provided more than $23,000 to AQ that were the proceeds of 

fraudulent activities.145 Similarly, although extortion is a TF tactic that is more prevalent internationally 

than within the United States, it has been used against U.S. individuals and entities as well. Notably, in 

2007, a U.S. corporation pleaded guilty to engaging in unlicensed transactions with a SDGT and paid a 

criminal fine of $25 million.146 The plea agreement arose from millions of dollars’ worth of payments 

that were made for years to the United Self-Defense Forces of Colombia to avoid harm to personnel and 

property. These payments were made by check and cash. Payments were directed by complicit corporate 

executives and continued even after attention had been called to the illegal activity by outside counsel.147

As described in the examples above, U.S. law enforcement and the DOJ have brought criminal cases 

under a variety of statutes where the proceeds of criminal activity are used to fund the activities of a 

terrorist organization.148 In addition to criminal prosecutions and civil charges, the DOJ has also used 

asset forfeiture laws to seize and forfeit significant assets that would otherwise be used to provide support 

to terrorist organizations. For example, one forfeiture provision, Section 981(a)(1)(G), allows for both 

criminal and civil forfeiture of all assets related to terrorism.149 Indeed, this forfeiture provision expressly 

enables law enforcement to seize and forfeit all assets, wherever located, of anyone engaged in planning 

or perpetrating acts of terrorism—regardless of whether the property was involved in the terrorist activity 

or is otherwise traceable to that activity, as required by most other forfeiture statutes.150 Another forfeiture 

provision allows for the forfeiture of funds traceable to other offenses, including violations of IEEPA and 

AML laws.151 A third provision provides for the forfeiture of property involved in money laundering.152 

A fourth provision allows for the forfeiture of funds in correspondent accounts to serve as a substitute for 

forfeitable funds held abroad.153 These statutes have been used against a variety of entities that have 

facilitated TF, including against LCB and U.S.-based entities controlled by the Government of Iran.154 

Risk Summary 

As the statistics and cases presented in this section indicate, terrorists and their facilitators use a variety of 

criminal activities as a means of raising funds. Although smaller scale criminal activity such as fraud is 

certainly used to raise money, the instances of larger international criminal activity such as drug 

trafficking pose a risk because of the significant sum of funds involved. For these reasons, KFR poses a 

 

145 See United States v. Khaled Ouazzani, Case No. 10-00025-01-CR-W-HFS (Indictment) (W.D. Mo. February 

2010). Ouazzani pled guilty to bank fraud for submitting false financial information to obtain a business loan, the 

proceeds of which were later provided for the use and benefit of AQ. Other TF cases have involved the use of tax 

and credit card fraud. 

146 Department of Justice, Press Release, “Chiquita Brands International Pleads Guilty to Making Payments to a 

Designated Terrorist Organization And Agrees to Pay $25 Million Fine,” March 19, 2007. 

147 Id.; see also United States v. Chiquita Brands Int’l, Inc., Case No. 1:07-cr-00055 (D.D.C. March 19, 2007). 

148 See Sharon Cohen Levin and Carolina A. Fornos, United States Attorneys’ Bulletin, Vol. 62, No.5 (September 

2014), “Using Criminal and Civil Forfeiture to Combat Terrorism and Terrorist Financing,” (citing cases). 

149 See 18 U.S.C. § 981(a)(1)(G). 

150 Sharon Cohen Levin and Carolina A. Fornos, United States Attorneys Bulletin, Vol. 62, No.5 (September 2014), 

“Using Criminal and Civil Forfeiture to Combat Terrorism and Terrorist Financing.” 

151 See 18 U.S.C. § 981(a)(1)(C). 

152 See id. § 981(a)(1)(A). 

153 See id. § 981(k). In order to transact in U.S. dollars, most foreign banks maintain accounts at U.S. banks. Such 

accounts are called “correspondent accounts.” 

154 See Michael Taxay, United States Attorneys Bulletin, Vol. 62, No.5 (September 2014), “Terrorist Financing: 

Trends in the Prosecution of Terrorist Financing and Facilitation.” 

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significant global TF risk. Additionally, the criminal activity is not limited to a single group or a single 

type of crime. As the cases demonstrate, numerous terrorist groups can be implicated in the same drug 

trafficking activity and, as Hizballah demonstrates, a single group can be involved in numerous types of 

criminal activity. Although much of this activity occurs globally, the cases in which U.S. persons are 

implicated demonstrate that this activity poses a TF risk to the United States as well. This TF risk is 

likely to persist as terrorists continue to rely on criminal activity for sources of financing, especially if 

other sources of TF are successfully combated. 

2. MISUSE OF CHARITABLE155 ORGANIZATIONS AND INDIVIDUALS RAISING FUNDS 

UNDER THE AUSPICES OF CHARITABLE GIVING

Globally, terrorist groups and their supporters continue to take advantage of charitable organizations and 

charitable giving to exploit donations and operations to support terrorist activities. The abuse of Nonprofit Organizations (NPOs) to facilitate TF is an area of focus for the FATF, the G-7, and the UN, as 

well as national authorities in many regions, including the United States. As called for in the FATF 

international standards, the United States assesses, monitors, and takes necessary actions to protect the 

large, diverse U.S. charitable sector and charitably minded donors from terrorist abuse on an ongoing 

basis using a risk-based approach. As will be described in more detail below, the United States engages a 

wide variety of agencies and authorities to promote effective supervision of the relevant sections of the 

charitable sector that are most at risk as well as to obtain information about specific threats to the sector 

and consider appropriate actions to take. New information related to specific cases and analyses of trends 

are reviewed by relevant government authorities on an ongoing basis to work towards preventing TF and 

taking action when such abuse is identified. 

a. Charitable Organizations 

FATF defines NPOs to be “a legal person or arrangement or organization that primarily engages in raising 

or disbursing funds for purposes such as charitable, religious, cultural, educational, social or fraternal 

purposes, or for the carrying out of other types of “good works.” In the United States, to facilitate 

fundraising, these types of NPOs falling within the FATF definition generally apply for tax-exempt status 

with the IRS, which permits their donors to deduct funds donated on their income tax returns, and are 

regulated as “tax-exempt charitable organizations”156 by the IRS, which generally includes the annual 

filing of required forms and disclosures. Some organizations, such as houses of worship, are not required 

to apply for exempt status with the IRS or file annual information reports, but they may need to register 

and make annual filings with state authorities to comply with state and/or local fundraising requirements. 

Other organizations, such as taxable non-profit organizations or for-profit organizations, may raise funds 

 

155 The term “charitable” as used herein is intended in its broadest sense, to include charitable, humanitarian, 

religious, educational, and other organizations and philanthropic individuals, and unless otherwise indicated, is not 

limited to organizations that the IRS has determined are tax-exempt charitable organizations under Section 501(c)(3) 

of the IRC. 

156 Qualified tax-exempt organizations obtain their tax-exempt status under Section 501(c)(3) of the IRC. Such 

organizations are religious, educational, charitable, scientific, or literary organizations; testing for public safety 

organizations; and organizations preventing cruelty to children or animals, or fostering national or international 

amateur sports competition. The IRC provides tax-exemption for certain non-charitable organizations, such as 

social welfare organizations under Section 501(c)(4) and business leagues under 501(c)(6). 

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without applying for tax-exempt status, but like all institutions they must file tax returns with the IRS, 

regardless of their taxable status. 

The IRS, which administers federal tax laws and regulations related to tax-exempt charitable 

organizations, looks to various organizational factors and the structure of an organization to determine the 

level of TF risk posed, including the activities, domestic and cross-border, conducted by the tax exempt 

organization, its mission statement and filings, financial transactions such as assets held by the taxexempt organization, donations and expenditures. 

i. Nature of the TF Vulnerability of Charitable Organizations 

Based on a review of publicly-available information on U.S. law enforcement cases involving terrorism 

and TF offenses, information obtained from financial institution reporting and Treasury designations of 

charitable organizations for financing terrorist organizations,157 some charitable organizations, 

particularly those based or operating in high-risk jurisdictions, continue to be vulnerable to abuse for TF. 

An analysis of the TF-related investigations and prosecutions surveyed for this assessment found that 

fundraising through charitable organizations accounted for about 20 percent of the overall observed 

methods of fundraising for terrorist organizations.158 As of December 31, 2014, Treasury has designated 

54 charities, along with some additional branches and associated individuals, for their support to terrorist 

organizations under Executive Order (E.O.) 13224.159 Out of these global designations, the United States 

has designated eight charities with operations in the United States.160 Also, U.S. financial intelligence 

derived from the analysis of financial institution reporting filed with FinCEN demonstrates the potential 

abuse of charitable organizations globally by terrorists, terrorist organizations, and those associated with 

or supporting them to raise, move, and place funds in the U.S. financial system.161 Since 2003, there have 

been an increasing number of SARs filed that include charitable organizations as the subject, with more 

than 5,000 SARs filed in 2013.162 

 

The extent of the TF risk for charitable organizations in the United States varies dramatically depending 

on the operations and activities of the charitable organization. For example, there are approximately one 

million charitable organizations163 in the United States that have been determined by the IRS to be 

eligible for tax-exempt status, the vast majority of which pose little or no TF risk. However, for those 

 

157 A list of charitable organizations designated by Treasury is available at http://www.treasury.gov/resourcecenter/terrorist-illicit-finance/Pages/protecting-fto.aspx. 

158 See Footnote 89. 

159 See OFAC, 2014 Terrorist Assets Report. In total, as of December 31, 2014 there are 894 individuals and entities 

designated under E.O. 13224 that remain on the Specially Designated Nationals and Blocked Persons (SDN) list for 

being owned or controlled by, acting for or on behalf of, or providing support or services to a SDGT, usually also a 

designated FTO. 

160 See Department of the Treasury, Resource Center, “Designated Charities and Potential Fundraising Front 

Organizations for FTOs.” Available at http://www.treasury.gov/resource-center/terrorist-illicitfinance/Pages/protecting-fto.aspx. 

161 Information derived from an analysis of financial institution BSA reporting. 162 Id. 163 Of approximately 1.6 million entities that the IRS has determined are eligible for tax-exempt status, 

approximately one million are “charitable organizations.” See IRS Pub. 55B, Data Book (2013), Table 25 at p. 56. 

Available at http://www.irs.gov/pub/irs-soi/13databk.pdf. This does not count charitable organizations, like houses 

of worship, which are not required to apply for tax-exemption or file annual information returns. 

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charitable organizations with U.S. tax exemption operating abroad or with overseas branches, particularly 

in high-risk areas where terrorist groups are most active, such as Pakistan, Somalia and Syria, the risks 

can be significant, highlighting the importance of accountability of charitable funding. Terrorist groups 

and their supporters continue to take advantage of charitable organizations to infiltrate the charitable 

sector and exploit donations and operations to support terrorist activities. 

Terrorist groups and their supporters may seek to exploit charities and charitable giving for a number of 

reasons. Charities can be established or otherwise used to provide a veil of legitimacy needed to cover 

the movement of funds, personnel, military supplies, and other resources by terrorist groups and their 

associates, including to high-risk areas where they operate. 

There have been many examples around the world of charities that have been integral components of 

terrorist networks. Examples include: the Revival of the Islamic Heritage Society (RIHS), which 

Treasury designated for providing financial and material support to the AQ network; FIF, which Treasury 

designated for providing financial support to LT; the Al-Waqfiya Al-Ri’aya Al-Usra Al-Filistinya Wa AlLubnanya, which Treasury designated for providing financial support to Hamas; and the Iranian 

Committee for the Reconstruction of Lebanon, which Treasury designated for providing financial, 

material and technical support to Hizballah.164

Terrorist exploitation of charities and charitable giving has not been limited to organizations located 

overseas. There have been several examples of terrorist groups and their support networks raising funds 

through charities in the United States as well. For example, Treasury designated the Tamils 

Rehabilitation Organization (TRO) on November 15, 2007 for serving as a front to facilitate fundraising 

and procurement for the designated terrorist group Liberation Tigers of Tamil Eelam (LTTE).165 In the 

United States, TRO raised funds on behalf of the LTTE through a network of individual representatives. 

TRO also facilitated LTTE procurement operations in the United States, including the purchase of 

munitions, equipment, communication devices, and other technology for the LTTE. TRO’s efforts 

worldwide reportedly allowed the LTTE to use humanitarian aid, which TRO collected from the 

international community after the December 2004 tsunami, to launch new campaigns to strengthen 

LTTE’s military capacity.166 In addition to the Treasury designations, a number of TRO affiliated 

criminal prosecutions also took place between 2006 and 2009.167 Most notably, the director of the 

American branch of the TRO, who pleaded guilty to conspiring to provide material support to a terrorist 

 

164 Department of the Treasury, Resource Center, “Protecting Charitable Giving: Frequently Asked Questions,” June 

4, 2010. Available at http://www.treasury.gov/resource-center/terrorist-illicitfinance/Documents/Treasury%20Charity%20FAQs%206-4-2010%20FINAL.pdf. 

165 Department of the Treasury, Press Release, “Treasury Targets Charity Covertly Supporting Violence in Sri 

Lanka, November 15, 2007. 

166 Id. 167 Indictment documents charged over 10 defendants with a range of legal violations including conspiracy to 

provide material support to a designated FTO [LTTE], conspiracy to bribe a public official, attempt to obtain 

classified material, violations of the International Emergency Economic Powers Act (IEEPA), conspiracy to export 

prohibited arms and munitions, attempt to export prohibited arms and munitions, international money laundering 

and possession of arms in the commission of a felony. See, e.g., United States v. Thavaraja, 740 F.3d 253, 254 (2d 

Cir. 2014).

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organization, oversaw and directed the LTTE’s various activities in the United States , including raising 

millions of dollars for the LTTE and laundering it through the TRO.168

 

Evidence suggests that terrorists and their support networks are aware of the ways in which charitable 

organizations can be abused as a cover to raise, move, and use funds and actively seek to exploit them. In 

a recent investigation, one defendant noted to a confidential informant that he “was involving himself in a 

non-profit from which he could build resources and money which he could then siphon away and provide 

to the brothers fighting in Afghanistan,” adding that “the reason for the use of a non-profit is because 

when he has attempted [to] send money by other means he has immediately been questioned as to where 

the money is going.”169

 

While some terrorist supporters create sham charities as a cover to raise and move funds, other terrorist 

groups and their supporters use charities to provide funds or otherwise dispense critical social or 

humanitarian services to vulnerable populations in an effort to radicalize communities and build local 

support. Charities established or controlled by terrorist groups and persons assisting their causes can help 

fund the operation of schools, religious institutions, and hospitals that may create fertile recruitment 

grounds or generate dependency among vulnerable populations for these essential services. For example, 

from 1993 through 2001, the Holy Land Foundation for Relief and Development (HLF) operated as the 

chief U.S. fundraising arm of Hamas. As noted by one U.S. court, “[t]he financial link between the Holy 

Land Foundation and Hamas was established at the foundation’s genesis and continued until it was 

severed by the Government’s intervention in 2001.”170 U.S. prosecutors demonstrated at trial that HLF 

intentionally cloaked its financial support for Hamas by funneling money through Zakat Committees and 

Charitable Societies in the West Bank and Gaza.171 In some cases, the defendants targeted financial aid 

specifically for families related to well-known Hamas operatives who had been killed or jailed. In this 

manner, the defendants effectively rewarded past and encouraged future terrorist activities. After a jury 

trial, HLF’s principals were convicted of providing material support to a FTO, as well as tax and money 

laundering violations, and received substantial terms of imprisonment (the longest being 65 years), and 

the organization was ordered to forfeit over $12 million.172

ii. U.S. Government Efforts to Mitigate Vulnerabilities Against TF Abuse of Charitable 

Organizations 

Recognizing the past TF threats and vulnerabilities associated with abuse of the charitable organizations, 

the U.S. government has taken enforcement actions when appropriate against both charitable 

organizations and individuals, strengthened oversight and internal coordination, and conducted sustained 

outreach to the charitable sector and donor communities to raise awareness of the vulnerability and 

provide guidance on risk mitigation best practices. 

 

168 See Department of Justice, Press Release, “Four Plead Guilty To Conspiring To Provide Material Support To The 

LTTE, A Foreign Terrorist Organization,” June 9, 2009. 

169 New York v. Humayoun Ghoulam Nabi and Ismail Alsarabbi, Q13800646, Q13800647 (Complaint) (N.Y. Crim. 

Ct. October 10, 2013). 

170 United States v. El Mezain, 664 F.3d 467, 484 (5th Cir. 2011). 171 See Michael Taxay, United States Attorneys’ Bulletin, Vol. 62, No.5, (September 2014), “Terrorist Financing: 

Trends in the Prosecution of Terrorist Financing and Facilitation.” 

172 Id. 

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Criminal and Civil Prosecutions 

In the aftermath of the September 11, 2001 terrorist attacks, the DOJ has investigated, prosecuted and 

convicted several large charities and/or their principals, including the Benevolence International 

Foundation , HLF, the Islamic American Relief Agency (self-described as the U.S. affiliate of the Islamic 

African Relief Agency), the Child Foundation, TRO, and Care International.173 These organizations were 

convicted of violations of multiple statutes criminalizing TF, including providing material support to a 

FTO and violations of U.S. economic sanctions.174 

In addition to prosecuting charitable organizations under statutes criminalizing TF, the DOJ and other 

LEAs can also utilize authorities under the IRC to impose additional criminal and civil liability on taxexempt charitable and taxable organizations that provide support to terrorist organizations. For example, 

DOJ’s Tax Division, which provides assistance in TF cases involving criminal violations of the IRC, may 

prosecute entities that conceal their affiliation with a terrorist organization, either an FTO or SDGT, or 

their affiliation with a foreign entity connected to an FTO or SDGT, through the filing of false tax forms 

with the IRS.175 Likewise, the IRS may revoke the tax-exempt status of an organization, including one 

affiliated with terrorism, that omitted or misstated a material fact or operated in a manner materially 

different from that originally represented.176 In that situation, a charity would lose its coveted tax-exempt 

status, and its financial affiliations with terrorist organizations may be exposed. Also, the IRS publicly 

suspends the tax-exempt status of any organization designated as an FTO, Specially Designated Terrorist 

(SDT), or SDGT.177 This loss and exposure probably would cause its donor base to shrink, depriving the 

affiliated terrorist organization of a key source of funding.178 

A 2011 U.S. Court of Appeals decision upholding the conviction of three officers of Care International 

for several criminal violations of the IRC, including willfully filing false tax returns, demonstrates the 

potential effectiveness of this type of criminal prosecution.179 In particular, the court noted that Care 

International’s failure to disclose its publication of the pro-jihad newsletter, “Al-Hussam,” and its 

financial support of orphans, which was in support of the children of deceased terrorists, was sufficient to 

justify a conviction for intentionally failing to disclose activities that were not previously reported to the 

IRS on earlier tax returns or Care International’s tax exempt application.180 The use of this particular 

strategy to investigate and prosecute tax-exempt charitable organizations alleged to be involved in TF is 

made by the relevant law enforcement agencies and DOJ on a case-by-case basis. 

 

173 Id. 174 See e.g., United States v. El Mezain, 664 F.3d at 484 ; See United States v. Islamic African Relief Agency, No. 07-

00087-01/07-CR-W-NKL at *15 (Second Superseding Indictment) (W.D. Mo. 2007). 

175 See e.g., United States v. Mubayyid, 658 F.3d 35 (1st Cir. 2011). 176 See 26 C.F.R. § 601.201(n)(6)(i). 177 See 26 U.S.C. § 501(p). 178 See Corey J. Smith, United States Attorneys’ Bulletin, Vol. 6, No. 3 (May 2013), Tax Enforcement II, “Terrorism 

Tax Evasion: Using Criminal Tax Charges to Combat the Use of Charities in Terrorism Financing.” 

179 See United States v. Mubayyid, 658 F.3d 35 (1st Cir. 2011). 180 See Corey J. Smith, United States Attorneys’ Bulletin, Vol. 6, No. 3 (May 2013), Tax Enforcement II, “Terrorism 

Tax Evasion: Using Criminal Tax Charges to Combat the Use of Charities in Terrorism Financing” (citing United 

States v. Mubayyid, 658 F.3d 35 (1st Cir. 2011). 

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NPO Reporting Requirements 

In addition, the IRS as the U.S. tax regulator has increased reporting requirements for some tax-exempt 

organizations in order to enhance transparency and mitigate TF risk within the charitable sector. Any 

U.S.-based charitable organization that wants to maintain its status as a tax-exempt entity under IRC 

section 501(c)(3), including foreign charitable organizations desiring tax-exempt status in the United 

States, must make annual information filings with the IRS.181 The IRS redesigned Form 990 in 2008 to 

include more information regarding tax exempt organizations’ stated mission, programs and finances, 

including a wide range of information about donors, activities and funds sent and used abroad that are 

required on Schedule F of Form 990.182 The redesigned form includes (1) a checklist to show which 

schedules the filing organization must complete, thereby simplifying the core form, (2) provides more 

opportunity throughout the form for supplemental information, (3) contains revised governance and 

compensation sections, and (4) has modified other areas of the form, including non-cash contributions and 

supplemental financial information. 

Monitoring of financial reports for transparency and accountability by the IRS may lead to further 

investigations that provide more insight into potential underlying illicit actions, including TF. IRSTE/GE examines tax-exempt organizations for compliance with the U.S. tax laws, including reviewing 

the reporting forms, and IRS-CI conducts criminal investigations, as they become necessary. Within IRSTE/GE is also a financial investigations unit composed of forensic investigators and specialists with 

specific financial expertise to pursue cases of potential misuse of charities for a range of purposes, 

ranging from fraud and tax evasion to illicit finance.183 More complex illicit finance cases are handled in 

cooperation with other relevant U.S. government agencies and offices. 

Outreach to the Charitable Sector 

In addition to better annual reporting and continued enforcement actions when terrorist threats have been 

identified within the charitable sector, the federal government continues to engage in direct outreach to 

the charitable sector and donor communities by raising awareness of the risk of terrorist abuse of 

charitable organizations and providing guidance on risk mitigation best practices and efforts to protect the 

sector from terrorist abuse. As part of this effort, Treasury provides guidance for charities and donors to 

help protect themselves against such TF abuse and has published a number of resource documents for the 

sector, including a risk matrix, voluntary charitable guidelines and best practices, frequently asked 

questions, and specific guidance regarding certain sanctions programs and/or global developments, such 

as sending humanitarian assistance to Somalia, Syria and Iran.184 In October 2014 OFAC issued 

 

181 See IRS, Compliance Guide for Public 501(c)3 Charities. Available at http://www.irs.gov/pub/irspdf/p4221pc.pdf. 

182 See IRS, Chronological History: Redesign of the 2008 Form 990 and Corresponding Instructions. Available at 

http://www.irs.gov/Charities-&-Non-Profits/Charitable-Organizations/Chronological-History:-Redesign-of-the2008-Form-990-and-Corresponding-Instructions. 

183 Any matter criminal in nature, as stated above (to include tax evasion, illicit finance and fraud) is investigated by 

IRS-CI with technical assistance provided by IRS’s TE/GE financial investigations unit. For criminal investigations, 

TE/GE’s financial investigations unit renders technical assistance to IRS-CI on accounting, tax law, and procedural 

issues regarding charities and other NPOs. 

184 See Department of the Treasury, Resource Center, “Protecting Charitable Organizations.” 

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humanitarian guidance for charities and donors working in a variety of high risk environments in which 

sanctions are in place.185 

The governmental and charitable sector share the same goal of protecting and promoting safe charitable 

giving. Recognizing this shared goal and the vulnerability faced by the sector to terrorist abuse, many 

charitable organizations have also strengthened their internal controls and procedures over the years, 

including through the use of Treasury’s voluntary charitable guidelines.186 There have been greater selfregulation initiatives within the sector to help promote greater transparency and accountability of funding 

and operations, including screening public terrorist lists and having more robust due diligence measures 

in place to help protect against diversion of funds and essential services that may be used to support 

terrorist organizations.187 Some charitable organizations operating overseas have developed sophisticated 

internal controls and procedures, including end use monitoring systems, in an effort to prevent misuse of 

funding and services. In addition to U.S. government enforcement action, reporting requirements and 

outreach efforts described above, these measures help mitigate TF risk in the sector. 

Risk Summary 

Through a combination of targeted enforcement action, focused oversight, sustained outreach, and 

extensive international engagement and cooperation to address global terrorist threats in the charitable 

sector, the U.S. government, working with the charitable sector, has reduced the opportunity for U.S. 

charitable organizations to be abused to facilitate financial support for terrorist groups. However, given 

the large size and diversity of the U.S. charitable sector and its global reach, the sector remains vulnerable 

to abuse. 

b. Individuals Fund Raising Under the Auspices of Charitable Giving 

At the same time, based on financial institution reporting and a review of publicly-available information 

on U.S. law enforcement cases involving TF, the United States has seen an increase in fundraising under 

the auspices of charitable giving, particularly by individual fundraisers, without the use of specific 

charitable organizations. In the survey of law enforcement cases mentioned above, the second largest 

grouping of cases, approximately 24 percent, involved individuals raising proceeds on behalf of 

humanitarian causes without a link to an established charitable organization.188 This method of soliciting 

donations has also taken on an increasing importance for terrorist groups. Of the cases examined, only 

 

185 See OFAC, Guidance Related to the Provision of Humanitarian Assistance by Not-for-Profit Non-Governmental 

Organizations, October 17, 2014. In the case of targeted financial sanctions administered by OFAC, in certain 

instances, OFAC may use its authority to license transactions that otherwise would be prohibited, when doing so 

would further U.S. foreign policy. OFAC regularly promulgates in its regulations what are known as “general 

licenses” authorizing certain categories of otherwise prohibited activity for all those who meet its terms, and it also 

grants specific licenses on a case-by-case basis. For additional information regarding the applicability of targeted 

financial sanctions to charitable organizations, see Department of the Treasury, Protecting Charitable Giving: 

Frequently Asked Questions, June 4, 2010. 

186 See Department of the Treasury, Anti-Terrorist Financing Guidelines: Voluntary Best Practices for U.S.-based 

Charities, September 2009. Available at http://www.treasury.gov/resource-center/terrorist-illicitfinance/Documents/guidelines_charities.pdf. 

187 See FATF, Risk of Terrorist Abuse in Non-Profit Organisations, June 2014. 188 See Footnote 89. 

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four cases prior to 2006 involved such fundraising, while there have been 14 cases involving this type of 

activity since then. 

In several of the cases examined, terrorist financiers acting as individual fundraisers preyed on unwitting 

donors’ good intentions and at times specifically targeted certain diaspora communities. These terrorist 

facilitators seek to avoid the oversight and reporting necessary for formal charitable organizations and 

instead solicit funds under the auspices of charity, but are unaffiliated with any charitable organization 

recognized by the U.S. government, then divert the proceeds to fund terrorist activity. 

U.S. law enforcement has responded to these emerging trends through a nationally coordinated campaign 

of investigations and criminal prosecutions that target this specific TF method. For example, the FBI 

initiated Operation Green Arrow to stem the flow of money from the United States to Al-Shabaab and 

other insurgents in Somalia.189 These individuals used a variety of methods to raise funds for AlShabaab, including door-to-door personal solicitations and teleconferences.190 Although the amount 

raised by these individuals was not substantial compared to other TF cases (each sent approximately 

$16,000 to Somalia), it was considered an important revenue source by Al-Shabaab’s leadership, which 

routinely directly communicated with the fundraisers.191 In one case, two naturalized U.S. citizens of 

Somali origin were sentenced for providing material support to Al-Shabaab. They solicited funds in 

person in Somali communities in the United States and Canada under the false pretense that the funds 

were for the poor and needy, but the donations went to support Al-Shabaab. The individuals also 

participated in teleconferences that featured speakers who encouraged donations to support AlShabaab.192 

Following the success of Operation Green Arrow, the FBI initiated Operation Rhino, which responded to 

the threat posed by persons traveling from the United States to join Al-Shabaab in Somalia.193 The U.S. 

government identified an increase in individuals who had traveled from the United States to engage in 

violent jihad overseas, which was particularly troubling due to concern that these “travelers” will return to 

the United States battle-hardened and fully indoctrinated in violent jihad and more likely to engage in 

domestic terrorist activity.194 These travelers require facilitators, which increasingly goes hand-in-hand 

with financing. Operation Rhino resulted in charges against more than 20 travelers and facilitators and 

nine convictions to date, including facilitators who provided funds to pay for travel and weapons in 

Somalia.195 One defendant convicted for providing material support to Al-Shabaab admitted that he 

helped raise funds for Al-Shabaab from the Somali-American community in Minnesota under false 

pretenses, claiming the money raised would be used for a local mosque or to help orphans in Somalia, 

when, in fact, it was for purchasing airline tickets and paying other expenses for men who traveled from 

 

189 See Michael Taxay, United States Attorneys’ Bulletin, Vol. 62, No.5 (September 2014), “Terrorist Financing: 

Trends in the Prosecution of Terrorist Financing and Facilitation.” 

190 Id. 191 Id. 192 See United States v. Ali et al., Case No. 0:10-cr-00187 (Sentencing Memorandum) (D. Minn, April 2013). 

193 See Michael Taxay, United States Attorneys’ Bulletin, Vol. 62, No.5 (September 2014), “Terrorist Financing: 

Trends in the Prosecution of Terrorist Financing and Facilitation.” 

194 See Id. 195 See Id. (citing United States v. Omar, Case No. 09-CR-242-MJD/FLN (Report and Recommendation) (D. Minn. 

2012); United States v. Mohamed, 09-CR-352-MJD/FLN (Government’s Trial Brief) (D. Minn. 2011). 

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Minneapolis to Somalia to join Al-Shabaab.196 In a separate Al-Shabaab-related case, the defendant 

purportedly described at a gathering of co-conspirators his own plans to fight “jihad” against Ethiopians, 

and he raised money to buy airplane tickets for others to make the trip to Somalia for the same purpose.197 

In raising that money, however, he allegedly misled community members into thinking they were 

contributing money to send young men to Saudi Arabia to study the Koran.198

Another method found in U.S. prosecutions for providing material support for terrorism is the increasing 

use of the internet and social media to solicit donations that are often provided to terrorist organizations or 

their supporters. In the TF-related cases and prosecutions reviewed, online fundraising was involved in 

nine cases; in all but two of those cases, the criminal activity began after 2007.199 The ability to easily 

reach potential donors and connect with like-minded supporters helps to raise and move funds quickly, 

less transparently, and often for illicit purposes. Of the TF cases examined, nine were identified as 

including personal fundraising online or through social media, as opposed to soliciting donations through 

a formal, established organization. A FinCEN analysis of financial institution reporting showed 

individuals with alleged links to AQ, the Taliban, Hamas, and Chechen Mujahideen using personal 

PayPal accounts to collect funds for named causes.200 Several Treasury designations of terrorist 

supporters have also cited the use of social media to solicit funds.201 The Syrian conflict has seen a 

significant use of the internet and social media sites, such as Twitter and Facebook, to solicit sizable 

donations that include support to designated terrorist organizations and their supporters. A number of 

online fundraisers explicitly advertise that collected funds are being used to purchase weapons and other 

equipment for extremist groups and post videos and photos verifying the receipt of donations by fighters. 

One Kuwait-based campaign claimed to have raised enough cash to arm 12,000 fighters.202

Risk Summary 

There has been a shift in recent years towards individuals with no connections to a charitable organization 

recognized by the U.S. government soliciting funds under the auspices of charity for a variety of terrorist 

groups, including AQ, Al-Shabaab, Hamas, ISIL, and the Taliban, often online and using personal 

accounts or informal channels. This shift probably is due in part to the comprehensive, multi-faceted 

approach to preventing TF abuse of tax exempt charitable organizations, including U.S. government 

oversight, enforcement actions, outreach to and engagement with the charitable sector, and international 

cooperation. This trend highlights the need for continued outreach to the charitable sector and donor 

community on the evolving TF threats and vulnerabilities the sector faces combined with continued use of 

 

196 See United States v. Ahmed Hussain Mahamud, Case No. CR-11-191-DWF/AJB (Plea Agreement and 

Sentencing Stipulations) (D. Minn. 2012). The defendant sent money via wire transfers to a co-conspirator in 

Somalia, knowing the money would be used to purchase weapons or otherwise support Al-Shabaab. 

197 United States v. Isse et al., Case No. 0:09-cr-00050 (Third Superseding Indictment) (D. Minn. July 2010); see 

also Department of Justice, Press Release “Fourteen Charged with Providing Material Support to Somalia-Based 

Terrorist Organization Al-Shabaab,” August 5, 2010. 

198 Id. 199 See Footnote 89. 200 Information derived from an analysis of financial institution BSA reporting. 201 See Department of the Treasury, Press Release, “Treasury Designates Three Key Supporters of Terrorists in Syria 

and Iraq,” August 6, 2014. 

202See Elizabeth Dickinson, Playing with Fire: Why Private Gulf Financing for Syria’s Extremist Rebels Risks 

Igniting Sectarian Conflict at Home, p. 13, December 6, 2013 (Brookings Institution). 

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existing government authorities to investigate, prosecute, or sanction those individuals abusing charitable 

organizations or charitable giving for TF. 

 

3. INDIVIDUAL CONTRIBUTIONS/SELF-FUNDING 

In addition to raising funds through charitable organizations or causes, as described above, terrorist 

groups also benefit from funds provided directly by U.S. citizens. An analysis of TF-related law 

enforcement cases and prosecutions since 2001 found that direct financial support from individuals to 

terrorist networks occurred in approximately 33 percent of the cases reviewed.203 In these cases, U.S. 

citizens or residents were observed soliciting funds to support their own planned terrorist activity, 

including paying for their travels and living expenses to fight alongside terrorist groups overseas. In 

2006, a U.S. citizen, Kobie Williams, pleaded guilty to conspiring to train with firearms in preparation to 

join the Taliban as well as contributing several hundred dollars to the Taliban to further this effort.204 

Recently, another U.S. citizen, Michael Todd Wolfe, was indicted by a federal grand jury for attempting 

to provide material support to ISIL.205 Wolfe allegedly planned to travel to the Middle East to provide his 

services to radical groups engaged in armed conflict in Syria, using an expected tax refund of $5,000 to 

cover his travel expenses. Of particular concern is that these homegrown violent extremists may use this 

type of activity to fund domestic terrorist activity in support of extremist ideology espoused by a terrorist 

group, but without direct assistance from the terrorist group. 

U.S. authorities have also observed foreign persons directly soliciting U.S. residents for financial and 

non-cash contributions to terrorist groups, frequently using social media. For example, Babar Ahmad, a 

UK resident, established and operated a family of websites known as Azzam Publications to enable 

individuals, including U.S. residents, to contribute directly to terrorist groups.206 Through those sites, 

which espoused the rhetoric of violent jihad, Ahmad solicited contributions from U.S. residents of funds, 

equipment, and personnel for a variety of terrorist groups, including the Taliban.207 U.S. officials 

successfully extradited Ahmad from the UK, and he pleaded guilty in 2013 to conspiracy to provide and 

actually providing funds, physical items, and personnel to the Taliban.208

Although these cases tend to involve small amounts of money, they pose a domestic TF risk. U.S. law 

enforcement and regulatory authorities have aggressively sought to prevent this type of activity and take 

appropriate enforcement actions. As described above, the DOJ indicted Michael Todd Wolfe for 

providing material support to a FTO, in addition to other charges. The DOJ also indicted Mufid Elfgeeh 

for providing material support to ISIL, which included sending funds to foreign terrorist fighters who 

 

203 See Footnote 89. 204 See Department of Justice, Press Release, “U.S. Citizen Taliban Supporter Sentenced to Prison,” August 7, 2009. 205 See FBI, Press Release, “Austinite Pleads Guilty to Attempting to Provide Material Support to Terrorists,” June 

27, 2014. 

206 See Michael Taxay, United States Attorneys Bulletin, Vol. 62, No.5 (September 2014), “Terrorist Financing: 

Trends in the Prosecution of Terrorist Financing and Facilitation.” 

207 See United States v. Ahmad, No. 3:04M240-WIG (Affidavit in Support of Request for Extradition) (D. Conn. 

2003). 

208 Department of Justice, Press Release, “Two British Nationals Plead Guilty To Terrorism-related Charges In New 

Haven Federal Court,” December 10, 2013. 

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were attempting to travel to Syria to join and fight for ISIL.209 These indictments, along with others 

mentioned above, highlight the important interaction between sanctions designations and criminal liability 

for TF, as designating an entity as an FTO permits law enforcement authorities to investigate and 

prosecute individuals for providing financial support to a designated entity, without having to additionally 

demonstrate direct support for terrorist activity by the individuals’ or entities.210 

To assist these law enforcement efforts, FinCEN has automated “business rules” to search BSA reporting 

daily for key terms, entities, or typologies of national security interest. The rules are designed to screen 

daily filings and identify reports that merit further review by analysts. For example, as of May 2015, 

rules related to ISIL alone generate more than eight hundred matches each month for further review and 

exploitation. FinCEN’s analysis of this reporting has revealed new foreign terrorist fighters and their 

networks, furthering ongoing domestic and foreign law enforcement investigations. 

Risk Summary 

Nonetheless, despite the aggressive efforts of U.S. law enforcement authorities to combat such activity, 

given the small dollar value of such activity and the limited number of individuals involved, identification 

of such activity is particularly challenging. Additionally, these funds could be used to facilitate organized 

or “lone-wolf” style attacks by homegrown violent extremists or foreign terrorist fighters returning to the 

United States from Syria or Iraq. Therefore, individual donations made in the United States to terrorist 

groups or self-funding by U.S. citizens or residents poses a residual TF risk to the United States. 

 

 

209 Department of Justice, Press Release, “Rochester Man Indicted on Charges of Attempting to Provide Material 

Support to ISIS, Attempting to Kill U.S. Soldiers and Possession of Firearms and Silencers,” September 16, 2014. 210 For example, 18 U.S.C. § 2339B, the most frequently used TF criminal statute, prohibits persons from knowingly 

providing material support or resources to an FTO. This statute reflects recognition of the fact that terrorist 

organizations can have multiple wings, to include military, political, and social, and that material support to any of 

these wings ultimately supports the organization’s violent activities. 

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B. MOVING AND PLACING FUNDS: VULNERABILITIES AND RISKS 

The growth and increasing sophistication of the international financial system in recent years has enabled 

illicit actors to place and move money, hide assets, and conduct transactions anywhere in the world, 

exposing financial centers to exploitation and abuse in an unprecedented way. The United States has seen 

a wide variety of terrorist groups, including AQ and its affiliates, Al-Shabaab, Hamas and Hizballah, use 

banks211 and MSBs212 to place and transfer funds, along with cash transportation provided by cash 

couriers.213 

The AML/CFT controls required by the U.S. regulatory framework aid financial institutions in identifying 

risk, provide valuable information to law enforcement, and inform U.S. national security policy. These 

required measures include the establishment of AML programs and reporting and record keeping 

requirements to provide useful information to law enforcement and national security authorities for the 

purpose of combating the full range of illicit finance threats. An AML program must include, at a 

minimum, a system of internal controls to ensure ongoing compliance, independent testing, designation of 

an individual responsible for managing BSA compliance and training for appropriate personnel.214 An 

effective AML/CFT regime also includes enhanced due diligence procedures for those customers that 

present a high risk for money laundering or TF, as well as for the provision of foreign correspondent 

accounts and private banking services.215 However, when these safeguards are not effectively 

implemented or stringently enforced, money launderers, terrorist financiers and other illicit actors are able 

to abuse the U.S. financial system. 

The combination of a strong AML/CFT legal framework and effective supervision has succeeded in 

making it more difficult for terrorists and their facilitators to access the U.S. financial system, often 

forcing support networks to resort to costlier and/or riskier means of meeting their operational needs.216 

Terrorist groups have increasingly turned to unregulated channels, including unlicensed money 

 

211 Under the BSA, as implemented by 31 C.F.R. § 1010.100, the term “bank” includes each agent, agency, branch 

or office within the U.S. of commercial banks, savings and loan associations, thrift institutions, credit unions, and 

foreign banks. The term “bank” is used throughout this document generically to refer to these financial institutions. 

212 An MSB is defined under the implementing regulations for the BSA to be “any person doing business, whether 

or not on a regular basis or as an organized business concern, in one or more of the following capacities: (1) 

Currency dealer or exchanger; (2) Check casher; (3) Issuer of traveler's checks, money orders or stored value; (4) 

Seller or redeemer of traveler's checks, money orders or stored value; (5) Money transmitter; and (6) U.S. Postal 

Service.” 31 C.F.R. § 1010.100(ff). However, banks and securities and commodities brokers that are regulated by 

the federal functional regulators are excluded from the definition of MSB. Id. 213 For example, banks and MSBs accounted for over 90 percent of all financial institution SAR filings with the 

subject line “terrorist financing.” See FinCEN, SAR Stats. Available at http://www.fincen.gov/Reports/SARStats. 214 See, e.g., 12 C.F.R. § 21.21 (national banks); 12 C.F.R. § 208.61 (state member banks); 12 C.F.R. § 326.8 (nonmember banks); 12 C.F.R. § 748.2 (credit unions); FINRA Rule 3310 (securities broker-dealers); and National 

Futures Association Rule 2-9(c) (commodities brokers and futures commission merchants). See also Federal 

Financial Institutions Examination Council (FFIEC) BSA/AML Examination Manual (2014), pp. 28-29. Available 

at https://www.ffiec.gov/bsa_aml_infobase/documents/BSA_AML_Man_2014.pdf. 

215 See id. at 112-118 & 125-129. See also Joint Guidance on Obtaining and Retaining Beneficial Ownership 

Information, FIN– 2010–G001, March 5, 2010. 

216 See David Cohen, Under Secretary for Terrorism and Financial Intelligence, Department of the Treasury, 

Remarks before the Center for a New American Security, “Confronting New Threats in Terrorist Financing,’” 

March 4, 2014. 

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transmitters and cash couriers, to transfer and move funds. However, the capacity of banks to quickly 

facilitate large cross border transactions makes them a target for abuse by illicit actors. 

Broadly speaking, based on an analysis of U.S. law enforcement investigations and prosecutions relating 

to TF, two methods of moving money to terrorists and terrorist organizations have been predominate in 

the convictions and cases pending since 2001: the physical movement of cash and the movement of funds 

through the banking system.217 Funds moved through the banking system were placed into the banking 

system by directly depositing cash at a bank; giving cash to an individual or business operating as an 

unlicensed money transmitter who then deposits the funds into the individual’s or business’s bank 

account; or using a licensed MSB (with the help of complicit agents) to deposit funds into the licensed 

MSB’s bank account. The physical movement of cash accounted for 28 percent of these cases while 

movement directly through banks constituted 22 percent; movement through licensed MSBs 17 percent, 

and movement by individuals or entities acting as unlicensed money transmitters constituted 18 

percent.218 

Further analysis of these cases suggests that, since 2007, defendants seeking to support terrorists and/or 

terrorist groups have tended to prefer licensed MSBs and unlicensed money transmitters as a point of 

entry into the banking system over banks. More than 30 percent of the identified funds transfers in TF 

cases prior to 2007 involved movement directly through banks, but this share drops to 8 percent for cases 

in and after 2007. Concurrently, the share of funds transfers identified in TF cases by licensed MSBs 

increased substantially, from approximately 5 percent to 30 percent. Additionally, physically moving 

cash (cash smuggling) to transfer funds from the United States increased from 22 percent to 37 percent, 

suggesting a desire to avoid transactions executed through financial institutions entirely. Financial 

institution reporting also indicates that certain Sunni extremist groups, such as certain AQ affiliates and 

Al-Shabaab, tend to use MSBs, while other terrorist groups, such as Hamas and Hizballah, appear to favor 

banks as a means of transmitting funds.219 

1. BANKS 

Banks are an attractive means for terrorist groups seeking to move funds globally because of the speed 

and ease at which they can move funds within the international financial system.220 Through their global 

networks and inter-bank relationships, U.S. banks can instantly transfer funds for their customers almost 

anywhere in the world. Additionally, because of the importance of the United States to global financial 

markets activity, many foreign banks have established subsidiary branches or agencies in the United 

States to gain access to U.S.-based customers and to serve their own local customers’ needs in the United 

States. 

 

217 See Footnote 89. 

218 The remaining 15 percent were a mix of checks, wire transfers through unspecified financial institutions, and 

TBML. See Footnote 89. 

219 Information derived from an analysis of financial institution BSA reporting. Additionally, funds related to 

Hamas and Hizballah account for approximately 40 percent of the funds blocked in U.S. financial institutions 

pursuant to E.O.s 12947 and 13224 and 18 U.S.C. § 2339B(a)(2) for affiliation with a SDGT, FTO or SDT. See 

OFAC, 2014 Terrorist Assets Report. 220 See FATF, Terrorist Financing, p. 21, February 2008. 

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In light of this vulnerability, the U.S. government has implemented an AML/CFT regulatory framework 

that includes robust implementation of targeted financial sanctions, which has made it more difficult for 

terrorists and their support networks to access the U.S. financial system. This framework aids financial 

institutions in identifying and managing risk, provides valuable information to law enforcement, and 

creates the foundation of financial transparency required to apply targeted financial measures against the 

various national security threats that seek to operate within the U.S. financial system.221 

OFAC administers and enforces a vigorous sanctions regime in collaboration with the regulatory, law 

enforcement, and intelligence communities. Violators of U.S. economic sanctions can be subject to a 

range of administrative, civil and criminal penalties. The federal banking agencies222 conduct regular 

examinations of banks to ensure compliance with BSA/AML programs, including ensuring that such 

institutions have an effective BSA/AML and OFAC compliance program that: identifies higher-risk areas, 

provides for appropriate internal controls for screening and reporting, establishes independent testing for 

compliance, designates an employee or employees as responsible for OFAC compliance, and creates 

training programs for appropriate personnel.223 The SEC and CFTC impose similar requirements on 

financial institutions they supervise. 

The enactment of the USA PATRIOT Act following the September 11, 2001 terrorist attacks enhanced 

the efforts of the U.S. government to prevent the U.S. financial system from being used to facilitate TF. 

For example, under Section 311 of the USA PATRIOT Act, the Secretary of the Treasury is authorized to 

find a foreign jurisdiction, foreign financial institution, class of international transactions, or type of 

account to be of primary money laundering concern, and to subsequently impose any one or a 

combination of special measures that U.S. financial institutions must take to protect the U.S. financial 

system, including from risks associated with TF.224 These special measures range from enhanced due 

diligence, recordkeeping, and reporting requirements, up to and including, prohibition against establishing 

or maintaining any correspondent account or payable through account for or on behalf of a foreign 

financial institution, if the account involves a jurisdiction, financial institution, class of transaction, or 

type of account that is of primary money laundering concern. Treasury, through FinCEN, has utilized 

Section 311 to alert the U.S. financial system to TF threats associated with several foreign jurisdictions 

and foreign financial institutions, including: the Islamic Republic of Iran; LCB; the Commercial Bank of 

Syria (CBS) (including its subsidiary Syrian Lebanese Commercial Bank); Halawi Exchange Co.; and 

Kassem Rmeiti & Co.225 In finding that CBS was a financial institution of primary money laundering 

concern, FinCEN noted that “numerous transactions that may be indicative of terrorist financing and 

 

221 David Cohen, Under Secretary for Terrorism and Financial Intelligence, Department of the Treasury, Testimony 

before the Senate Committee on Homeland Security and Governmental Affairs Permanent Subcommittee on 

Investigations, “U.S. Vulnerabilities to Money Laundering, Drugs, and Terrorist Financing: HSBC Case History,” 

July 17, 2012. Available at http://www.hsgac.senate.gov/download/?id=55d94bbb-cbee-4a35-89ca-5493a12d73dd. 

222 For the purposes of the National TF Risk Assessment, the relevant federal banking agencies are the FRB, the 

FDIC, NCUA and OCC. 

223 The Federal Financial Institutions Examination Council (FFIEC) BSA/AML Examination Manual includes 

specific portions on compliance with OFAC’s targeted financial sanctions regime. See FFIEC BSA/AML Manual 

2014, pp. 145-154. 

224 See 31 U.S.C. § 5318A. 

225 A list of Section 311 Special Measures taken by FinCEN is available at 

http://www.fincen.gov/statutes_regs/patriot/section311.html. 

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money laundering have been observed transiting CBS,” including “several transactions through accounts 

at CBS that reference a reputed financier for Osama bin Laden.”226 

In addition to Section 311, Sections 314(a) and 319 of the USA PATRIOT Act strengthened the U.S. 

government’s ability to take specific regulatory actions to advance law enforcement investigations against 

TF threats. Section 314(a) allows law enforcement authorities to share information with financial 

institutions regarding individuals, entities, and organizations engaged in or reasonably suspected of 

engaging in terrorist acts and to determine whether the target of an investigation maintains an account at a 

particular financial institution.227 Section 319(a) enhances law enforcement’s ability to pursue assets 

overseas, while Section 319(b) provides law enforcement with summons and subpoena authority with 

respect to foreign banks that have correspondent accounts in the United States.228 

Punitive measures and, for egregious cases, financial penalties, have been applied to banks determined to 

be out of compliance. For example, in December 2012, HSBC, a UK-headquartered financial institution 

with a substantial U.S. presence, was ordered to pay a total of approximately $1.9 billion in civil money 

penalties and asset forfeitures for various violations of U.S. AML and economic sanctions laws and 

regulations.229 Furthermore, in a July 2014 settlement with U.S. regulators and law enforcement, BNP 

Paribas, in addition to having to pay a total of approximately $8.9 billion in criminal penalties and asset 

forfeitures, was subjected to a one-year long suspension of certain U.S. dollar-clearing services through 

its New York branch and other affiliates for business lines on which the misconduct centered.230 FinCEN 

has also imposed civil money penalties against U.S. branches of foreign banks for failing to implement 

adequate due diligence procedures and internal controls that effectively managed the risk arising from the 

provision of foreign correspondent accounts or dollar-clearing services to financial institutions located in 

jurisdictions deemed a high-risk for money laundering and TF.231 

Misuse of Foreign Correspondent Banking 

The regulatory and enforcement actions taken by the U.S. government and the subsequent substantial 

financial and organizational investments by U.S.-based financial institutions have improved AML/CFT 

compliance among financial institutions.232 However, the international financial system is interconnected 

 

226 FinCEN, Imposition of a Special Measure Against Commercial Bank of Syria, Including Its Subsidiary, Syrian 

Lebanese Commercial Bank, as a Financial Institution of Primary Money Laundering Concern, Notice of Proposed 

Rulemaking, 69 Fed. Reg. 28098, 28100, May 18, 2004. 

227 See 31 U.S.C. § 5318. 

228 See 18 U.S.C. § 981(k); 31 U.S.C. § 5318(k)(3). 

229 See OCC EA 2012-261, AA-EC-2012-140, December 4, 2012 and FRB Docket Nos. 12-062-CMP-FB, 12-062-

CMPHC,and 12-062-B-FB, 2-4, December 11, 2012; FinCEN, In the Matter of HSBC Bank USA, N.A. Mclean, 

Virginia, No. 2012-02, December 10, 2012; see also Senate Permanent Subcommittee on Investigations, U.S. 

Vulnerabilities to Money Laundering, Drugs, and Terrorist Financing: HSBC Case History, at 210, July 16, 2012. 

230 See Department of Justice, Press Release, “BNP Paribas Agrees to Plead Guilty and to Pay $8.9 Billion for 

Illegally Processing Financial Transactions for Countries Subject to U.S. Economic Sanctions,” June 30, 2014. 

231 See FinCEN, In the Matter of Doha Bank, New York Branch, New York, New York, No. 2009-1, April 20 2009; 

FinCEN, In the Matter of The Federal Branch of Arab Bank, PLC, New York, New York, No. 2005-2, August 17, 

2005. 

232 For example, in its deferred prosecution agreement with the DOJ, HSBC noted that it had increased AML 

compliance spending nine –fold and AML staffing ten-fold between 2009 and 2011. See HSBC Bank USA, N.A. 

and HSBC Holdings plc DPA, ¶ 5, December 11, 2012. 

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and foreign financial institutions maintain correspondent accounts at and receive services from U.S. 

financial institutions in order to access the U.S. financial system. These relationships allow financial 

institutions worldwide to facilitate cross border transactions in the currency of choice. They also enable 

financial institutions to conduct business and provide services to clients in foreign countries without the 

expense and burden of establishing a foreign presence. However, some correspondent banking 

relationships are inherently higher-risk, in large part due to the challenges of “intermediation,” where 

multiple intermediary financial institutions may be involved in a single funds transfer transaction. The 

complexity and volume of transactions that flow through U.S. correspondent accounts, coupled with the 

varying (often limited) recordkeeping requirements of funds transfer systems in different countries, 

increase the likelihood that funds associated with illicit finance, including TF, may flow through these 

accounts and into the U.S. financial system. These relationships could potentially indirectly expose a 

U.S. financial institution to risk, including TF, if the foreign financial institution does not effectively 

implement AML/CFT controls. 

To help mitigate against this risk, certain U.S. financial institutions are required to conduct due diligence 

on their foreign correspondents to ensure that the foreign correspondent’s controls are adequate to manage 

the risk to the U.S. financial institution associated with this relationship.233 These U.S. financial 

institutions are also required to conduct enhanced due diligence on certain higher risk foreign 

correspondents which requires (1) enhanced scrutiny, (2) determining whether the foreign correspondent 

maintains nested accounts for other foreign banks, and (3) the collection of beneficial owner information 

regarding foreign correspondents that are not publicly traded.234 In addition to these requirements for 

foreign correspondents, U.S. financial institutions are also prohibited from maintaining correspondent 

accounts for foreign “shell banks” (i.e., foreign banks with no physical presence in any country).235

Despite these requirements, there have been isolated and particularly egregious instances of U.S. banks 

not adequately managing potential TF risks posed by their relationships with foreign financial institutions. 

In one case, the U.S. subsidiary of a foreign parent bank was found to have failed to collect or maintain 

customer due diligence information on non-U.S. banking affiliates of the foreign parent bank for which it 

maintained correspondent accounts.236 This resulted in transactions flowing to and from the United States 

without appropriate monitoring and alerts to identify movements of funds.237 A significant number of 

non-U.S. financial institutions and their customers gained indirect access to the U.S. financial system 

without appropriate safeguards.238 These customers included foreign banks that were publicly associated 

with terrorist organizations or terrorist financing.239 

 

233 See 31 C.F.R. § 1010.610(a); FFIEC BSA/AML Manual, pp. 177-80. 

234 See 31 C.F.R. § 1010.610(b). 

235 See 31 C.F.R. § 1010.630. 

236 See FinCEN, In the Matter of HSBC Bank USA, N.A. Mclean, Virginia, No. 2012-02, December 10, 2012. 

237 Id. 238 Id. 239 See Senate Permanent Subcommittee on Investigations, U.S. Vulnerabilities to Money Laundering, Drugs, and 

Terrorist Financing: HSBC Case History, at 225, 228, July 16, 2012. 

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Risk Summary 

As noted above, U.S. financial institutions face residual TF risk when foreign correspondents are not 

subject to the same or similar regulatory guidelines as U.S. banks, or do not have in place acceptable 

AML/CFT processes or controls.240 This may be especially true where a foreign financial institution, 

based on its particular risk profile, which may include geographic profile, business line, or customer base, 

does not implement effective customer due diligence practices, suspicious activity identification 

processes, and/or recordkeeping. 

2. LICENSED MSBs 

The MSB industry in the United States is extremely diverse, ranging from Fortune 500 companies with 

numerous outlets and agents worldwide to small, independent “mom and pop” convenience stores in 

communities with population concentrations that do not necessarily have access to traditional banking 

services or in areas where English is rarely spoken. In addition, many MSBs only offer money services as 

an ancillary component to their primary business, such as a convenience store that cashes checks or a 

hotel that provides currency exchange. 

As noted above, recent criminal prosecutions demonstrate that some TF facilitators have gravitated 

towards using licensed MSBs to place and transfer funds through the banking system. This trend has 

been more pronounced among certain Sunni extremist groups, such as certain AQ affiliates and AlShabaab, which tend to use MSBs, while other terrorist groups, such as Hamas and Hizballah, appear to 

favor banks as a means of transmitting funds.241 In one case, an individual raised funds for Al-Shabaab 

from within the Somali diaspora in Missouri and elsewhere and used a variety of licensed MSBs with 

offices in the United States to remit the money to Somalia for general support of Al-Shabaab fighters. 

The co-conspirator, who worked in Minneapolis for one of the MSBs involved, helped the individual 

avoid leaving a paper trail by structuring transactions into low dollar amounts and by using false 

identification information. The MSB worker and other conspirators used fictitious names and phone 

numbers to hide the nature of their transactions.242

 

There is often overlap between some of the fund-raising methods that present a residual TF risk for the 

U.S. financial system and the use of MSBs to transfer them. For example, several individuals raising 

money under the auspices of charitable giving have used MSBs to transfer the funds to the terrorist 

organizations. In one case, an individual wanting to use a charitable organization as cover to send money 

to the Taliban eventually sent approximately $2,000 to Lahore, Pakistan via two separate MSB 

locations.243 In a separate case, four Somali immigrants were convicted on a variety of TF-related 

charges, including conspiracy to provide material support to Al-Shabaab and money laundering. In this 

case, a worker at a licensed MSB was the conduit for moving the funds.244 He conspired with two taxi 

 

240 Id. 241 Information derived from an analysis of financial institution BSA reporting. 242 United States v. Mohamud Abdi Yusuf, et al., Case No. 4:10-cr-00547-HEA (E.D. Mo. October 2010). 

243 New York v. Humayoun Ghoulam Nabi and Ismail Alsarabbi, Q13800646, Q13800647 (Complaint) (N.Y. Crim. 

Ct. October 2013. 

244 See FBI, Press Release, “San Diego Jury Convicts Four Somali Immigrants of Providing Support to Foreign 

Terrorists, February 22, 2013. 

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drivers and the imam at a mosque to raise thousands of dollars for Al-Shabaab and send it back to 

Somalia. The defendants claimed to be motivated by charity and were trying to raise money for 

humanitarian purposes in Somalia. Evidence presented at trial indicated that thousands of dollars were 

solicited and raised via the mosque and from other taxi drivers. The defendants transferred funds from 

San Diego to Somalia through a now-defunct MSB in San Diego, structuring the transfers and using false 

names to conceal the destination of the funds. The MSB and its owner were charged in 2009 by the SEC 

for engaging in fraudulent activities.245 The FBI also obtained transaction records from the MSB 

documenting the money transfers discussed in the recorded conversations.246

While these cases demonstrate the risk of licensed MSBs in the U.S. financial system serving as a conduit 

for TF, the U.S. government has endeavored to mitigate this risk through regulation and enforcement. As 

detailed in the National ML Risk Assessment, all MSB principals,247 except for the U.S. Postal Service, 

are required to register with FinCEN248 and to establish a written AML program reasonably designed to 

prevent the MSB from being used to facilitate money laundering and TF.249 Additionally, the BSA 

requires MSBs to file CTRs250 and SARs,251 and maintain certain records. With limited exceptions, 

MSBs are also subject to reporting, recordkeeping and customer identification. Finally, 48 states have 

established supervisory requirements for MSBs, often including the requirement that an MSB be licensed 

with the state in which it is incorporated or does business.252 The U.S. government continues to explore 

additional guidance and action that can be taken to allow the important legitimate business conducted by 

MSBs to continue while disrupting illicit activity. 

Along with comprehensive regulatory requirements, FinCEN and U.S. law enforcement authorities have 

also pursued civil and criminal penalties against MSBs and individual employees who are complicit in 

facilitating TF. As described above, U.S. authorities have successfully prosecuted several MSBs and their 

employees who facilitated TF for providing material support to terrorist organizations, along with 

violations of other criminal statutes.253 In addition to criminal charges brought by DOJ, FinCEN has the 

authority under the BSA to pursue civil enforcement actions against both MSBs and individual employees 

 

245 See SEC v. Shidall Express Inc. and Mohamud Abdi Ahmed, Case No. 3:09-cv-02610-JM-POR (S.D. Cal. filed 

November 19, 2009). 

246 See United States v. Moalin, No. 3:10-CR-4246 (JTM) (S.D. Cal. 2013). 

247 Many MSBs, including the vast majority of money transmitters in the United States, provide their services 

through agent relationships. While agents are not presently required to register with FinCEN, they are themselves 

MSBs that are required to establish AML programs and comply with the other recordkeeping and reporting 

requirements. 

248 See 31 C.F.R. § 1022.380. 

249 See 31 C.F.R. § 1022.210. 

250 See 31 C.F.R. § 1010.311. 

251 See 31 C.F.R. § 1022.320. Check cashers are not covered by the SAR requirement. See 31 CFR 1022.320(a)(1). 

252 At the federal level, MSBs are required to register with FinCEN and are examined for compliance with BSA 

requirements, which FinCEN has delegated to the IRS SB/SE division. Additionally, under the Money Remittances 

Improvement Act of 2014, Pub. L. 113–156, FinCEN may rely on examinations of MSBs for BSA compliance 

conducted by State supervisory agencies. State supervisory requirements vary, but general include licensing, capital 

and ownership requirements, and compliance with consumer protection and AML statutes. 

253 See, e.g., United States v. Ali, No. 0:10-CR-187, at *2 (MJD/FLN) (D. Minn. 2012); Government Response to 

Defendant’s Sentencing Memorandum; United States v. Yusuf, No. 4:10-CR-00547-HEA (E.D. Mo. 2012), 

Government’s Unclassified Memorandum; United States v. Moalin, No. 3:10-CR-4246 (JTM) (S.D. Cal. 2012). 

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for violations of the BSA that may contribute to TF, including the failure to abide by BSA reporting 

requirements.254 

In light of the important role that non-bank financial institutions play in promoting financial inclusion, the 

U.S. government has made a sustained effort to create international standards and a domestic regulatory 

framework that protect consumers, expand financial access, and curtail money transmitter abuse by 

criminal actors and terrorist financiers. Treasury has led inter-governmental efforts over the past 15 

years, working with money transmitters, banks, U.S. and foreign financial regulators and multilateral 

organizations such as the FATF, to establish domestic and international standards for the regulation and 

supervision of money transmitters.255 As a result of these efforts, record volumes of remittances are being 

transmitted through legitimate and transparent channels. 

Risk Summary 

Despite these efforts, residual TF risk does remain for MSBs, especially for funds being moved from the 

United States on behalf of AQ and its affiliates, Al-Shabaab and South Asia-based terrorist groups, 

including TTP. As described in several of the cases noted above, licensed MSBs may be misused by 

complicit employees who willingly facilitate TF in violation of applicable laws, regulations and the MSBs 

own AML/CFT policies and procedures. The current $3,000 recordkeeping threshold results in the 

processing of the typical $200-$400 remittance without verifying customer identification, and these low 

value transactions by occasional customers presents a manageable TF risk because MSBs are required to 

file SARs when there is suspicion of ML or TF.256 

3. UNLICENSED MONEY TRANSMITTERS 

As detailed in the National ML Risk Assessment, along with licensed MSBs, there are also individuals 

and entities operating illegally as unlicensed money transmitters in the U.S. SARs filed by banks citing 

potential unlicensed money transmission activity identified a variety of businesses, including grocery or 

convenience stores, gas stations and liquor stores, which operated as unlicensed money transmitters. 

A review of publicly available information on U.S. law enforcement cases involving TF offenses and 

financial reporting indicates that unlicensed money transmitters continue to be used to transfer illicit 

proceeds. For example, Saifullah Anjum Ranjha, a Pakistani national residing in the United States and 

operator of an unlicensed money remitter business in the District of Columbia, pleaded guilty to 

conspiring to launder money and to concealing TF. A cooperating witness, acting at the direction of law 

enforcement, held himself out to Ranjha as providing financing to members of AQ and its affiliated 

 

254 See, e.g., FinCEN, In the Matter of Saleh H. Adam dba Adam Service, Dearborn, Michigan No, 2014-02, 

February 7, 2014; FinCEN, In the Matter of Mohamed Mohamed-Abas Sheikh, Ann Arbor, Michigan, No. 2011-9, 

September 23, 2011. 

255 See, e.g., Daniel L. Glaser, Treasury Notes Blog, Treasury’s Work to Support Money Transmitters, October 8, 

2014. Available at http://www.treasury.gov/connect/blog/Pages/Treasury%E2%80%99s-Work-to-Support-MoneyTransmitters.aspx. 

256 However, in their internal AML/CFT policies and procedures, some MSBs require customer identification for 

transactions below $3,000. See FinCEN, Financial Institutions Outreach Initiative: Report on Outreach to Money 

Services Businesses, p. 19, July 2010. 

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organizations. Over the course of four years, the cooperating witness gave Ranjha and his associates a 

total of $2,208,000 to transfer abroad, explaining that the funds were the proceeds of, and related to, his 

involvement in international drug trafficking, international smuggling of counterfeit cigarettes and 

weapons. Ranjha conducted 21 transactions in amounts ranging from $13,000 to $300,000. Ranjha 

arranged with his associates for the equivalent amount of monies, minus commissions, to be delivered to 

the cooperating witness, his third party designee, or a specified bank account in Canada, England, Spain, 

Pakistan, Japan and Australia.257 

In light of the use by TF facilitators of unlicensed money transmitters, U.S. regulatory and law 

enforcement authorities have aggressively targeted these actors for investigation and prosecutions, with a 

targeted focus on the most significant violators. Importantly, 18 U.S.C. § 1960 imposes criminal 

penalties for the act of engaging in unlicensed money transmission, giving law enforcement and 

prosecutors a powerful tool to sanction violators regardless of whether their activity is used to facilitate 

TF. This can be especially useful for curtailing unlicensed money transmitter activity where proving the 

connection to TF may be difficult or pose particular evidentiary challenges. As noted above in August 

2011, Mohammad Younis pleaded guilty to a violation of 18 U.S.C. § 1960 for running an unlicensed 

money transmitter that transferred funds to many individuals, including Faisal Shahzad, who later used 

the funds for his attempt to detonate a car bomb in Times Square.258 Because Section 1960 does not 

require proving a connection to TF, U.S. authorities were able to shut down a potential TF source without 

having to prove Younis knowingly facilitated the funds transfers for terrorist activity. In addition to 

prosecuting unlicensed money transmitters, the U.S. government has also worked with financial 

institutions to more effectively detect and report potential unlicensed money transmission. For example, 

FinCEN has issued detailed guidance to financial institutions on how to report suspicious activity 

associated with unregistered MSBs.259 

Risk Summary 

 

The ongoing challenge of identifying unlicensed money transmitters, which largely serve populations that 

cannot or choose not to use legitimate channels, raises the specter of illegal transactions that may support 

terrorist groups including AQ and its affiliates, Al-Shabaab and TTP, and poses a residual risk for TF. 

4. CASH SMUGGLING 

As robust implementation of AML/CFT controls across financial institutions has raised the costs, risks 

and difficulty for TF networks operating within the financial system, cash smuggling has become an 

increasingly attractive way for foreign terrorists to transfer funds. The use of cash is attractive to 

criminals mainly because of its anonymity, portability, liquidity and lack of audit trail. 

 

257 See Department of Justice, Press Release, “Money Remitter Pleads Guilty To Money Laundering Conspiracy 

And Concealing Terrorist Financing,” August 22, 2008. 

258 See Department of Justice, Press Release, “Long Island Man Pleads Guilty in Manhattan Federal Court to 

Engaging in Hawala Activity that Funded Attempted Times Square Bombing,” August 18, 2011. 

259 See FinCEN Advisory, Informal Value Transfer Systems, FIN-2010-A011, September, 1, 2010. 

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According to the surveyed cases, since 2007, 18 TF-related prosecutions in the United States have in 

some way involved the use of cash to transfer funds to terrorist organizations.260 These cases have 

involved various FTOs, including core AQ, AQ in Iraq (the predecessor organization to ISIL), AQAP, AlShabaab, Hizballah, and FARC. There have been several notable cases in which U.S.-based individuals 

sought to smuggle cash for the benefit of Hizballah by concealing it in vehicles. On May 21, 2012, an 

individual was sentenced to more than six years in prison for conspiring to send hundreds of thousands of 

dollars to Hizballah.261 His wife and co-conspirator previously pleaded guilty to one count of conspiracy 

to provide material support and resources to a FTO. During multiple meetings with an FBI confidential 

source, the two defendants discussed ways to secretly send money to Hizballah leaders in Lebanon.262 

The two defendants proposed several methods, including using wealthy individuals with property in 

Lebanon to act as unlicensed money transmittal services and by using legitimate U.S. businesses that deal 

primarily in cash to over-report revenue, which would be taxed and therefore “legitimately” declared 

during transport to Lebanon.263 The two defendants also proposed sending funds through couriers, who 

would carry cash in amounts less than the $10,000 reporting requirement either directly to Lebanon, 

where it would be recovered by co-conspirators and delivered to Hizballah, or to a third country, where it 

would be transferred to an offshore account and wire transferred to co-conspirators in Lebanon.264 

Alternatively, money orders in amounts less than the $3,000 record-keeping requirement could be sent to 

post office boxes in a third country where they would be deposited in an offshore account and transferred 

by wire to Lebanon.265 One of the defendants indicated that he had previously carried about $66,000 on 

his person over the course of two trips to Lebanon.266 He also indicated that he understood the funds 

would be sent to a designated terrorist organization and used to target Israel. The fact that the two 

defendants, after discussing multiple options to transfer the funds, ultimately agreed to send 

approximately $500,000 by concealing it inside a car, which they planned to send to Lebanon via a 

container ship, demonstrates how terrorist supporters were compelled to resort to cash smuggling – a less 

efficient means of funds transfer – in an effort to avoid U.S. controls.267 

Similarly, on July 31, 2012, a Virginia resident pled guilty to attempted money laundering for placing 

what he believed to be $100,000 belonging to Hizballah inside a Jeep in 2010 and directing it to be 

shipped to Beirut; his arrest was the result of an FBI-orchestrated sting operation.268 In a similar case, 

two Iraqi nationals pleaded guilty to TF-related charges resulting from an FBI-led sting operation.269 

From September 2010 through May 2011, one Iraqi participated in ten separate operations to send 

weapons and money that he believed was destined for terrorists in Iraq. In January 2011, he recruited the 

 

260 See Footnote 89. 

261 FBI, Press Release, “Ohio Man Sentenced to 75 Months in Prison for Scheme to Send Money to Hizballah,” May 

21, 2012. Available at http://www.fbi.gov/cleveland/press-releases/2012/ohio-man-sentenced-to-75-months-inprison-for-scheme-to-send-money-to-hizballah. 

262 See United States v. Hor and Amera Akl, No. 3:10-cr-00251-JGC, (N.D. Ohio, filed June 7, 2010). 

263 Id. 264 Id. 265 Id. 266 See United States v. Hor and Amera Akl, No. 3:10-cr-00251-JGC (Indictment) (N.D. Ohio, filed June 7, 2010) . 

267 Id. 268 See United States v. Mufid Kamal Mrad, Case No. 1:12mj363 (Affidavit) (E.D. Va. May 30, 2012); see also FBI, 

Press Release, “Vienna Man Pleads Guilty to Attempted Money Laundering,” July 31, 2012. 

269 United States v. Alwan et al, Case No. 1:11-cr-00013 (Indictment) (W.D. Ky. 2011); Department of Justice, Press 

Release, “Iraqi National Pleads Guilty to 12-count Terrorism Indictment in Kentucky,” August 21, 2012. 

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second defendant to assist in these material support operations. Over the course of the conspiracy, the 

individual believed he had sent $375,000 cash alone and $565,000 cash with the help of the second 

defendant. The primary means of smuggling the cash was in a hidden compartment of a tractor-trailer 

which would then be sent on to Iraq.270 

 

These case studies demonstrate that cash couriers are being used to transfer funds to terrorist 

organizations. The U.S. government, particularly LEAs, proactively investigates and prosecutes such 

cases of abuse in order to effectively mitigate the vulnerability. For example, DHS, through ICE and 

CBP, has established special programs and initiatives to target bulk cash smuggling across U.S. 

borders.271 DOJ and other prosecutorial authorities have levied criminal penalties for failing to report the 

cross-border transfer of currency in excess of $10,000.272 Additionally, as detailed in the National ML 

Risk Assessment, the misuse of cash is limited by transaction recordkeeping and reporting requirements 

that require financial institutions to verify a customer’s identity and retain records of certain information 

prior to issuing or selling payment instruments when purchased with currency in amounts between $3,000 

and $10,000.273 For cash transactions above $10,000, whether a single transaction or a series of related 

transactions with a customer in a single business day, financial institutions are required to file a CTR with 

FinCEN.274 Other non-financial businesses must report cash transactions of more than $10,000 to the IRS 

and FinCEN.275 

Risk Summary 

It is difficult – if not impossible – to completely stop the use of cash smuggling, and thus, it remains a 

residual TF risk. Combined with the widespread demand for U.S. currency globally, multiple terrorist 

groups, including AQ and its affiliates, ISIL, Al-Shabaab, Hizballah, and FARC, will continue to use cash 

smuggling as a less efficient alternative for moving funds globally. 

C. POTENTIAL EMERGING TF THREATS AND VULNERABILITIES 

1. CYBERCRIME AND IDENTITY THEFT 

In addition to the various methods of raising funds described above, U.S. authorities are closely 

monitoring TF activity to identify potential new strategies of fundraising that may be employed by 

terrorist organizations. For example, a variety of terrorist organizations, including AQ and Hizballah, 

could use successful cybercrime schemes employed by criminal actors to directly steal funds, or 

alternatively, steal information or other assets that could then be sold in online black markets.276 Terrorist 

 

270 Id. 

271 See Department of Homeland Security, Disrupt Terrorist Financing. Available at 

http://www.dhs.gov/topic/disrupt-terrorist-financing. 

272 See 31 U.S.C. § 5332. 

273 See 31 C.F.R. § 1010.415. 

274 See 31 U.S.C. § 5313. 

275 See 31 U.S.C. § 5331 and 26 U.S.C. § 6050I. 

276 See, Gordon M. Snow, Assistant Director, FBI Cyber Division, Statement Before the Senate Judiciary 

Committee, Subcommittee on Crime and Terrorism, April 12, 2011. Available at 

http://www.fbi.gov/news/testimony/cybersecurity-responding-to-the-threat-of-cyber-crime-and-terrorism. 

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organizations may also use various identity theft schemes to raise funds, particularly given the substantial 

revenues that can be generated from these schemes.277 While terrorist groups have stolen credit cards to 

raise funds in the past, as well as to evade detection by law enforcement, the proliferation of stolen 

identities and their sale in various online forums make them an attractive fundraising scheme.278 

2. ISIL 

U.S. authorities are also actively monitoring attempts by ISIL to raise funds from U.S. persons and move 

funds through U.S. financial institutions. While ISIL receives the vast majority of its revenue from 

criminal and terrorist activities in Syria and Iraq, including the exploitation of local resources, extortion of 

the local population and KFR, coalition efforts to disrupt these sources of funding may force ISIL to look 

elsewhere for new revenue, including increasing fundraising from individuals in the United States.279 

U.S. law enforcement authorities have identified isolated cases of U.S. persons who have provided or 

attempted to provide funds to ISIL, as well as U.S. persons who have traveled or attempted to travel 

overseas to serve as foreign terrorist fighters with or otherwise support ISIL.280 Additionally, ISIL may 

also seek to exploit Iraqi and Syrian bank branches or other financial institutions that it controls to 

conduct international transactions, which would allow it to more easily receive foreign funds to finance its 

activities as well as send payments abroad to procure weapons and other goods to sustain itself. U.S. 

authorities, working with international partners, are taking measures to prevent ISIL from accessing the 

international financial system, including U.S. financial institutions.281 

3. NEW PAYMENT SYSTEMS 

As detailed in the National ML Risk Assessment, virtual currencies such as Bitcoin and other emerging 

payments technologies, while representing an opportunity for financial innovation, have attracted the 

attention of various criminal groups, and may be vulnerable to abuse by terrorist financiers. For example, 

the U.S. Secret Service has observed that criminals are looking for and finding virtual currencies that 

offer anonymity for both users and transactions; the ability to move illicit proceeds from one country to 

another quickly; low volatility, which results in lower exchange risk; widespread adoption in the criminal 

underground; and trustworthiness.282 In terms of TF risk, there has been some speculation about using 

 

277 DOJ estimated direct and indirect losses from identity theft at approximately $24.7 billion in 2012. See Erika 

Harrell, Ph.D. and Lynn Langton, Ph.D., DOJ, Office of Justice Programs, Bureau of Justice Statistic, Victims of 

Identity Theft, 2012. Available at http://www.bjs.gov/content/pub/pdf/vit12.pdf. 

278 See FATF, Terrorist Financing, p.17, February 2008. 

279 Jennifer Fowler, Deputy Assistant Secretary for Terrorist Financing and Financial Crimes, Remarks at the 

Washington Institute for Near East Policy on U.S. Efforts to Counter the Financing of ISIL, February 2, 2015. 

Available at http://www.treasury.gov/press-center/press-releases/Pages/jl9755.aspx. 

280 See, e.g., Department of Justice, Press Release, “Six Defendants Charged with Conspiracy and Providing 

Material Support to Terrorists,” February 6, 2015. In addition, in October 2014, U.S. authorities detained three 

teenage girls who flew from Colorado to Germany in an attempt to travel on to Syria and join the Islamic State. 

281 Jennifer Fowler, Deputy Assistant Secretary for Terrorist Financing and Financial Crimes, Remarks at the 

Washington Institute for Near East Policy on U.S. Efforts to Counter the Financing of ISIL, February 2, 2015. 

282 Edward Lowery III , USSS Criminal Investigative Division Special Agent in Charge Testimony Before the U.S. 

Senate Committee on Homeland Security and Governmental Affairs hearing titled “Beyond Silk Road: Potential 

Risks, Threats, and Promises of Virtual Currencies,” November 18, 2013. 

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virtual currency to transfer funds overseas. For example, a posting on a blog linked to ISIL has proposed 

using Bitcoin to fund global jihadist efforts.283 

In light of this risk, U.S. law enforcement authorities have aggressively investigated and prosecuted 

individuals and entities that have attempted to use virtual currencies for illicit activities. Liberty Reserve, 

for example, a virtual currency based in Costa Rica, its principal founder, and six others were charged in 

federal court in New York in 2013 with money laundering and illegally operating as an unlicensed money 

transmitter.284 The defendants were convicted in 2013 and 2014. Before founding Liberty Reserve, the 

business’s principal had been convicted in the United States for operating “Gold Age,” an E-Gold 

exchanger. The Secret Service estimates that Liberty Reserve had more than one million users 

worldwide, with more than 200,000 in the United States, and processed more than $1.4 billion of 

transactions annually.285 The transactions processed through Liberty Reserve involved payments 

associated with credit card fraud, identity theft, investment fraud, computer hacking, drug trafficking, and 

child pornography.286 

With an eye to both stopping financial crime and permitting socially beneficial financial innovation to 

occur, U.S. regulators have sought to develop a coherent framework for regulating emerging payment 

systems and virtual currencies.287 Given the attractiveness of virtual currency to conduct illicit financial 

transactions, the possibility exists that terrorist groups may use these new payment systems to transfer 

funds collected in the United States to terrorist groups and their supporters located outside of the United 

States, although the degree to which this presents a residual TF risk is unclear. 

 

 

283 See Coindesk, “ISIS-Linked Blog: Bitcoin Can Fund Terrorist Movements Worldwide,” July 17, 2014. 

Available at http://www.coindesk.com/isis-bitcoin-donations-fund-jihadist-movements/. 

284 See United States v. Liberty Reserve, S.A., et al., 13 Crim. 368 (S.D.N.Y. May 20, 2013). 

285 Edward Lowery III , USSS Criminal Investigative Division Special Agent in Charge Testimony Before the U.S. 

Senate Committee on Homeland Security and Governmental Affairs hearing titled “Beyond Silk Road: Potential 

Risks, Threats, and Promises of Virtual Currencies”, November 18, 2013. 

286 Jennifer Shaskey Calvery, Director, FinCEN, Department of the Treasury, Testimony Before the U.S. Senate 

Committee on Homeland Security and Government Affairs hearing titled “Beyond Silk Road: Potential Risks, 

Threats, and Promises of Virtual Currencies,” November 18, 2013. 

287 See, e.g., FinCEN FIN-2013-G001, Application of FinCEN's Regulations to Persons Administering, Exchanging, 

or Using Virtual Currencies, March 18, 2013; New York Department of Financial Services, Press Release, “NY 

DFS Releases Proposed BitLicense Regulatory Framework for Virtual Currency Firms,” July 17, 2014. 

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Conclus

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National Terrorist Financing Risk Assessment 

CONCLUSION 

To combat the threat posed by TF, the U.S. government has developed and implemented a comprehensive 

interagency approach to aggressively investigate and prosecute all forms of TF occurring in the United 

States, close existing gaps in the U.S. financial system that have been used to facilitate TF, designate 

financiers for economic sanctions to isolate them from the global financial system, and engage 

international partners and institutions to develop a secure global framework that will effectively prevent 

TF from infiltrating the global financial system. 

Although this effort has been effective in reducing the overall vulnerability of the United States and U.S. 

financial system to TF, certain residual risks still remain. Terrorists and terrorist organizations continue 

to engage in criminal activity in the United States, including benefitting from drug trafficking, to raise 

funds. To combat this, the U.S. government uses sophisticated interagency information-sharing, 

investigations, designations and prosecutions, aided by powerful legal authorities and tools, to target such 

criminal activity. 

Although the charitable sector continues to face vulnerability to abuse by TF facilitators, a coordinated 

law enforcement, regulatory and outreach effort by the U.S. government, working within government and 

with charitable organizations, has improved the resiliency of the charitable sector to such abuse and 

forced potential TF fundraisers to pursue fundraising activity outside of charitable organizations. A 

notable trend in this sector has seen individuals unaffiliated with any charitable organization recognized 

by the U.S. government raise funds for terrorist organizations under the auspices of charity, with outreach 

through social media playing a key role. In response, the U.S. government has deployed interagency and 

joint resources to identify, investigate and prosecute these facilitators. 

Finally, individuals based in the United States have also given funds directly to terrorist groups, or raised 

funds for their own terrorist activities, including funding travel to join militant groups overseas. While 

these types of transactions are particularly difficult to detect, law enforcement and the regulatory 

community continue to develop new tools to identify, investigate and prosecute these individuals. 

Given the central role U.S. banks play in facilitating global payments, the United States is vulnerable to 

the movement of funds associated with TF through the banking system. To address this, the U.S. 

government has focused on developing and implementing preventive measures to reduce the vulnerability 

of these institutions to TF, used additional tools and authorities to more effectively target TF, and 

imposed substantial financial penalties on noncompliant institutions. Even with these measures, the U.S. 

banking system is exposed to residual TF risk, such as from foreign correspondents that may not have 

effective AML/CFT programs. 

Although TF facilitators may seek to abuse MSBs to move funds through the banking system, financial 

regulatory and outreach efforts have mitigated much of the potential vulnerability, although residual risk 

remains, especially from complicit MSB employees assisting TF facilitators. The U.S. government has 

also aggressively prosecuted persons or entities operating as unlicensed money transmitters and worked 

with financial institutions to develop measures to more effectively recognize such activity; however, 

given the difficulty in identifying these transactions and their observed use to facilitate TF, some residual 

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risk does remain. Finally, as AML/CFT measures, prosecutions and outreach have forced terrorist groups 

out of the regulated financial system, they have increasingly favored less efficient means of moving 

funds, such as cash smuggling. 

In addition to the residual risks identified, the U.S. government continues to monitor and review potential 

emerging TF threats and vulnerabilities, including the use of new payment technologies and growing 

links between online criminal activity and TF. To identify and combat these emerging threats and 

vulnerabilities, the U.S. law enforcement, intelligence and regulatory communities will continue to 

collaborate and share information, utilize legal authorities and tools to sanction and prosecute TF 

facilitators, and reach out to private sector and international partners to improve the understanding of such 

threats. As a leader in the global economy and international financial system, the United States is 

committed to continuing to develop and implement effective CFT measures to further reduce TF risks in 

the United States and to the U.S. financial system. 

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