Counter-Terrorism Financing

Nathalie Rébé, J.S.D. (2018) & LL.M. (2012) in International Tax and Financial Services, in Compliance & Risk Management, at Thomas Jefferson School of Law. D.B.A. in Financial Strategy & Risk Management (2013), Paris School of Business.

• Acronyms and AbbreviationsAcknowledgementsIntroductionPart 1: Counter Terrorism Financing Worldwide OverviewIntroduction to Part 11 What is the Current Situation Concerning Counter-Terrorism Financing?A Terrorism’s Purpose and Modus OperandiB The Struggle to Define TerrorismC Defining Terrorism FinancingD International Specialized Agencies Fighting TFE Current Counter-Terrorism Financing Regulations2 Can Terrorism Financing Detected?A The Links between Terrorism Financing and Anti Money LaunderingB Traditional Terrorism Financing Methodsi) Cash Schemesii) Merchandising and Movable Assets Laundering iii) Wire and International Transfersiv) Investments v) White Collar Crimes vi) Secret Banking Systems, Private Donations and Charities vii) Gambling viii) New Payment Technologies C Terrorism Financing Risks Faced by Financial Institutions i) CTF Red Flags ii) Cases from FIU Reports3 Existing Compliance Measures to Prevent Terrorism FinancingA Internationally used Tools to Detect and Report TF i) How Institutions Model Terrorism Financing Risk a Counter-terrorism Risk Models b Risk Assessment c Risk-Based Supervision ii) Identification a Customer Due Diligence (CDD) b Know Your Customer (KYC) c Enhanced Due Diligence (EDD) d Politically Exposed Persons (PEPs) 1 Defining PEPs2 PEP Affiliated Risks3 Risk Mitigation and Managemente Customer Identification Programs (CIPs) f Comparison with Government Terrorist lists iii) Reportinga Currency Transaction Reports (CTRs) b National Security Letters (NSLs) c Suspicious Activity Reports (SARs) B The Egmont Group and Financial Intelligence Units Part 2: Main Threats to the Accomplishment and Success of a New Counter Terrorism Financing ConventionIntroduction to Part 2 4 Key Challenges at the International LevelA Main Problems Encountered While Trying to Detect TF Activitiesi) Anonymity ii) Cross-border Activities iii) Third-party Involvement a Employee Participation in the Financing Schemeb Third-party Reliancec Third-party FundingB The Emergence of New Payment Technologies C International Cooperation between Actors and AgenciesD Political Pressure5 The Ineffectiveness of the Current Enforcement System MechanismA Cross-Border Enforcement B Assets Tracing, Freezing of Assets and Assets Recovery6 Potential Conflicts between a New CTF Tool and Human RightsA International Privacy Laws B Civil Liberties and Humanitarian LawsPart 3: Current Regulatory InstrumentsIntroduction to Part 37 Analysis of Existing Counter Terrorism Tools with Regards to Counter Terrorism Financing 1 International Counter Terrorism Regulations 2 Agencies and Financial Institutions Recommendations3 Countries Legislative Contribution 8 Current Counter Terrorism Tools and Regulations Successes and FailuresA A Critique of Current Counter Terrorism Financing Tools and Regulations B Counter Terrorism Financing Regulations’ Gap Analysis C Constructive Criticism and Advice by International Experts for Building a New ModelPart 4: New Counter Terrorism Financing Convention Model and RecommendationsIntroduction to Part 4 9 The importance of a New CTF Framework10 Building a New Counter-Terrorism Financing Model11 Ways to Strengthen Worldwide Detection, Prevention and EnforcementA Actors’ Involvement and Cooperation at the Domestic and International LevelsB Collaboration with the Private Sector C The Positive Development of Global Financial Intelligence UnitsConclusionPart 5: Matters for Further ConsiderationIntroduction to Part 5Bibliography Annexes Index