Financial institutions on the front lines of combating terrorist financing

Eversheds Sutherland (US) LLP

Immediately following the October 7 attack by Hamas on Israel, the United States Financial Crimes Enforcement Network (FinCEN) announced the creation of the Counter Terrorist Financing Taskforce— Israel (CTFTI)—a coalition of global financial intelligence units (FIUs) of the United States, the United Kingdom, Israel and at least 10 other allied nations.
 
As a result of this task force, financial institutions—large and small—should review and enhance their customer-monitoring procedures, report suspicious activities promptly, and recognize their vulnerability to money-laundering activities, including threat financing. In particular, financial institutions should review and test know-your-customer and financial due diligence systems and controls to ensure that primary, secondary and third-party screenings are robust and adequate to prevent high-risk behavior and transactions often associated with money laundering and threat financing.
 

CTFTI committed to pursuing four concrete actions to achieve their goal:

  • Enhancing financial intelligence: Enhanced financial intelligence on terrorist-financing matters, including associated financial flows and economic activities. Expediting information sharing:
  • Members pledged to expedite and increase the sharing of financial intelligence related to terrorist financing as well as associated financial flows and
    economic activities
  • Best practices and lessons learned: The task force will facilitate discussions on FIU best practices and lessons learned, and it will explore opportunities for additional actions and partnerships to combat and disrupt terrorist-financing activities. Strengthening relationships:
  • Strengthening and facilitating the working relationships between FIUs, competent public authorities and the private sector can help address the threat of terrorist financing.

Regulators consider financial institutions vital to thwarting money-laundering and threat-financing efforts. Vigilance, reporting and strong customer monitoring programs are essential for effective countering of threat-financing efforts. 

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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