China hunting down assets and money launderers in Canada and the US in “Operation Skynet”

By Christine Duhaime | March 27th, 2015

Operation Skynet

Business Insider has an interesting story here on “Operation Skynet”, the operation by the Chinese government to track down money laundering foreign nationals from China who exported funds and other assets illegally from China as part of the immigration process. Most of those people moved assets and money to Vancouver and New York and parked the funds in real estate.

Denial of Safe Haven

Operation Skynet is part of the larger global initiative of “denial of safe haven” in which the G20 countries agreed in 2013, not to allow the immigration system to be used to provide a safe haven for people who remove assets illegally from a country. The denial of safe haven permits the easier removal of a person to their home country to face money laundering charges in cases where there is evidence of such activities.

Tax Havens & Financial Firms Targeted 

The Government of China said they are going after people who have facilitated or assisted Chinese foreign nationals to remove funds from the country illegally, such as immigration consultants and financial firms.  Operation Skynet is also going to target tax havens.

Currency Restrictions

In China, a person or company can only export $50,000 per year from China unless they obtain permission in advance to remove more than that amount. Often Chinese foreign nationals immigrating to places like Canada or the US do not want to seek permission in advance to remove more than $50,000 because they do not want to alert the Chinese government with respect to the amount of funds they have accumulated; and (b) how those funds were obtained. With respect to the latter, that is because often the funds were obtained from bribery or other forms of corruption and are proceeds of crime. If a person uses proceeds of crime, they are a money launderer. Every tax evader from China is, by definition, a money launderer. If a person from China removed funds illegally to Canada and China determines that the removal of funds is criminal, that person is likewise a money launderer.

Ways Chinese Nationals Illegally Move Funds

Foreign nationals from China remove money illegally in several ways when they immigrate to places like Canada and the US, as follows:

  1. They have  several friends and family, or they force employees, to wire funds for them each at the maximum $50,000 amount to circumvent currency export restriction rules in China. I have seen files with up to 200 different employees of a Chinese company who were forced to wire $50,000 each so that the business owner could buy a $7 million mansion in Vancouver and have some spending money left over.
  2. They use junket operators who are sometimes connected to the Triads to move money for them to Macau where they gamble for relative minimal play and then have the funds wired from Macau to Canada or the US, sometimes using passé tax havens such as the BVI, Cayman Islands, Cook Islands or the like, or back through Hong Kong.
  3. They engage in trade-based money laundering where they create false invoicing to justify the wiring of vast sums of money on the basis of fictional trades to companies in places like Canada or the US.
  4. They pay money mules a 20% commission to physically transport funds from China to Canada or the US, who fail to report the importation of funds when they enter the country.
  5. Anecdotally, they buy Bitcoin in the amount they want removed, and cash it out in Canada or the US. If the price fluctuates in the interim period, it still cost them less than using a money mule and is more secure (and just as anonymous).

Last year, China apparently seized over 500 former foreign nationals who they allege illegally removed assets from China for prosecution. The adoption of FATCA by China and Canada signalled the death knell for funds removed from China illegally that were not declared.

Will China Seek to Recover from Banks for PEP Failures?

Private banks and  asset managers who facilitated, or turned a blind eye to the removal of assets and funds from clients in China may have compliance issues of their own on this issue. That’s because most of the Chinese foreign nationals who removed, and continue to remove, funds from China are politically exposed persons in the US and Canada under anti-money laundering and counter-terrorist financing laws and very few bankers comply with politically exposed persons (“PEP“) laws in the way they were meant to be complied with. Often, banks provide a questionnaire to the client from China and ask the client to self-declare whether they are a PEP. It is not incumbent upon a person to self-declare whether they are a PEP or not and moreover, that determination is a legal one that most PEP are unqualified to determine. Asking a PEP to self-declare and purporting to rely on that self-disclosure does not constitute compliance with anti-money laundering law. The Government of China may be tempted, as a next step in Operation Skynet, to seek recovery from financial institutions who failed to meet the standard of care pursuant to PEP laws if that failure caused losses to the Government of China by allowing state assets to be moved from China.

Typologies of Money Laundering from China

Money launderers from all countries follow identical typologies (spending patters) the world over that help to identify them. The typologies below do not mean that anyone who displays these behavior patterns is a money launderer. Those typologies are:

1. They buy luxury homes.

2. They buy high end racing cars.

3. They buy high end jewellery (mostly watches).

4. They immediately register children in the most expensive private schools or most elite universities in Canada or the US.

5. They carry large amounts of cash.

6. They like to flaunt wealth in public.

7. They use private banking where the anti-money laundering and counter-terrorist financing practices are the most lax.

8. They use certain tax havens such as BVI or the Cayman Islands, that are no longer used by the financial elite who have moved on to other havens that are less obvious.

9. Their bank accounts are funded with hundreds of wire transfers from different sources.

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PayPal to pay $7.7 million for sanctions non-compliance issues

By Christine Duhaime | March 26th, 2015

PayPal has settled with the US Treasury Department to pay $7.7 million over alleged sanctions failures in which they are alleged to have processed more than 500 financial transactions to places like Iran, Cuba and the Sudan and to persons who are on the sanctions list. They processed 136 transactions for a person on the sanctions list who trafficked WMD. PayPal allegedly said that before 2013, it did not  have a compliance plan in place to detect sanctioned transactions as they were occurring. The US Treasury Department is increasingly focusing its compliance and enforcement efforts on non-banking financial services providers.

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France to limit cash and ‘anonymous’ transactions; introduces new law; et mobilise contre le terrorisme avec l’investissement de €736 million

By Christine Duhaime | March 21st, 2015

€736 Million Investment in Counter-Terrorism Infrastructure

Le gouvernement français a décrété une “mobilisation générale” contre le terrorisme, annonçant la création de 2,680 emplois et le déblocage de €736 millions sur trois ans.

Le Premier ministre a présenté des mesures visant à mieux lutter contre les filières suspectes, notamment via internet et dans les prisons, évaluant à “près de 3,000″ le nombre de personnes à surveiller.

“Au total, au cours des trois prochaines années, ce sont donc 2,680 emplois supplémentaires qui seront consacrés à la lutte contre le terrorisme dans les services régaliens de l’Etat et dans les juridictions”, a déclaré Manuel Valls.

Sur les 1,400 emplois créés au ministère de l’Intérieur, 1,100 renforceront les services de renseignement. Sont aussi annoncés 950 postes à la Justice, 250 à la Défense et 80 au ministère des Finances, dont 70 aux douanes.

Côté financement, €425 millions d’euros de crédits d’investissement, d’équipement et de fonctionnement ont été débloqués sur trois ans, dont €233 pour le ministère de l’Intérieur et €181 millions pour la Justice.

Le Premier ministre a confirmé la création d’un fichier de personnes déjà condamnées pour terrorisme sur le modèle de ce qui existe pour le suivi des pédophiles et la création de cinq quartiers réservés aux détenus radicalisés.

Il a évoqué un montant de €60 millions pour lutter contre la radicalisation dans les trois prochaines années.

Des “mesures exceptionnelles, et non pas d’exception”, dont une partie sera incluse dans la loi sur le renseignement appelée à être présentée en mars au Parlement, en vue d’une adoption définitive début juin.

Reprenant une proposition de la droite, le chef du gouvernement a proposé d’engager une réflexion parlementaire sur une peine d’indignité nationale, dont la privation des droits civiques, pour les Français condamnés pour terrorisme.

“La République est debout et nous prenons des mesures exceptionnelles, à la hauteur de ces menaces” a dit M. Valls.

Manuel Valls a lancé en outre un appel aux usagers d’internet, principal vecteur du djihadisme, les invitant “à coopérer étroitement avec les autorités pour appliquer les règles relatives aux contenus illicites et au déréférencement des sites illégaux”.

New Law on Surveillance and Data Collection

France also unveiled a new law to allow intelligence forces to monitor and collect the email and telephone communications of anyone suspected of being a terrorist. It would also force ISPs and telcos to allow intelligence agencies to record metadata that would be stored for five years and analyzed for serious criminality related to, among other things,  terrorism, organized crime and economic stability. The law also sets up a national commission that would oversee surveillance requests and information collection.

New Regulations on Anonymous & Cash Transactions

France also announced measures to limit the ability of terrorists to use cash and anonymous payment methods that the Minister of Finance Michel Sapin, said facilitated terrorist acts.

As of September 1, 2015,  the amount of cash that a person can spent at once in France is €1,000 (it’s now €3,000). Banks would also have to report monthly transactions of €10,000 or more to TracFin. ID would  be needed to buy a prepaid card worth more than €250 or to complete a currency exchange of more than €1,000. And virtual currencies will be a “lot better regulated” said Sapin.

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American Banker – Why banks should be concerned about hackers taking on counter terrorist financing

By Christine Duhaime | March 11th, 2015

In case you missed it, our article in American Banker‘s Bank Think entitled “We Shouldn’t Be Relying on Hackers to Stop Terrorism Financing” can be read here.

The article discusses the recent phenomena of hackers in #OpISIS taking down the websites of the Islamic State and their stated promise to go after banks engaged in terrorist financing. It also discusses ways in which ISIS is funded and why counter-terrorist financing efforts are failing thus far and why it is of concern that hackers may be targeting global banks and their executives over terrorist financing, raising cyber-security issues.

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What does Boko Haram’s allegiance to ISIS mean for terrorist financing?

By Christine Duhaime | March 11th, 2015

Boko Haram aligns with ISIS

Over the weekend, Boko Haram, the terrorist group in Nigeria, pledged its allegiance to the leader of the Islamic State (“ISIS“) over Twitter. Some strategists believe that the allegiance is a sign of weakness and shows that Boko Haram’s sphere of influence is shrinking. I doubt that. For ISIS, the benefits are clear – it gets to expand its profile and reign of terror more quickly. The benefit for Boko Haram is that it gets more media attention as an ISIS-affiliate than it would on its own without the name brand that ISIS has created on social media among its followers.

Illegal Ransom Payments

In the last few years, Boko Haram has been well-funded by kidnap for ransom payments of captured foreigners. Such payments are illegal acts of terrorist financing and although they imperil many more foreigners, insurance companies and some governments continue to pay terrorists ransoms to secure the release of hostages. Because of ISIS’ higher profile, illegal ransom payments to ISIS have become less frequent. By aligning itself with ISIS, ransom payments to Boko Haram will likewise become less frequent. Unfortunately, this means that Boko Haram, like ISIS, will escalate the magnitude of horrific acts against captured people when ransom payments are not made.

Kidnap for ransom payments generally are a pressing problem for terrorist financing. Unfortunately, insurance companies and governments who have illegally paid terrorists to secure the freedom of people, encourage more kidnappings to occur all over the world and directly fund terrorist activities that threaten national security. It is not an understatement from a terrorist financing perspective to say that insurance payments to terrorist organizations are a direct threat to national security. Until there are prosecutions for terrorist financing arising from ransom payments, such payments will continue to be made.

Natural Resources

Like ISIS, Boko Haram has learned that it can become rich overnight by controlling natural resources and extracting taxes from the locals and we will thusly see an increase in activities that result in Boko Haram taking over control of natural resources, especially oil, in other parts of Nigeria and imposing the payment of taxes over all types of commercial activities.

Kidnap and Sale of Young Girls

Also like ISIS, Boko Haram is engaged in organized criminal activities such as human trafficking and the sale of young girls. This activity will likely increase and not abate under an ISIS affiliation. We will begin to see the trafficking of those young girls across international borders, similar to the way in which ISIS sells young girls inTurkey and other Gulf states. ISIS publishes its price list for the sale of young girls to foreigners. It is likely that the price list was generated to shock us in the West and does not represent the true amount of money that ISIS charges for trafficking girls to foreigners. There can be no doubt that this activity for ISIS is a lucrative source of terrorist financing in the Gulf and Boko Haram may try to replicate the success of ISIS in this form of terrorist financing. We can expect to see hundreds more kidnappings of young girls by Boko Haram and we can expect that, like ISIS, certain religious groups will be targeted for social media purposes.

Like ISIS, Boko Haram will take over financial institutions and banks and seize cash deposits on hand. We can also expect that they will ostensibly take over foreign businesses and demand extortion payments to fund their activities.

Quest for Luxury Goods

Also like ISIS, we can expect that the leadership of Boko Haram will move vast sums of money to banks in Nigeria which they will then wire to tax havens and to financial capitals (Vienna, London, Paris). All terrorists leaders, almost without exception, are driven to remove wealth almost at any cost from areas of conflict because they share one dream –> sending their children to elite private school in the UK. They also share a common desire to acquire status symbols of wealth (luxury cars, mansions, chauffeurs, expensive jewelry). The common denominator of all corrupt and terrorist leaders, a drive to obtain wealth and status, is a terrorist financing and money laundering typology that makes them relatively easy to catch.

Unlike ISIS, I do not think we will see Boko Haram becoming savvy with social media in terms of recruitment or terrorist financing anytime soon, and nor do I see them being able to manage and administer agricultural and industrial activities for terrorist financing. And also unlike ISIS, I do not foresee tens of thousands of people from the West defecting to join Boko Haram. There are also religious reasons for that tied to the genealogy of the leader of ISIS.

Cash Couriers

Boko Haram, like ISIS, uses women to act as cash couriers because they know that they make more effective terrorist financiers than men and are more successful at crossing borders. The former wife of the leader of ISIS was a money mule for a long time without being detected or caught by officials. She took money from charities for Syrian refugees sent to Lebanon and moved the funds to ISIS in Syria. We can expect Boko Haram to do the same, namely to cause a large humanitarian crisis that results in humanitarian aid from the West that they take from aid agencies.

Convergence of Organized Crime & Terrorism

Boko Haram has been significantly engaged in the drug trafficking world for a number of years. ISIS recently began the trafficking of drugs on a large scale, according to residents in ar Raqqa. In this respect, we are seeing a convergence of organized criminal activities with terrorism – a disturbing trend.

To date, Boko Haram has been limited to the north of Nigeria as a regional threat and I suspect with the affiliation of ISIS, it will become a more national and international threat.

Politically Exposed Persons

Unlike ISIS, however, there are significant numbers of politically exposed persons remaining in Nigeria who are used to facilitate the financing of Boko Haram. We can expect that they will seek to immigrate to the West, now as foreign politically exposed persons, with unexplained and unexplainable wealth that is proceeds of crime and proceeds of terrorism. The one aspect of counter-terrorist financing that has always worked but is seriously under-used is the domestic and foreign politically exposed person regime. I don’t know of any financial institution that truly understands the PEP regime and implements it as it was intended to be implemented, which is unfortunate because it not only identifies and prevents the movement of proceeds of crime, it’s an exceedingly effective tool to identify terrorist financing. ISIS’ wife, for example is a PEP. So are all her family members in Iraq. I’m guessing that the Dulaimi family is significantly more wealthy now than before Saja Dulaimi married al-Baghdadi and that they have no problem using banks. With Boko Haram and Nigeria, banks need to be ferreting out PEPs.

Perhaps if regulators prosecuted for PEP failures, that would change. It’s a really easy prosecution. If there is a PEP with money in country X and the PEP’s bank did not independently identify him as a PEP and his source of funds to determine the funds are legitimate, then the PEP’s bank in country X is liable for PEP failures. It’s immaterial whether the funds are proceeds of crime.

Standard of Care

A director or officer of a bank or financial institution who fails to obtain advice in respect of counter-terrorism, including the PEP regime, and/or fails to have  adequate PEP and counter-terrorist financing controls in place, breaches the standard of care expected of an officer or director of a financial institution. They may be without much of a defence if the day comes when they are prosecution individually in anti-money laundering law. Breaching the standard of care vitiates some directors’ liability insurance policies and such directors and officers may be without money to pay for their defence. I’m guessing that not too many lawyers have informed bank executives of their exposure or we would see drastic changes in counter-terrorism compliance at banks.

Terrorism is growing around the world and so is terrorist financing, as is evident by the marriage of Boko Haram and ISIS, exposing financial institutions and their officers and directors to a wider range of compliance risks during a time when there is less tolerance for compliance failures. In counter-terrorism law, the buck truly does stop with the bank’s directors and officers.

Perhaps the allegiance of Boko Haram with ISIS in a country in which many Western nations have business interests will serve as the impetus for financial institutions to ensure that their procedures in respect of counter-terrorist financing are rock solid.

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The Jihad Express –> Gaziantep Turkey still ISIS’ conduit city of choice

By Christine Duhaime | March 8th, 2015

Updated March 13, 2015

Jihad Express

Gaziantep, Turkey appears to have emerged as a city of choice for terrorist financing and human trafficking for the Islamic State (“ISIS“) in the past twelve months and should be carefully monitored by financial institutions for financial transactions, banking, organized crime and trade-based money laundering.

Gaziantep is a city close to the Syrian border and is considered one of the key “porous” border towns, where people (including foreign fighters and terrorists) and goods illegally sold or shipped to ISIS from the Middle East or the West, can cross the Turkey – Syrian border easily. It is located 60 miles from Aleppo, Syria, a city largely under the control of ISIS. The flight from Istanbul to Gaziantep is known as “jihad express.” Reyhanli, a Turkish border town, is also a conduit town. Both places are used by foreign fighters to buy army-type gear that they need to join ISIS.

Economic Centre 

Gaziantep is known as “ISIS International” in reference to it being an ISIS hub where the group collects new recruits arriving from other countries to take them across the border, and conducts a large part of its commercial activities.  In the last two months, Turkey’s National Intelligence Organization estimated that 3,000 foreign fighters joined ISIS traveling through Gaziantep and its importance as a town economically supported by terrorist commerce is not disputed.

US Indictment

Last month, the US Department of Justice indicted six foreign nationals for terrorist financing in connection with al Qaeda and ISIS for, inter alia, allegedly using money services businesses to send money to Gaziantep where it was collected by ISIS affiliated agents to fund their activities. The Indictment also says that army-related goods were shipped from the US to ISIS via Gaziantep. A few months earlier, an organization in Egypt circulated an infographic on Twitter showing how young teenage girls from the UK are routed to ISIS through Gaziantep and how funds to pay for their travel is facilitated by a money services business in Gaziantep that accepts payments from ISIS to remit funds to the UK for teenage girls to defect to Syria.

Bethnal Green Academy

In fact, the three British brides who recently joined ISIS were filmed in Gaziantep getting into a car before crossing the border to Syria. In the video, you can see that the girls have expensive Louis Vuitton luggage. Their ISIS handler gives them new Syrian passports, which speaks to the control ISIS has over official Syrian documentation that UK nationals can be given Syrian passports in Turkey and it also speaks to the pre-planning involved for ISIS operatives to have secured their photos in passport format and issued passports for the girls purportedly from the Syrian government. The smuggling route through Gaziantep is well-organized and meets no resistance in Turkey or Syria. In the video, the ISIS handler tells the girls that there are lots of “bullets” in Gaziantep and is heard saying that Gaziantep is the “better border.” The ISIS handler was allegedly arrested by Turkey and there is video footage of that here, however, considering that the person is an alleged ISIS handler and is on a video providing material terrorist support to ISIS, it is odd that he is not handcuffed or physically constrained in public.

Hostages

Gaziantep is also being used as a location where ISIS is picking up new Western hostages. Two weeks ago, several Western journalists went missing, including a Swedish journalist. The ease with which ISIS can transact in Gaziantep, including picking Westerners off the street for kidnap-for-ransom fund raising, is an indication of the high level of tolerance that city, and its financial institutions, appear to afford ISIS’ commanders. Banks in the West should be careful of instances where their ATM products are used in Gaziantep and should consider such use a red flag, and determine whether, together with other indicia, it raises to the level of being a suspicious transaction that should be reported.

It goes without say that selling goods or services to ISIS, including financial services, is participating in terrorist financing and providing material support to a terrorist group.

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Two Bitcoin stories hit the news related to ISIS and terrorist financing allegations

By Christine Duhaime | March 5th, 2015

Bitcoin hits the news related to ISIS

There were two Bitcoin stories today in the US media with an ISIS connection, raising alarm bells regarding the potential use of virtual currencies for terrorist financing.

The first story was that a teenager in Virginia had been arrested by the FBI for allegedly facilitating a person to travel to Syria to join the Islamic State.  According to BuzzFeed.com, the teenager wrote for a Bitcoin newspaper called “CoinBrief” and covered virtual currency news developments. The teenager apparently also operated a Bitcoin exchange that sold Bitcoin.

His sympathetic leanings in respect of ISIS may have been predicted – in 2013, according to BuzzFeed, the teenager wrote an article lauding the practice of human slavery as a “peaceful” way of integrating “belligerent” women and children into society as opposed to “killing them”, whereby (according to the teenager], non-Muslims would learn to accept Muslim culture.

The allegation that the teenager assisted a person to travel to Syria may have arisen in the context of the teenager having sold or exchanged Bitcoin for the person who travelled to Syria. The indictment remains sealed until the teen is approved for prosecution as an adult.

Bitcoin via Twitter Tips

The second story is surreal and I only learned of it from a chief global compliance office at a major US bank, a fact that should indicate the concern among global banks over how companies in the Bitcoin space continue to miss cues on, and fail to report, serious financial crime such as terrorist financing.

This story involves the use of a Bitcoin tipping service that was allegedly used for terrorist financing. A person allegedly used the tipping service to send $1 via Twitter to another person whom the sender believed was a member of ISIS.  According to the story, it appears that the sender deliberately and knowingly completed a financial transaction over the Internet to engage in terrorist financing to benefit ISIS as a test. Later, the sender is alleged to have commented that he was not yet “in jail.” Terrorist financing is the type of indictable criminal offense which has zero prosecutorial or judicial forgivability and I have a hard time believing that a person would fund terrorism on the Internet as a test and risk a lifetime term of imprisonment for it. More problematic, the test got publicity and now legally exposes the tip service and the sender just educated people on terrorist financing using Bitcoin.

The article then goes on to quote a company spokesperson from the tipping company commenting about freedom of speech, the relevance of which is unclear. Nothing in the US Constitution or the 1st Amendment protects terrorist financing as a form of freedom of expression.  Sending Bitcoin via Twitter, regardless of the mechanism, is not an exercise of freedom of speech – it is a financial transaction and there is no protected right to conduct a financial transaction.

It remains unclear whether anyone at the Bitcoin tipping company filed the requisite reports to federal law enforcement over the terrorist financing.

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Europol calls Bitcoin perfect money laundering tool; says organized crime is quickly changing; and says the return of Robin Hood-like criminals that deprive the rich of wealth will be socially acceptable

By Christine Duhaime | March 4th, 2015

In a report released yesterday on serious organized crime called “Exploring Tomorrow’s Organized Crime” (the “Report“), Europol found that organized crime is now becoming a virtual activity over the Internet and as a result, transnational criminal organizations (“TCO“) are migrating towards virtual payment methods to conduct commercial affairs, including virtual currencies such as Bitcoin. According to Europol, the move to virtual currencies eliminates face-to-face interactions (and reduces identity risks for organized criminals), allowing anonymous exchange of currency and financial resources.

Most surprising of all in the Report is the statement that Robin Hood criminals (my phraseology), who deprive rich people of their wealth illegally will be viewed by people as socially acceptable because of the growing disparity in wealth. I think the whole world (except obviously rich people) agrees that the wealth disparity issue needs to be solved quickly for global stability and security but surely the day will not emerge when criminals who rob from the rich are lauded for their efforts – or will it? It is an interesting projection that socially-speaking, crimes against the rich will be not only be tolerated but accepted if the result is a re-distribution of wealth to criminals. The Report’s conclusion is that there are insufficient resources to police the change to TCOs operations so does that also mean, rhetorically-speaking, that stealing from the wealthy will not be prosecuted because the criminal activity will be socially acceptable.

Key facts from the Report are as follows:

  1. Innovation will increasingly allow TCOs to commit crimes anonymously.
  2. Big data will be exploited by TCOs to extort people and businesses on an unprecedented scale, as well as to commit fraud using stolen personal information. The more people provide personal data to more and more organizations, the more they become exposed to criminality.
  3. The “rich are getting richer” problem in the EU is making people more readily accept TCO criminal activities that target the wealthy if the crimes deprive the rich of their wealth.
  4. TCOs continue to infiltrate natural resources all over the world as agents (wind farm projects, natural gas, solar energy, etc.). They continue to prefer green energy sector and have successfully infiltrated those sectors.
  5. Virtual currencies like Bitcoin facilitate money laundering and alleviate the need for old-fashioned and costly criminal infrastructure. The anonymous nature of virtual currencies and their rapid transferability make them ideal for money laundering, especially if used with illegal forms of online gambling.
  6. Bitcoin has become the currency of choice for internet-facilitated crime.
  7. The proliferation of virtual currencies will allow an entire criminal economy to flourish with little possibility of law enforcement intervention.
  8. Virtual currencies will be used for human trafficking, drug sales, sex trade and the purchase of illegal goods.
  9. With respect to terrorism, anonymous marketplaces on the Internet for goods and services that are illegal carry the risk of convergence of terrorism and organized crime.
  10. The return of terrorist defectors (from places like Syria) who are radicalized will join the TCO underworld and drive some of its activities. Part of the concern here is that ISIS for example, has told locals in ar Raqqa that they are sending foreign fighters home under the pretext of being “defectors from ISIS” in order to accelerate terrorism in the West, on the assumption that Western nations will  believe that ISIS defectors have not been radicalized and did not commit war crimes (more on that here).
  11. Part of the solution for law enforcement will have to be public-private partnerships to get on top of TCOs and their activities.
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Counter-Terrorism in the Post-ISIS Era

By Christine Duhaime | March 1st, 2015

The Association of Certified Anti-Money Laundering Specialists (“ACAMS”) is holding a two-hour webinar on managing counter-terrorism risks and threats in the post-ISIS era this week.

In addition to us, the speakers are Martin Cunningham (Standard Chartered), Amit Kumar (Georgetown University) and Dennis Lormel (DML Associates).

Topics are wide-ranging and include organized crime, terrorist financing typologies and risks, red flags, high risk jurisdictions, recent terrorist attacks, security risks, critical infrastructure, the FATF Recommendations, Bitcoin and digital terrorism with a discussion on ISIS financing.

The link to register is here.

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Counter-Terrorist Financing Presentation in Toronto

By Christine Duhaime | February 13th, 2015

With the Association of Certified Anti-Money Laundering Specialists, we’re organizing a special presentation on “Terrorist Financing Concerns & Risks in Ontario for the Financial Services Sector” on February 24, 2015, in Toronto. The presentation will be given by the OPP’s Deputy Commissioner, Scott Tod, and Deputy Director of FINTRAC, Barry MacKillop, and is sponsored by Thomson Reuters.

It is a great step in making Canada a leader in counter-terrorist financing initiatives. You can contact Christine Duhaime to register for the event. Space is limited.

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