Growing protests over corruption in global hot spots means increased risks of the movement of proceeds of corruption from PEPs to the West

2019 seems to have been a record year for mass protests by citizens marching against national corruption – at least 10 countries have had massive protests in the last few months, many of which are ongoing. Corruption at the national level is perpetrated by politically exposed persons (“PEPs“) who have access to the country’s coffers, […]

Two US lawmakers introduce bills to prevent Iran from developing an ICO

Two US lawmakers introduced bills to prevent Iran from being able to grow its planned government issued sovereign initial coin offering, or its own digital currency. Both bills add criminal liability to persons, financial institutions, correspondent banks and digital currency exchanges that facilitate transactions involving an Iranian digital currency. That criminal liability is in addition […]

The CIA on terrorism and tech

On June 16, 2016, the Director of the CIA testified before the Senate Select Committee on Intelligence in respect of the Islamic State (ISIS), terrorism and technology generally. Here is an executive summary: The CIA said there there has never been a time when there is such a “dizzying” array of national security issues and […]

A banker’s update on terrorist financing and money laundering from the US Committee on Homeland Security

Summary of the Updates The US House Committee on Homeland Security released a number of updates and received testimony on the status of terrorist financing, terrorism and money laundering in the last few weeks with some interesting developments relevant to banks in terms of changes in terrorist financing typologies that should be added to anti-money […]

Summary of the 2016 US Threat Assessment

The Worldwide Threat Assessment of the US Intelligence Community (the “Report“) prepared by the Director of National Intelligence on February 9, 2016, is a very interesting read from a counter-terrorism perspective, and essential reading for any bank in respect of assessing client and regional risks. Generally, the Report is dead on in respect of the […]

Canada and the fake refugee passport issue

Fake refugees — A crisis within a crisis It seems to becoming clear that it is not reasonably possible to rely on the identity documents of any persons who claim Syrian or Iraqi refugee status from 2014 onwards, the time in which the Islamic State acquired the capacity to create authentic passports. Since at least […]

FinTech and Terrorist Financing – a major RegTech issue

The news last month that the couple responsible for the San Bernadino shooting had received a P2P loan for $28,000 from an online lender, Prosper Marketplace, was cause for concern among financial crime regulators. It was cause for concern because some financial regulators were of the view that a typology for terrorist financing is the […]

New US law brands journalists and humanitarian aid workers as terrorist risk

In this story in Quartz, we explore how a new US law, HR158, the Visa Waiver Program Improvement Amendment Act 2015, will result in journalists and humanitarian aid works, and many others being branded a terrorist risk for visiting Iraq, Syria, Iran and the Sudan, and how the new law will affect the ability of […]

France’s top lawyer says there’s no reason to be optimistic on terrorism front

Francois Molins, France’s top prosecutor, says that the risk of terrorism is becoming larger, more multi-faceted and complex. In this interview (en francais), Maitre Molins talks about the threat of terrorism in France and some of the investigation and prosecution challenges in respect of counter-terrorism. No reason for optimism in terrorism Mr. Molins said that […]

US approves law limiting access to the US for people who visited or are from Iran, Iraq, Syria & Sudan

A “Terrorist Risk” Following the terrorist attack in San Bernadino on December 2, 2015, an 11-month-old relatively dormant bill to amend an American law to impose visa restrictions on select foreign nationals entering the US gained traction when it was rapidly enacted in the US. US Bill H.R. 158, the Visa Waiver Program Improvement Act […]