Dear all,

this was posted to Acams List earlier and wanted to share it with BOL People.


I am Positive that every one of ACAMS Members has gone through the financial profile of Sep. 11th hijackers’ domestic accounts many times and applied his/her Analysis skills to reach a result that would benefit his/her Financial Institution not to be abused by terrorism Financers, which is the goal of all us who sit on the sharp edge of the fight against Money laundering and terrorist financing.



However , when this analysis was conducted by FBI ) where the result was published through the Testimony of Dennis M. Lormel, Chief, Financial Crimes Section, FBI , ( http://www.fbi.gov/congress/congress02/lormel021202.htm it gave us ( Middle eastern Bankers and AML Specialists ) a chance to do our own Analysis taking into consideration that the 19 Hijackers come from the same region and culture as our selves , and since we share that together with those terrorists , we are Much More able to Judge, analyze on the Financial & Non – Financial Profile ( even though we don’t have an access to all related financial information like the law enforcement has ) .





in order to achieve that goal we ran something similar to Focus groups ( where the financial profile was translated into Arabic and distributed to AML Training participants who some of them has a rich banking experience up to 20 years .we requested all to read the profiles carefully and pinpoint to us which of those indicators can indicate any thing related to terrorist activity or if a certain pattern was constructed through all ( or some of ) those indicators or any other Comments , this exercise was done in various countries in the Middle east & North Africa during AML Training ( Jordan , Egypt , Dubai , Libya ) .



to our amazement , more than 80 % of participants said : That the financial profile of Sep. 11th hijackers' domestic accounts reflects an ordinary “ Middle eastern “ Banking Practice , which means in other words , if you chose a group of ACAMS “ Middle eastern “ Members between 5 – 10 members and send them to USA or Europe for a 2-3 Month period and then run an analysis of their “ Financial and Non Financial - Profile “ it will come very close ( up to 85 % ) of the profile of Sep. 11th hijackers' domestic accounts .






What does that tell us?


- All Middle eastern Cant be terrorists , even if their Financial and non financial profiles almost Match



- The FBI Analysis lacked an understanding of “ Middle east “ Banking Culture & Practice ( that was shown is many indicators in the profile which the interpretation by a Middle eastern differs considerably than that of the FBI )- those indicators are related to account profile , transaction profile , international activity , non-financial profile )



- The Biggest Fear would be that this Profile analysis sends the wrong message to The US Financial institutions in the sense that “if among your customers you spot such a profile, then it might indicate that your bank is being used as a channel for terrorist funds or a step in launching a terrorist attack somewhere in USA “, Which will Double or Triple the Number of SARs ** and will Keep law enforcement and intelligence on alert Most of the time.

** SARs filed relating to terrorism (by Calendar Year(CY) quarters) :

- CY 2001 – 4TH Q = 985 SARs

- CY 2002 – 1ST Q = 645 SARs

- CY 2002 - 2ND Q = 567 SARs

-




- this will scare the US Arab – Middle eastern Abiding by the law citizens , even though their banking " culture Practice " is US based since they Lived there for along time and their Financial profile wouldn’t even come close to that of the Sep.11th Hijackers.



- The US Banks will spend more time, effort, Money , looking for such similar Profiles (matching or even come close) to those of Sep/11th Hijackers rather than doing their AML & CFT Due Diligence according to US Patriot ACT. Or some banking - maybe- will be doing both which is a headache.




I know this will draw lots of questions and comments, which is most welcome , since we all stand on the same front of the war against Money Laundering and terrorist Financing.

Thanks for the interesting post.

Very interesting! Thanks, Hussam! And it's good to "hear" from you again.

Hussam - it doesn't really surprise me since one of the methods used by Al Queda was for the front level operatives to appear as "normal" as possible so they would blend in to the society around them and not attract attention to themselves.

IMHO - Without additional information about who could be a suspected terrorist, Banks will not be able to detect front level terrorist operations because $300 withdrawn from an ATM by a customer could easily buy a night on the town or materials to make a bomb.

That's why I am hoping the 314(a) lists are carefully focused, and all we can do is file SAR's when we find activity we can't explain or is just out and out blantent.

I have a friend who is a forensic accountant who said that, in all likelihood, banks will only be able to detect the activities of the really stupid criminals. Depressing thought!

Unfortunately, the same conclusion was reached here last year. There was nothing remarkable or unique in the terrorists' financial activities; they accomplished their goal of blending in financially:

Nothing the hijackers did would have alerted any bank personnel to their being criminals, let alone terrorists bent on mass murder. Their transactions were routine and caused no alarm. Their wire transfers, in amounts from $5,000 to $70,000, were utterly anonymous in the billions of dollars moving through the international financial system on a daily basis. Their bank transactions, typically large deposits followed by many small ATM or credit card withdrawals, were entirely normal, especially for foreign students living in the United States. No financial institution filed a suspicious activity report (SAR) and, even with benefit of hindsight, none of them should have. Contrary to numerous published reports, there is no evidence the hijackers ever used false Social Security numbers to open any bank accounts. In some cases, bank employees completed the Social Security number fields on the new account application with a hijacker’s date of birth or visa control number, but did so on their own to complete the form.

Staff Report to National Commission on Terrorist Attacks
Upon the United States, pages 52 & 53.

In addition, some of the activities mentioned in other narratives: frequent calls to the bank (to determine balances or to see if wires had arrived), as well as several attempts to withdraw more money than the accounts actually held, are even typical of U.S. customers. Any "profile" based on these activities would generate many, many false positives; it would be unworkable.

As Bonnie indicates by alluding to the 314(a) queries, within this country there is increasing comprehension of the fact that U.S. banks cannot be expected to detect terrorist financing based on transaction patterns. In this arena, the paradigm has shifted to banks relying on the U.S. government to identify suspects and then expecting banks to find those organizations or individuals in their customer lists. U.S. banks are not attempting to identify terrorist financing through the review of consumer transactions based on models derived from the terrorists' activities.

Dear all ,
thanks for Your comments , I agree to what Bonnie and Ken said , which triggers a Nother question from My side .

Ken said :"In this arena, the paradigm has shifted to banks relying on the U.S. government to identify suspects and then expecting banks to find those organizations or individuals in their customer lists. U.S. banks are not attempting to identify terrorist financing through the review of consumer transactions based on models derived from the terrorists' activities".

what a bout the " sleeping cells " or those " Ordinary US Citezens " who never left to recive training in Afganistan or those " who did not have any burns or harsh training marks on their hands when checked upon returning from Pakistan "...those will not appear as " suspects " on any US Gov. agency List ? and as what we witnessed in London Bombings ,,,,the terrorists were Born and raised in UK but still their terrorist nature overcomed them and they did what they did.

How can those be Idnetified at Financial institiuations?

'Who knows what evil lurks in the heart of men' - or something like that.
We can give extra due diligence to those customers who have wire activity with certain targeted countries, but in reality the average extremist act does not require much money, and it probably will not go though any of our banks.
I agree with Bonnie - the local Muslim communities will sooner know who the next extremist is - not the bankers.

Understandably, SARs relating to suspected terrorist financing spiked shortly after 9/11 and then went down. Those filings have risen again somewhat steadily since the 1st quarter of 2003. There's a highly detailed analysis begining on page 5 of the most recent issue of the SAR Activity Review.

As far as a bank's ability to catch terrorists who blend into our society, we have no illusions - it cannot be done unless we decide to close our society and exclude many people who are already here. This is no surprise. When our government announced its requirements for banks to develop "Customer Identfication Programs" this was in the preface of the comment letter I wrote:

It is worth noting that the USA PATRIOT Act was prompted by the actions of foreign, not domestic terrorists. Nevertheless, this proposal does nothing to require or facilitate better identification of nonresident aliens – BSA regulations already require banks to obtain evidence of foreign citizenship and record the information. It is Kafkaesque that our country’s attempt to keep international terrorists out of the banking system is entirely focused on getting better identification from U.S. citizens.