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Aspects of Financial Transactions that May Indicate Terrorist Financing

This section of the SAR Activity Review provides information related to potential terrorist financing activity. This information has been obtained from a variety of sources, including:

  • reconstruction of the September 11th hijackers. financial transactions by law enforcement;
  • FinCEN's analysis of SAR filings in combination with other Bank Secrecy Act (BSA) data and other information available to the government;
  • analysis of SARs filed by financial institutions since September 11th; and Financial Action Task Force (FATF) efforts.

Since September 11th, it has become even clearer that the BSA and other antimoney laundering measures can assist in the fight against terrorism. However, it is also apparent that it can be difficult to definitively identify terrorist fundraising activities separate and apart from traditional money laundering and financial crime activities.

Currently, there is no exhaustive or exclusive list of .terrorist indicators. that the government is able to provide. FinCEN and law enforcement continue to develop indicative and distinct typologies which may be associated with terrorist financing. A complete understanding requires examination at the global level. Further input from the law enforcement community, as information is compiled and analyzed, should serve this effort.

Information provided in this SAR Activity Review comes from a variety of sources, some of which are only available to the government. This information may be useful to financial institutions in detecting suspicious transactions that either potentially involve terrorism, or are not commensurate with normal activity and may later prove to be related to terrorist financing.

Financial transaction activity alone may not identify terrorist financing. However, financial institutions are often in a position to compare that activity with other information provided by the government that could produce significant leads and other useful information regarding potential terrorist activity. Law enforcement and the regulatory agencies will continue to provide the industry such information as may appropriately be made public to assist them in that effort.

Excerpted from SAR Activity Review Issue 17, page 17

First published on 05/01/2010

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