FINANCING OF THE TERRORIST ORGANISATION ISLAMIC STATE IN IRAQ AND THE LEVANT (ISIL)
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that the trucks contained material for radical groups in Syria, organized by charity groups in that
country. The source country’s authorities claimed to not be able to stop the trucks themselves due
to lack of sufficient regulations. It should be emphasized that the above examples are relatively
isolated in nature, and while certain payments, from, to or through NPOs operating in these areas
may require higher due diligence, they are not meant to imply that all transactions to or through
NPOs operating in these areas are high risk.
Case Study 2:
Diversion of Funds by Actors to NPOs
An individual (Mr. A) established a charitable foundation under the pretext of collecting donations
for Syrian refugees, people in need of medical and financial aid, and construction of mosques,
schools and kindergartens. However, Mr. A was the leader of an organized scheme in which
donations were sent to a group of individuals related to Mr. A (Group A) instead of the foundation's
account. In most cases, the first stage involved money being sent through money remitters and then
transported in cash. The money was then transferred either to credit cards accounts or to e-wallets.
The members of Group A placed the relevant information (that funds are being collected for the
declared purposes) on the Internet, but, in fact, the funds were sent as an aid for terrorists and their
families and meant to be used as a financial support for terrorist activities.
This information was discovered through investigations conducted by the FIU based on regular
monitoring of entities on their domestic list of designated terrorist entities and related persons or
on information provided by law enforcement. Analysis of the collected information allowed the FIU
to identify the relation between different cases: common payers and recipients and similar modus
operandi in collection and distribution of funds. Further cooperation with law enforcement
authorities allowed the FIU to establish the direct link between Mr. A and ISIL's activity. This
resulted in several criminal investigations related to Mr. A. In addition, Mr. A was listed on the
domestic list of designated terrorist entities, with the relevant freezing procedures performed.
Under the court decisions, assets of the Group A members were frozen.
Source: Russian Federation
4. MATERIAL SUPPORT TO INCLUDE FOREIGN TERRORIST FIGHTERS
The term material support is used as outlined in the FATF definition of “funds and other assets,”
which includes “financial assets, economic resources, property of every kind.” Foreign terrorist
fighters (FTFs) continue to be a relatively small, but important source of funding for ISIL. This
includes FTFs collecting money in their home country for travel; FTFs traveling with funds and
Diasporas sending funds to support FTFs. These volunteers and their respective social networks are
the source from which ISIL receives some physical and monetary support. According to US
government information, as of December 31, 2014, at least 19,000 FTFs from more than 90
countries have left their home countries to travel to Syria and Iraq to join ISIL. This pool of
international supporters is the source from which ISIL receives both physical and some monetary
support.
While significant in terms of manpower, the overall financial contributions from such
sources are relatively low.
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21
The following graphic
51
details the breakdown of which countries FTFs are originating from
52
.
Graphic 1. Breakdown of FTFs by country of origin
ISIL has benefitted from supporters developing recruitment hubs in various places around the
world.
53
The payment of fighters and the development of international recruitment hubs are
endemic to a global movement, as seen in the case of core-AQ. Managing a multinational operation
and the logistical and financial framework will require, in one form or another, use of the
conventional banking system. Finland has reported that a common methodology for financing FTFs
51
Based on a information originally published by the Washington Post on October 30, 2014. While the graphic
and associated story estimates the number of FTFs at approximately 15 000 FTFs from 80 countries,
this is not the most current estimate of FTFs, which has been included above. Nonetheless, the broader
geographic trends in FTF origination illustrated are still accurate.
52
Miller, G. (2014).
53
Monitoring Team Report on ISIL and ANF, at 28; Dalton, M. & Coker, M. (2014).
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is to send money via money remitters (i.e. MVTS) who have agents operating in border areas close
to ISIL held territory. This is to finance them once they are in Syria/Iraq.
The Netherlands authorities have observed that in some cases FTFs have to pay for their own living
expenses and to that end receive funds from their respective home countries. Such transfers have
been found to vary from several hundred euros to several thousand euros per transaction. The
Netherlands has detected funds being transferred via regulated money and value transfer systems
(MVTS) to agencies located near territories where ISIL operates. Netherlands authorities regard it
highly likely that in other cases intermediaries transport cash to areas near territory occupied by
ISIL. The Netherlands has also found indications that FTFs use debit-cards that are linked to their
national bank accounts when withdrawing money from ATMs alongside those areas where ISIL
operates. (See page 17 for US case study on continued access to bank accounts by FTFs.)
Case Study 3: Material Support
A suspicious traveller from a Nordic country arrived in İstanbul Sabiha Gökçen Airport. Upon his
interview by the competent authorities, he admitted that he travelled to Turkey with the intention
of traveling to Syria and to join ISIL. This case involves the use of material support as resources.
Camouflage, AK-47 type gun parts and cartridges, a first aid kit, three knives, binoculars, batteries,
sport shoes, wire ropes, torches and military supplies were found in his luggage. He was denied
entry into Turkey and was deported to his country of residence.
Source: Turkey
Suspected FTFs are also seen funding their own travel to ISIL-held regions to join the group’s
terrorist campaign. Self-funding scenarios are often limited to the purchasing of airline tickets or
physically carrying small amounts of cash (less than USD 1 000) which are often based on personal
earnings. Many of these fighters travel to Syria and Iraq with just enough cash to finance their travel
expenses, while some abuse the cash declaration or disclosure requirements for cross-border
transportation, sometimes taking significant sums of cash across borders into Syria and Iraq to the
benefit of ISIL. While these methods are often difficult detect, it provides an opportunity for
relevant authorities, such as Financial Intelligence Units (FIUs) and border agencies to work
together to detect instances of terrorist financing.
Case Study 4: Examples of identified revenue streams of FTFs
•
Proceeds of robbery and drug trafficking
•
Social benefits, from unemployment to family allowances
•
Non paid off consumer loan, below 10 000 euros, withdrawn in cash
•
Opening of several bank accounts and use of bank overdraft limit to withdraw cash
•
Donations by family, friends and supporters, raised through social media, and sent by cash
or wire transfers
Source: France