FINANCING OF THE TERRORIST ORGANISATION ISLAMIC STATE IN IRAQ AND THE LEVANT (ISIL)
10
2015
ISIL to move funds and other assets, including the regulated banking system, Money and Value
Transfer Services (MVTS) and smuggling cash, gold and other valuable items. Information was also
received on preventative or specific measures taken or being considered by jurisdictions to combat
this terrorist financing (TF) threat. A significant portion of the data related to this subject is of a
sensitive nature and therefore could not be included in this public report.
NATURE AND EVOLUTION OF THE TERRORIST THREAT
ISIL, which is the successor to Al-Qaida in Iraq (AQI), has undermined stability in Iraq, Syria and the
broader Middle East through its terrorist acts and crimes against humanity, and poses an immediate
threat to international peace and security.
6
Prior to ISIL’s expansion of territorial control in parts of
Iraq and Syria, the group (and its predecessor, AQI) benefitted from a network of associates in Syria,
which it used to facilitate travel to Iraq.
7
ISIL persecutes individuals and entire communities on the
basis
of their identity, dissent, kidnaps civilians, forces displacement of communities and minority
groups, kills and maims children, rapes women and commits other forms of sexual violence, along
with engaging in numerous other atrocities.
8
ISIL presents a global terrorist threat which has
recruited thousands of FTFs to Iraq and Syria from multiple countries across the globe and
leveraged technology and other resources to spread its violent extremist ideology and to incite
terrorist acts.
9
ISIL seeks to change the political order primarily in the Middle East through its
extremist ideology and terrorist violence and aims to bring most traditionally Muslim-inhabited
regions of the world under its political control, beginning with Iraq and the Levant.
10
ISIL's operations are distinct from those of most other terrorist organisations, particularly with
respect to how they finance their operations. Compared to Al-Qaida (AQ) core and AQ affiliates such
as the Al-Nusrah Front (ANF), there are notable differences in their leadership and operational
structures. Unlike some AQ associated organisations, most of ISIL’s funding is not currently derived
from external donations, but is generated within the territory in Iraq and Syria where it currently
operates.
11
Distinct from most terrorist organisations, ISIL is operating in vast swathes of land
across Syria and northern Iraq, allowing ISIL to exploit the local population and material
resources
through extortion of, and theft from residents. ISIL takes advantage of the resources in this domain,
ranging from oil and banks to leveraging utilities and taxing local economies. According to several
delegations, ISIL has been engaging in energy-related commerce with the Syrian regime, despite
claiming otherwise.
ISIL obtains the vast majority of its revenues through local criminal and extortion activities in the
territory where it operates (see sources of funding below), which present unique challenges for the
international community but also presents a declining revenue base if it is unable to find alternative
6
The Al-Qaida and Taliban Monitoring Team (2014), hereafter Monitoring Team Report on ISIL and ANF
(2014)
7
Levitt, M. (2010).
8
Monitoring Team Report on ISIL and ANF, at 10.
9
Id. at 11.
10
Id. at 6.
11
Id. at 19-20.
FINANCING OF THE TERRORIST ORGANISATION ISLAMIC STATE IN IRAQ AND THE LEVANT (ISIL)
2015
11
sources of revenue or take additional territory. Unlike core-AQ, ISIL currently derives a relatively
small share of its funds from deep-pocket donors (relative to its other revenue sources), and thus
does not depend principally on transferring money across international borders for this purpose.
Available research on ISIL’s organisational structure suggests that it is hierarchically organized and
that ISIL recreates its top level leadership structure at the group’s provincial level.
12
FATF, UNITED NATIONS AND OTHER STATEMENTS ON ISIL
Building on the condemnation by the United Nations and others of ISIL's illicit activities, on 24
October 2014 the FATF expressed profound concern with the financing generated by and provided
to ISIL, highlighted the importance of robust implementation of the FATF standards to disrupt and
prevent ISIL financing and called on all countries to take steps to prevent ISIL from accessing their
financial systems. The FATF noted that ISIL is subject to sanctions under the United Nations Al-
Qaida Sanctions List. Recently, UNSCR 2170 (2014) and 2199 (2015) identified ISIL-related funding
streams, including revenues generated from control of oil fields and related infrastructure,
kidnapping for ransom, private donations from individuals and entities, fundraising through the
internet and possible sanctions evasion through aircraft or other transport to transfer gold, or other
valuable items and economic resources for sale on international markets. In addition, UNSCR 2178
(2014) requires all member states to prevent and suppress the financing of FTFs, including their
travel and subsequent activities.
The Kingdom of Bahrain hosted the Manama Meeting on Combating the Financing of Terrorism on 9
November 2014. The meeting was for participating countries to demonstrate their commitment to
put a halt to the financing of terrorist groups and activities in all its forms. The FATF welcomed the
determination of the participating countries to fight terrorism in the region. The closing declaration
of the Manama meeting is a valuable step forward, showing the strength of international
commitment, and the relevance of the counter-terrorist finance tools set out in the FATF
Recommendations and UNSCRs. In particular, the statement emphasized the need for the full and
effective implementation of the FATF Recommendations and active participation in the FATF's
global network by countries in the region.
13
12
Lister, C. (2014).
13
Kingdom of Bahrain, Ministry of Foreign Affairs (2014).