Terrorism Financing - Suspicious Activity

Suspicious Activity

Operation Green Quest was the US multi-agency task force set up in October 2001 to combat terrorism financing and had developed a checklist of suspicious activities. The following patterns of activity indicate collection and movement of funds that could be associated with terrorism financing:

1. Account transactions that are inconsistent with past deposits or withdrawals such as cash, cheques, wire transfers, etc.
2. Transactions involving a high volume of incoming or outgoing wire transfers, with no logical or apparent purpose that come from, go to, or transit through locations of concern, that is sanctioned countries, non-cooperative nations and sympathizer nations.
3. Unexplainable clearing or negotiation of third party cheques and their deposits in foreign bank accounts.
4. Structuring at multiple branches or the same branch with multiple activities.
5. Corporate layering, transfers between bank accounts of related entities or charities for no apparent reasons.
6. Wire transfers by charitable organisations to companies located in countries known to be bank or tax havens.
7. Lack of apparent fund raising activity, for example a lack of small cheques or typical donations associated with charitable bank deposits.
8. Using multiple accounts to collect funds that are then transferred to the same foreign beneficiaries
9. Transactions with no logical economic purpose, that is, no link between the activity of the organization and other parties involved in the transaction.
10. Overlapping corporate officers, bank signatories, or other identifiable similarities associated with addresses, references and financial activities.
11. Cash debiting schemes in which deposits in the US correlate directly with ATM withdrawals in countries of concern. Reverse transactions of this nature are also suspicious.
12. Issuing cheques, money orders or other financial instruments, often numbered sequentially, to the same person or business, or to a person or business whose name is spelled similarly.

It would be difficult to determine by the activity alone whether the particular act was related to terrorism or to organized crime. For this reason, these activities must be examined in context with other factors in order to determine a terrorism financing connection. Simple transactions can be found to be suspect and money laundering derived from terrorism will typically involve instances in which simple operations had been performed (retail foreign exchange operations, international transfer of funds) revealing links with other countries including FATF blacklisted countries. Some of the customers may have police records, particularly for trafficking in narcotics and weapons and may be linked with foreign terrorist groups. The funds may have moved through a state sponsor of terrorism or a country where there is a terrorism problem. A link with a Politically Exposed Person (PEP) may ultimately link up to a terrorism financing transaction. A charity may be a link in the transaction. Accounts (especially student) that only receive periodic deposits withdrawn via ATM over two months and are dormant at other periods could indicate that they are becoming active to prepare for an attack.

The Operation Green Quest raids led to the convictions of two people, including Abdurahman Alamoudi, who worked for the SAAR Foundation. Alamoudi admitted that he plotted with Libya to assassinate the Saudi ruler and was sentenced to 23 years in jail.