Countering Terrorism Finance The Current Regime. Tony Doyle Economic Crime Division Guernsey Border Agency

Transcription

1 Countering Terrorism Finance The Current Regime Tony Doyle Economic Crime Division Guernsey Border Agency

2 Terrorism Laws & Regulations Bailiwick of Guernsey The Terrorism and Crime (Bailiwick of Guernsey) Law, 2002 (As amended). The Terrorism and Crime (Bailiwick of Guernsey) Regulations, 2007 (As amended). The Disclosure (Bailiwick of Guernsey) Regulations, 2007

3 Terrorism & Crime Law, 2002 Section 7 Terrorist Property Section 8 Fund raising Section 9 Use and possession Section 10 Funding arrangements Section 11 Money laundering Section 15 Failure to disclose Financial Services Businesses Section 18 Forfeiture of property Section 19 Forfeiture of terrorist cash

4 Relevant legislation Code of Practice Trust Service Providers (2009) Published by the GFSC under Sec 35 of the Regulation of Fiduciaries, Administration Businesses and Company Directors, etc. Law, 2000 Integrity & Know Your Client

5 AML Fines HSBC Holdings Plc agreed to pay a record $1.92 billion in fines to U.S. authorities for allowing itself to be used to launder a river of drug money flowing out of Mexico and other banking lapses.

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7 Truism No terrorism without finance

8 So what is Money Laundering and what is Terrorist Financing? Raise Use TF Store Move

9 Global Terrorism Index /2015 (Institute for Economics and Peace) 34.8bn 21% 7, bn

10 Attacks evolving $ ,000 7,235 48

11 7 July dead & 747 injured 7,235

12 How it was financed Self-financed Mohammed Siddique Khan employment; loans Lindsay - cheque fraud

13 Financial Investigation achievements Identification of suicide bombers. Identification of some of the victims and witnesses. Identification and evidence of all purchases relating to the manufacture and transportation of the bombs. Identification of criminality and associates Evidence of total cost of the attack

14 Accessibility

15 Headline news?

16 Financial Times 19 September 2010

17 Funding Who financed the Paris attacks? Two charged in Birmingham for giving Mohamed Abrini 3,000 - April 2016 ISIS / ISIL / Daesh How does it affect Guernsey? UNSCRs 1267 and

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19 They have also issued (2008) a guidance document on adopting a Risk Based Approach for TCSPs. Should be read in conjunction with the Recommendations' Risk categories: Countries/Geographic Customer Product/Service

20 Financial intelligence is a very powerful tool %

21 Terror Finance efforts are still failing According to a recent RUSI document, we are in no better place today with tracking TF, then we were when 9/11 happened. This is because too many barriers and inefficiencies prevent those dealing with financial information, including banks and law enforcement from extracting real value.

22 Partnerships needed RUSI paper The role of Public-Private Partnership

23 Guernsey SARS Of these, 3 were TF SARS E-casino Insurance TCSP

24 UKFIU SARS Oct 2014 Sep ,882

25 Mortgage fraud and the connection to terrorism.

26 Abid Haider AKA Adam Khan

27 Greed

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29 Case study - Operation Mazhar.

30 Bektasevic commentary we are prepared to attack and will attack the Kuffars who are killing our brothers and Muslims in Iraq, Afghanistan and Chechnya and many other countries. These weapons are going to be used against Europe, against those who have their forces in Iraq and Afghanistan. We are ready to attack

31 Young, gifted and dangerous. Younes Tsouli Aged 22 at time of arrest Waseem Mughal Aged 21 at time of arrest Tariq Al-daour Aged 19 at time of arrest

32 Set up over 75 websites Publish propaganda of AQ Promote ideology of AQ Incite killing of disbelievers Recruit suicide bombers

33 Latest trends - UK Low level fraud; Benefits fraud; Drug dealing; Street robbery; ABPs

34 A brief look at indicators FIUs and Terrorist Financing analysis Behavioural Indicators Parties to transaction from countries known to support terrorist activities and organisations. Use of false corporations, including shell companies. Inclusion on the UN 1267 Sanctions list Media reports client linked to known terrorists Beneficial owner not properly identified. Use of nominees, trusts, family member or third party accounts Use of false ID Abuse of NPO

35 Red flags?

36 Thank You