AML program

High risk regions for Terrorist Financing

The activities of terrorists and terrorist groups puts every country at risk. As result, each country has to have a proper understanding of the nature of the exposure to such risks and improve its counter-terrorist-financing regime and the extent to which its financial system is connected to those higher risk jurisdiction.


Homegrown terrorists still represent the principal threat to European countries. These individuals are radicalized online, consult online tutorials and possibly connect with other radical elements through encrypted Internet applications. They do not require contact with the ISIL core or its authorization to claim attacks in its name.

It is reported that European foreign terrorist fighters in the Syrian Arab Republic and Iraq continued to provide an income stream for ISIL through a financing network across Europe. Financing from relatives was regularly observed, including through intermediaries based in Turkey. No observed large-scale organized fundraising in Europe on behalf of ISIL or Al-Qaida. Funds entering the ISIL core area often arrive in Turkey through money service businesses and then reach beneficiaries via hawala or cash courier. 

Despite weaknesses in the current structure, the threat of a planned complex attack in Europe, especially by former expert operatives who have the ability to operate independently, is assessed to persist. Al-Qaida has also shown interest in large-scale attacks against symbolic European targets. In this regard, HAD is assessed to have a global agenda, including international attack planning and the establishment of clandestine structures.


Canada Terrorist Financing Assessment: 2018

Canada Terrorist Financing Assessment: 2018

Please see below some notes from the document:

The document examines Canada terrorist financing risks related to jurisdictions that meet one of two criteria:
– exposure to terrorism and terrorist activity; or
– role in the global financial system and their degree of financial connection to Canada, measured by the volume of reporting to FINTRAC and their overall trade and economic relations with Canada.

Although Canada does not have significant financial connections to certain jurisdictions, the general state of their counter-terrorism-financing regimes and the proliferation of terrorist actors mean that even limited financial exposure may lead to significant risks for Canadian financial entities.

At the same time, while some jurisdictions face lower risks of terrorist violence, features of their financial systems or their financial and economic role in a particular region creates a higher risk for terrorist financing activity.

The extremist traveller phenomenon has posed the primary terrorist financing risk to Canada over the past several years, drawing approximately 190 individuals with a nexus to Canada to conflict zones all over the world. While the phenomenon predates the creation of Daesh, the most recent conflict in Syria and Iraq has drawn thousands of individuals from across the globe to Daesh-controlled territory. As of 2017, approximately 60 individuals had returned to Canada from global conflicts.


Moneygram admited Anti-Money Laundering violations …

United States Department of Justice on November 9, 2012
Moneygram International Inc. Admits Anti-Money Laundering and Wire Fraud Violations, Forfeits $100 Million in Deferred Prosecution

MoneyGram International Inc. – a global money services business headquartered in Dallas – has agreed to forfeit $100 million and enter into a deferred prosecution agreement (DPA) with the Justice Department in which it admits to criminally aiding and abetting wire fraud and failing to maintain an effective anti-money laundering program, as charged in an information filed today in the Middle District of Pennsylvania.

According to court documents, MoneyGram was involved in mass marketing and consumer fraud phishing schemes, perpetrated by corrupt MoneyGram agents and others, that defrauded tens of thousands of victims in the United States.  MoneyGram also failed to maintain an effective anti-money laundering program in violation of the Bank Secrecy Act.  The Justice Department will return the forfeited funds to the victims of the fraud scheme through its Victim Asset Recovery Program.

“MoneyGram’s broken corporate culture led the company to privilege profits over everything else,” said Assistant Attorney General Breuer.  “MoneyGram knowingly turned a blind eye to scam artists and money launderers who used the company to perpetrate fraudulent schemes targeting the elderly and other vulnerable victims.  In addition to forfeiting $100 million, which will be used to compensate victims, MoneyGram must for the next five years retain a corporate monitor who will report regularly to the Justice Department.”


What happens in USA when you do not follow AML rules

What happens in USA when a company does not follow anti money laundering rules?

Former US Arizona Attorney General Terry Goddard and Western Union Financial Services, Inc. announced in Feb 2010 a ground-breaking $94 million settlement agreement which will provide substantial new resources for law enforcement authorities in the four Southwest border states to combat illegal activity along the entire U.S.-Mexico border.

Meanwhile, on July 2016, Western Union announced in a press release that completed successfully the primary recommendations made by the monitor pursuant to the Southwest Border settlement agreement, dated in February, 2010.

Arizona Attorney General Mark Brnovich said, “Over the last few years Western Union has made great strides in developing an effective AML program. We believe Western Union’s Southwest AML Compliance Program should be a model for others in the industry.”