Latin America & Terrorism Financing
In 2016, the unpredictable nature of, and constant threat posed by, ISIS and other terrorist groups has become a frightening part of every day life for civilians across the globe, and a threat to the physical, financial, and in some cases political, security of the countries these citizens inhabit. Deaths from terrorism have increased exponentially in recent years, and it seems the Bush administration’s “war on terror” initiative following the September 11th attacks, as well as other measures implemented by the United States and governments of other countries since the early 2000’s, have done little to quell this global issue. In fact, the physical threat of terrorism seems more evident now than ever, as “terrorist attacks occurred in almost 100 countries in 2015, an increase from 59 in 2013” according to the University of Maryland’s Global Terrorism Database (Friedman, 2016). This has led to an increase in global fear and a state of paranoia amongst the masses; a trend derived in large part from the pervasiveness of the mainstream media and its constant coverage of attention-grabbing stories around the world, including the terrorist attacks that have plagued the world of late.
One successful measure implemented by the U.S. government following 9/11 however was the creation of the Terrorist Finance Tracking Program (TFTP) by the U.S. Department of the Treasury. The program’s goal was to identify, track and pursue terrorists and their network(s) by tracking their flow of money, allowing for the identification of operatives and those financing their efforts, disruption of terrorist networks, and saving of lives in the process. This coupled with federal mandates calling for the establishment of adequate anti-money laundering (AML) and counter-terrorism financing (CTF) programs within U.S. financial institutions have significantly reduced the scope of financial crime and terrorist-funding activities seen within the United States. However, terrorist financiers continue to employ new methods to maintain their clandestine operations, and have even begun reverting to traditional methods, such as exploitation of trade based money-laundering and cash couriers in countries with non-existent or weak anti-money laundering programs, where movement of funds to finance terrorist activities can be more easily accomplished. In her article titled “U.S., Foreign Officials Meet Over Threat of ISIS Using Latin America to Finance Operations” cited in BSA News Now on November 30th, writer Morgan Chalfant analyzes the increased concern in the international community over terror groups “exploiting weakness in Latin America to fund their terrorist activities” (Chalfant, 2016). Chalfant reports that a group of American officials and numerous international experts met with representatives from 10 nations last week in what was coined the Regional Parliamentary Intelligence and Security Forum. The meeting was held “to discuss joint efforts to prevent terrorist financing in Latin America, amid growing concern that Islamic extremist groups are operating in the region” (Chalfant, 2016). One of the organizers of the forum was United States Representative and Chairman of the Congressional Taskforce on Terrorism and Unconventional Warfare, Robert Pittenger, who held the meeting to address the growing relationships seen between middle-eastern terrorist groups and drug lords in the Caribbean.
Pittenger stated that there is a consensus among U.S. allies in South America that they believe they are very susceptible to terrorism financing activity for groups such as ISIS and other terrorist groups. Mariano Federici, president of Argentina’s Financial Intelligence Unit, was also on hand for the conference. He noted that there are certain countries in Latin America that could be more open to the creation of terrorist funding channels than others due to respective histories in the recruitment of “foreign terrorist fighters” for groups such as ISIS and Hezbollah (Chalfant, 2016). Federici also urged the U.S. representatives in attendance to share more of the valuable information they have on terrorist groups with their Latin American counterparts, as he believes this will aid in the greater understanding of the terrorism threat facing these countries, and could ultimately slow the cycle of terrorism financing in this region.
In a letter to President Obama earlier this month, Iowa Senator Joni Ernst wrote of the “increasing presence of Islamic extremist groups operating in Latin America”, writing that “with decades of violence and illicit activity throughout Latin America, it remains fertile ground for extremist groups, like ISIS, to prosper” (Chalfant, 2016). U.S. officials fear that if terror groups begin to put roots down in South America and the Caribbean, that it may lead to the spread of criminal networks into the United States. Thus the need for greater cooperation between the United States and other Latin American countries is vital for the security of not only North & South America, but for the rest of the world as well. Suggestions have already been made to the administration of President-elect Donald Trump on the matter, with the training of foreign officials in advanced technologies and emphasis on establishment of thorough AML/CTF programs of the utmost priority for these vulnerable countries. This will also require the building of strong partnerships between the United States and Latin American countries in the coming years to maintain security abroad.
FinCEN SAR Advisory Update
In other news, the U.S. Financial Crimes Enforcement Network (FinCEN) issued an advisory on October 25th regarding suspicious transactions and the information that should be included in Suspicious Activity Reports (SAR’s) as they relate to web-based events. The advisory stated, “while suspicious transactions may not always involve a cyber-event, relevant cyber-related information should still be included in SARs when available” (Shearman & Sterling, 2016). This information includes, but is not limited to, IP addresses, timestamps, etc. Furthermore, when a suspicious transaction does involve a cyber-event, all relevant information regarding the transaction(s) and the cyber-event (type, magnitude, etc.) should be included in the SAR’s.
FinCEN closed the advisory by encouraging the collaboration between “in-house” BSA & AML security units and other organizations to promote the overall security of all financial institutions across the U.S. via the sharing of valuable information.
Chalfant, Morgan. “U.S., Foreign Officials Meet Over Threat of ISIS
Using Latin America to Finance Operations.” Washington Free Beacon. 29 Nov. 2016. Web.
Shearman and Sterling, LLP. “US Financial Crimes Enforcement
Network Issues Advisory and Frequently Asked Questions on Reporting Cyber-Events in Suspicious Activity Reports | JD Supra.” JD Supra Business Advisor. 25 Nov. 2016. Web.