Challenges

With the intensification of the terrorist threat over the recent years and the concurrent evolution of terrorist financing typologies, the UN Security Council has adopted additional resolutions, often under Chapter VII, to address new avenues of terrorist financing, including by targeting the nexus between terrorists and organized crime groups and tackling fundraising through kidnapping for ransom. In Resolution 2462 (2019), the Security Council expressed concern at the flow of funds to terrorists and the need to suppress all forms of terrorist financing. In order to be effective, efforts to counter the financing of terrorism need to rely more on financial intelligence sharing between countries and enhanced coordination between the public and private sector. In addition, public sector financial regulators and private sector regulated and semi-regulated entities, including banks, often carry information that could benefit the other if shared through better and timely channels.

In order to be more effective, targeted financial sanctions and other Financial Action Task Force (FATF) mandatory measures need to be buttressed with risk assessment and typology identification, enhanced intelligence sharing and better cooperation between the public and private sectors. Full adherence to international human rights standards and due process issues is also required.

Toward a Solution

The United Nations Counter-Terrorism Centre (UNCCT) Countering the Financing of Terrorism (CFT) Project provides assistance to Member States beyond understanding asset freeze requirements, and places a renewed emphasis on making asset freezing effective through prioritization of counter-terrorist financing practices in accordance to assessed risks, integration of financial intelligence into counter-terrorist financing tactics, and promotion of cooperation between the public and private sectors, thereby benefiting Member States in their broader efforts to implement FATF’s other recommendations and strengthening their financial sectors.

During implementation, UNCCT has continued to support interested Member States in developing the laws, policies, institutions and practices to effectively identify, detect, pursue and deny financing by terrorists and their supporters. The adoption of Security Council resolution 2462 (2019) has given further impetus to UNCCT’s efforts in this field. In response to the resolution, UNCCT has developed an expanded global capacity-building programme on countering the financing of terrorism that is premised on four pillars – awareness raising, comprehensive needs assessments, legislative support and operational capacity-building.

Building on capacity-building support offered in the preceding year, UNCCT continued engagement with Tunisia, Mauritius, and Mongolia during 2019. In Tunisia, UNCCT supported the implementation of a new decree on countering the financing of terrorism. In Mauritius (February 2019) and Mongolia (April 2019), UNCCT delivered workshops for around 60 participants from a variety of national authorities, to help identify vulnerabilities faced by the NPO sector and good practices to engage the NPO sector in a manner that did not impede their work and yet helps safeguard their activities from terrorist abuse. In Mauritius, UNCCT held a dedicated seminar for parliamentarians that raised awareness of the vulnerabilities faced by the non-profit sector. In this regard, UNCCT benefited from the participation of the Charity Commission of England and Wales and the Canada Revenue Agency as key operators with extensive experience in this field. UNCCT helped Mauritius identify ways to develop laws on the protection of the NPO sector, which Mauritius was able to demonstrate during the course of the year through the adoption of key pieces of legislation. The satisfaction rate from both workshops stood above 85% on average.

In addition, UNCCT initiated capacity-building support for Bahrain, Sri Lanka and Madagascar. In July 2019, in the aftermath of the Easter bombings in Sri Lanka, UNCCT responded to a call from national authorities and the UN Country Team to jointly deliver a comprehensive training to more than 100 Sri Lankan officials from a broad cross-section of agencies on terrorist financing, supervision, investigations and prosecution, especially as it pertains to the protection of the charities sector from terrorist abuse. These trainings helped lay the groundwork for future work, especially in conducting a possible risk assessment for Sri Lanka’s NPO sector that could take place in the future. In September 2019, UNCCT organized a training workshop for Bahraini officials which also focused on best practices on the protection of the NPO sector from terrorist abuse. That workshop was deeply appreciated by Bahraini officials, who called for an additional event to consider the issue more intensively in 2020. Finally, in December 2019, UNCCT commenced work with Madagascar, including to enhance the awareness of officials of international obligations on countering the financing of terrorism.