As part of the Financial Crimes Enforcement Network’s (FinCEN) first national priorities list for anti-money laundering and countering the financing of terrorism (AML/CFT) policies, one important priority continues to be detecting, reporting, and preventing terrorist financing.
The Sept. 11 terrorist attacks were a significant driver in the development and implementation of many internal processes we see at banks throughout the US and beyond, aimed at ensuring we properly identify customers and deter bad actors. With such a serious and complex nature, this activity seems as it would be subject to large, international banks. Unfortunately, that is not the case. Financial institutions of all sizes are more likely than ever to see activity related to terrorist financing.
While we have long considered terrorism to be an international matter, domestic terrorism has been on the rise in recent years. In June 2021, the White House released the first rendering of the National Strategy for Countering Domestic Terrorism1, a strong indicator that it is time for us all to be paying closer attention to this matter.
While there is no doubt you feel a sense of responsibility in your role, protecting your institution from being an unwilling pass-through for terrorist financing, you may also be questioning your ability to be a part of the solution. Your time may already be stretched thin with a jam-packed calendar, a long list of tasks and obligations. What can we reasonably do to offer meaningful actions from our individual positions? We educate ourselves as often and as best we can, ensure we are familiar with red flags should they ever present themselves, and converse with our peers and leaders whenever possible.
