Terrorism Financing Activities

Terrorism financing activities behave differently from money laundering, and staff trained only on laundering will not recognise them.

The direction is reversed. Laundering takes dirty money and makes it look clean. Terrorism financing can take entirely lawful money, from employment, savings, donations or small business income, and direct it toward an unlawful purpose.

The amounts are also different. Laundering often involves significant sums. Financing can involve very small ones, well below any threshold that would attract attention.

So the indicators sit elsewhere. Repeated small transfers to the same destination. Movement through higher-risk jurisdictions without an obvious reason. Activity inconsistent with a customer’s stated purpose. Funds collected under a charitable description with no verifiable recipient.

Transaction value, on its own, tells you almost nothing here. That is the single hardest habit to unlearn for staff who came to this from an anti-money laundering background.

AUSTRAC publishes guidance. This is general information rather than legal advice, and obligations vary by state and territory.

See Sentrient’s AML/CTF course and workplace compliance courses.