The Financial Action Task Force has announced that the fight against terrorist finance is its 'top priority.' It has, accordingly, published a report full of relatively recent examples for money-laundering reporting officers to read.

Recommendation 5 of the FATF's collection of 40, as revised in 2012, says that countries should criminalise terrorist finance and the financing of terrorists even if there is no direct link to a terrorist attack. States should ensure, moreover, that such offences are money-laundering predicate offences. The interpretative note to this recommendation has been changed.

The main findings of the report are that:

• almost all jurisdictions have criminalised terrorist financing and 33 jurisdictions have obtained convictions;
• more than 90% of jurisdictions have laws in place to impose targeted financial sanctions;
• 27 jurisdictions have updated their laws to criminalise the financing of travel by foreign terrorist fighters – as required by United Nations Security Council Resolution 2178 from September 2014;
• many jurisdictions implement UN targeted financial sanctions too slowly, making it more difficult to prevent asset flight; and
• two-thirds are not making practical use of targeted financial sanctions, which limits the effectiveness of these measures.

The report finds that electronic, online and new payment methods pose an emerging "terorism financing vulnerability" which may increase over the short term as the use and popularity of these systems grows. Many of these systems can be accessed globally and used to transfer funds quickly. While transactions may be traceable, it proves difficult to identify the actual end-user or beneficiary. The report presents a number of interesting cases, but the actual prevalence and level of exploitation of these technologies by terrorist groups and their supporters is not clear at this time and remains an information gap to be explored. The exploitation of natural resources for terrorist finance was raised as a substantial concern in the context of ISIS but this report has confirmed that it is also relevant for other terrorist organisations and regions.

The FATF cited a case uncovered by the Russians of a large-scale crowd-funding scheme with e-wallets. A group of people registered numerous e-wallets, credit cards and mobile phone numbers. It placed the 'financial requisites' (whatever the FATF means by that) on the Internet, not least on social networks, under the pretext of collecting donations for Syrian refugees, people in need of medical and financial aid, and for the construction of mosques, schools and kindergartens. The wording contained some indirect indications that the money was intended as financial support for terrorist activities. Indeed, the funds were sent to support terrorist activities and went either to the credit-card accounts or to e-wallets. The group then moved the payments through a chain of transfers and withdrew them in cash to be transported further by couriers. It managed the payment instruments on the Internet, using mobile devices as well.

Then there was a case uncovered by the French of a charity set up in 2012, ostensibly to raise money for pro-Palestinian humanitarian projects, among them the sending of medical material to build a hospital. The protagonists posted pictures on Facebook to attest to the reality of the project and to communicate with donors. A month later, the charity made a new call for funds on social networks, indicating that three members of the association planned to take funds to Turkey. A customs control at a French airport revealed that each of them carried €9,900, a sum below France's declaration threshold, but only €6,000 were to be used for the humanitarian project.

The remaining funds were to be given to foreign terrorists. In January 2014, an administrative order froze the assets of the association and four of its members. In November 2014, the association was dissolved and two members were arrested for terrorist finance and criminal conspiracy in connection with a terrorist enterprise. Law enforcement authorities used Facebook public messages and pictures as evidence.

An American case demonstrates the fact that terrorists are no strangers to Bitcoin and the use of virtual currency. On 28 August 2015 Ali Shukri Amin was sentenced to 11 years in prison to be followed by a lifetime of supervised release and monitoring of his internet activities for conspiring to provide material support and resources to ISIS. Amin had pleaded guilty, as almost everyone in America does because of the dire threat of extended sentences if they plead the wrong way and lose.

He admitted to using Twitter to provide advice and encouragement to ISIS and its supporters. Amin, who used the Twitter handle @Amreekiwitness, provided instructions about the use of Bitcoin to mask the provision of funds to ISIS as well as help to ISIS supporters who wanted to travel to Syria to fight. Amin’s Twitter account boasted more than 4,000 followers and was used as a pro-ISIS platform during the course of more than 7,000 tweets. He used this account to conduct twitter-based conversations about ways to develop financial support for ISIS using online currency, tweeting a link to an article he had written entitled "Bitcoin and the Charity of Jihad." It suggested the use of Dark Wallet, a new Bitcoin wallet that supposedly keeps the user of bitcoins anonymous.

The report is to be found at http://www.fatf-gafi.org/media/fatf/documents/reports/Emerging-Terrorist-Financing-Risks.pdf