The individual who reportedly carried in the $2m was Said Siam, also known as Saeed Siam, the Minister of the Interior and Cultural Affairs [UID 417135] and a member of HAMAS, officially called the Islamic Resistance Movement [UID 1313].

Siam allegedly visited Iran and Syria during a trip to the Middle Eastern region, which was believed to be a fundraising venture. The Palestinian Authority has been unable to meet its employee payroll since Hamas was elected to power in January. Funding sources in the EU and US terminated aid after Hamas failed to meet certain specified conditions precedent.

MLROs and compliance officers, though aware of the political realities that give rise to support radical Islamist groups, have a duty to render a strong objection whenever they encounter suspicious transactions that may involve what the EU and US contend is terrorist financing; cash payments to Hamas, Hizbollah, Al-Qaeda, ETA, or any specially designated global terrorist organisation. To do less is a breach of their obligation as compliance officers.

One must also regularly remind senior management of the possible adverse consequences of having your bank labeled as a terrorist financier by US regulators:

• Being designated an entity of special money laundering concern, which will cause banks worldwide to decline to do business with you, and signal a rampant flight of your depositors to your competition.
  

• Losing your correspondent banking privileges in the US or elsewhere.
  

• Seeing American banks being ordered not to transact any business with your institution, directly or indirectly.
  

• Being indicted in US District Court for money laundering or aiding and abetting in terrorist financing.
  

• Having your US-based funds and assets frozen without notice.
  

• Having your US branch, office or agency closed forthwith, with all the incidental reputation and financial damage that such a drastic action entails.
  

For those who say that we reiterate these extreme penalties far too often, imagine how many of your major customers would remain if they could no longer access European and American financial structures. Keep a sharp eye out for any suspicious bulk cash withdrawals. To do any less is professional negligence.