FROM A
DIFFERENT ANGLE by Kenneth Rijock
Financial Crime Consultant, for World-Check
Are your NGO clients involved in terrorist financing ?
30 October 2006

The large number of non-governmental organisations that have been found to be engaged in terrorist financing in Europe and North America means that you must periodically review the activities of your NGO customers for the bank's protection. Today we discuss this threat, and the red flags you must look for.

Most tax-exempt NGOs are legitimate, and serve the public interest, and those who quietly assist terrorist groups represent but a small fraction of the total. The hidden threats posed by non-governmental organisations that are terrorist affiliates are:

  • The NGO can engage in fundraising for a designated terrorist organisation, without even the donors knowing who the the ultimate beneficiary of their contribution is.
  • The NGO can render financial support in a covert manner, and often only a sharp compliance eye looking for the presence of red flags will spot this activity.
  • Ease of rendering logistical support; goods, materials and needed supplies can be adroitly funneled to the terrorist organisation by the NGO with little risk of discovery.
The best method of uncovering NGO terrorist financing activity by compliance is still watching for those reliable red flags. The presence of more than one should cause one to immediately conduct an investigation in the affairs of the client. The red flags most often associated with NGO terrorist financing are:

  • Foreign banks accounts, where the NGO's stated aims and activities have no connection with that area.
  • The NGO has a high volume of wire transfers.
  • Transfers are made to regions where there is a high risk of terrorist activity.
  • The NGO has multiple accounts without a satisfactory explanation for their use.
  • The NGO receives third party cheques for deposit into its account.
  • Multiple cheques are received from the same individual.
  • Donations are diverted from their intended purpose or application.
  • Cash deposits are followed by immediate ATM withdrawals.
  • Donation cheques are cashed rather than deposited in the NGO account.
  • Transfers are received from intermediary organisations.
  • There are multiple transfers to the same recipient.
  • The NGO has a hoard of cash available that is not deposited into its account.
  • There is evidence of layering of funds.
  • The account history is inconsistent with typical NGO activity.
Many NGO officers who are involved in terorist financing have had prior experience with other non-governmental organisations that were also fronts.  All NGO staff, as well as officers and directors, should be vetted when the organisation is periodically checked.







The facts and opinions stated in this article are those of the author and not those of World-Check. World-Check does not warrant the accuracy of any facts and opinions stated in this article, does not endorse them, and accepts no responsibility for them.

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