Prior to
September 11, the hijackers used the
1.
Deposited money into
2.
Kept funds in foreign accounts that they
accessed in the
3.
Retrieved funds from facilitators in other
countries as they traveled to the
“Al Qaeda is comprised of modern, educated young people who are as aware of the cracks in the Western financial system as they are of the lines in their own hands. These are the very flaws in [the] Western financial system which is [sic] becoming a noose for it.”—Usama bin Laden
Potential Indicators
of Terrorist Financing Activities
Each potential indicator may result from legitimate recreational or commercial activities or from criminal activity unrelated to terrorism; however, multiple indicators combined with other information may suggest a terrorist threat. It is critical for law enforcement professionals to examine these activities and determine whether there is a need to investigate further. The following examples of common patterns of suspicious activity relating to financial institutions, though not fully inclusive, may be of possible concern to law enforcement:
§
A lack of evidence of legitimate business
activity, or any business operation at all, undertaken by many of the parties
to the transaction(s).
§
Unusual financial nexuses and transactions
occurring among certain business types (e.g., a food importer dealing with an
auto parts exporter).
§
Transactions that are
not commensurate with the stated business type and/or that are unusual and
unexpected in comparison with the volumes of similar businesses operating in
the same locale.
§
Unusually large numbers and/or volumes of wire
transfers and/or repetitive wire transfer patterns.
§
Unusually complex series of transactions
indicative of layering activity involving multiple accounts, banks, parties, or
jurisdictions.
§
Bulk cash and monetary instrument transactions.
§
Unusual mixed deposits of money orders,
third-party checks, and/or payroll checks into a business account.
§
Transactions being conducted in bursts of
activities within a short period, especially in previously dormant accounts.
§
Transactions and/or volumes of aggregate
activity inconsistent with the expected purpose of the account and expected
levels and types of account activity conveyed to the financial institution when
the account was opened.
§
Suspected shell entities.
§
Beneficiaries maintaining accounts at foreign
banks that have been subjects of previously filed Suspicious Activity Reports.
§
Parties and businesses that do not meet the
standards of routinely initiated due diligence and anti-money laundering oversight
programs (e.g., unregistered/ unlicensed businesses).
§
Transactions seemingly designed to, or
attempting to, avoid reporting and recordkeeping requirements.
§ Correspondent accounts being utilized as “pass-through” points by foreign jurisdictions with subsequent outgoing funds to another foreign jurisdiction.
§ Suspicious Activity Reports are used to provide law enforcement with information on possible terrorist activity.
Your impressions and assessment, based on your professional experience, are extremely valuable and should guide you in determining whether a customer request, a fact pattern, or a set of circumstances is unusual. Remember that the conduct itself does not have to be criminal to be reported.
Frederick Police Department
(301-600-2100)
Information
researched and provided by the State and Local Anti-Terrorism Training (SLATT)
Program.
SGT Dennis K. Dudley
Planning Division
Frederick Police Department
301-624-1206 (Office)
301-696-2082 (FAX)