FTFs may use diverse methods to disguise their finances or intentions.
With respect to publicly available information, for instance, ISIL and other terrorist organizations are known to be active on social media sites.
Financial institutions may find available social media information helpful in evaluating potential suspicious activity and in identifying risks connected to the red flags provided in this and other advisories.
Financial institutions should also refer to the red flags and other information provided in this an d the May 2015 non-public advisory to formulate a more comprehensive assessment of potential suspicious activity.
Depending on their products and services offered, financial institutions may be able to observe one or more of the following red flags.
Some of these red flags may be observed during general transactional screening, while others may be more readily identified during in-depth case reviews.
Activities Prior to Departure: Prospective FTFs make typical financial and logistical preparations prior to traveling.
Similarly, the location from which a customer logs into a financial institution’s online services platform may also be considered when determining whether a transaction is suspicious (see next section). In applying the red flags below, financial institutions are advised that no single transactional red flag is a clear indicator of terrorist activity.
Financial institutions should consider additional factors, such as a customer’s overall financial activity and whether he or she exhibits multiple red flags, before determining a possible association to terrorist financing and FTFs.
The Financial Crimes Enforcement Network (Fin CEN) is issuing this advisory to provide financial institutions with information on identifying and reporting transactions possibly associated with Foreign Terrorist Fighters (FTFs) who support the Islamic State of Iraq and the Levant (ISIL), al-Qa’ida, and their affiliates in Iraq and the Lev ant region.
Financial institutions may use this information to enhance their Anti-Money Laundering (AML) risk-based strategies and monitoring systems.
Transactions associated with FTFs may include: Purchasing goods at camping or survival stores; Purchasing first-person shooter games or engaging in combat training-type activities; Purchase of airfare and payment of travel related fees (e.g., visa fees) involving countries in Europe or countries near or adjacent to ISIL-controlled areas—including Cyprus, Egypt, Greece, Jordan, Lebanon, and Turkey; Establishing lines of credit and taking out personal loans where no loan repayments are made; Liquidating personal assets, including retirement accounts/plans, and obtaining life insurance policies; Receiving funds from or sending funds to seemingly unrelated individuals who are located near cities with a reported ISIL/al-Qa’ida-presence, where the transactions do not appear to have a lawful business purpose.