Counter Terrorist Financing
Identifying terrorist financing can be challenging for OCC banks. Meeting the following objectives can greatly enhance a bank’s ability to achieve this goal.
- Conducting a complete risk assessment and developing a thorough understanding of the anti-money laundering and counter terrorist financing risks not only within lines of businesses, but across the bank. Understanding the inherent risks in product and service offerings as well as how these are used by customers is important.
- Establishing an effective BSA compliance and transaction monitoring program based on the bank’s risk profile. This is a key step in reporting all suspicious and unusual activity that may indicate potential terrorist financing activity to assist law enforcement to analyze and follow up on reported activity.
- Screening for potential OFAC violations and effectively reviewing and closing alerts generated in a timely manner.
Additional Guidance is also available from the following sources:
- The Financial Action Task Force (FATF) Terrorist Financing Typologies Report.
- FATF guidance and best practices to assist jurisdictions in their implementation of the FATF Recommendations.
- Basel Committee on Bank Supervision (Basel Committee Publications - January 2014) – Sound Management of risks related to money laundering and financing of terrorism.
- A list of the countries supporting international terrorism appears in the U.S. Department of State’s annual Country Reports on Terrorism. This report is available on the U.S. Department of State’s Web site for its Counterterrorism Office: www.state.gov/s/ct/.