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Terrorist Financing

Low-Value Terrorist Financing to High-Risk Countries

Small-value transfers sent frequently to jurisdictions with known TF exposure. Individually unremarkable but collectively indicative of financing activity directed at conflict zones or sanctioned regions.

Firm typesE-Money Institution (EMI)Payment Institution (PI)Money Service Business (MSB)Bank / Credit Institution
ProductsCross-Border PaymentsRemittanceE-Money Accounts
CustomersIndividualsNon-Profit / CharitiesAgents & Intermediaries
Key terms:

What it is

Small-value transfers sent frequently to jurisdictions with known TF exposure. Individually unremarkable but collectively indicative of financing activity directed at conflict zones or sanctioned regions.

Control objective

Detect and investigate patterns of low-value transfers to FATF-identified high-risk jurisdictions that may indicate terrorist financing, ensuring timely SAR submission where appropriate.

Data required

  • Transaction amount and currency
  • Beneficiary country and institution
  • Sender identification and verification records
  • Transaction frequency per sender (rolling 30-day)
  • FATF high-risk country list (current)
  • UN sanctions list matches
  • Sender declared purpose of payment
  • Historical transaction pattern baseline