Terrorist financing (TF) is frequently viewed as an afterthought
by firms in the context of anti-money laundering (AML)/countering
the financing of terrorism (CFT) frameworks.
This is perhaps unsurprising given the clear focus, until
recently, by governments, regulators and the public at large on
money laundering (ML) flowing from tax evasion, high-level
corruption and bribery cases. It is also an uncomfortable topic for
financial institutions to grapple with given the violent and
graphic results of terrorist acts. Additionally, there is a common
perception among offshore practitioners that terrorist financing
always involves small sums of money that are difficult to identify
as being linked to terrorism and that it is largely an issue for
the banking community. While some of this is undoubtedly true, it
would be incorrect to assume that this presents a complete picture
of the threat posed by not only those who commit acts of terror but
also those who stand behind
