The report highlights specific cross-border risks and techniques to address them among broader approaches to counter-terrorism financing:
Cross-border transaction or movement reports (CTRs) – The FATF Standards require that all countries implement a declaration or disclosure system for incoming and outgoing cross-border transportation of currency and bearer negotiable instruments (CBNIs) with a maximum threshold of USD/EUR 15,000 (FATF Recommendation 32.) While the low volume of funds often used by terrorists presents challenges for detection in a threshold-based system, countries to date have found that information on the general inflows/outflows of CBNI may still provide useful information on the potential TF vulnerabilities posed by different borders.
Suspicious Transaction Reports (STRs) – The FATF Standards require that all financial institutions and DNFBPs should be required to notify the FIU if they suspect or have reasonable grounds to suspect that funds are the proceeds of a criminal activity, or are related to TF (FATF Recommendation 20). The value of STRs for strategic analysis purposes is likely to vary between countries depending on the quality and volume of STRs filed. Nevertheless, when assessing cross-border risks, countries to date have found value in analyzing STRs for cross-border elements (e.g. suspicious TF funds linked to incoming/outgoing transfer from third country).
Cross-border Wire Transfers (CBWTs) – While not required under the FATF Standards, the collection and strategic analysis Cross-border Wire Transfers (CBWTRs) can prove a useful source of information when assessing TF risk. In particular, countries have found that analysis of CBWTRs at country, sector, and channel levels may provide insights into common destination or conduit countries for transfers, as well as longer term changes in fund flow patterns. Information on CBWTRs may also be matched with other financial information (such as suspicious transaction reports, or cross-border declarations of cash and bearer negotiable instruments) to identify broader TF patterns and networks.
This report builds on the 2013 FATF guidance on national money laundering and terrorist financing risk assessments, and draws on inputs from over 35 jurisdictions from across the FATF Global Network on their extensive experience and lessons learnt in assessing terrorist financing risk. Recognising that there is no one-size-fits all approach when assessing terrorist financing risk, this guidance provides relevant information sources and considerations for different country contexts.