The Department of Homeland Security (DHS) issued a National Terrorism Advisory System (NTAS) bulletin on January 4th warning that homegrown violent extremists “could capitalize on the heightened tensions.”

The bulletin comes as no surprise to anyone who has turned on a television or Twitter this century, as tensions in the Middle East have obviously escalated. Politics aside, there are individuals in the world who seek to do harm to civilian populations through terrorist activities. 

For financial crime professionals, understanding that it doesn't take a listed SDN or someone with $10,000 to carry out an organized attack is important for a periodic reality check. There are various terrorist tactics and techniques that are combated from the civilian sector through (from the US State Department):

  • Exposing the infrastructure of criminal organizations, webs of corruption and conspiracies to commit terror acts;
  • Providing authorities with roadmaps to those who facilitate criminal and illicit activities;
  • Assisting the recovery and forfeiture of unlawfully-acquired assets; and
  • Supporting broad and effective deterrence efforts against a wide range of criminal activities, including the financing of terrorism.

Those prevention, detection, and reporting efforts as described above require the following from AML/CFT practitioners:

  • Understanding that not every alert, case, or SAR is going to lead to the takedown of a criminal or terrorist organization by Seal Team Six;
  • Also understanding that AML/CFT works as a system, and the aggregate efforts of the civilian, political, law enforcement and military sectors are still the best course of action;
  • Giving earnest and diligent effort towards implementing and operating effective AML/CFT and sanctions programs within our respective organizations;
  • Understanding customer attributes and behaviors IN CONTEXT while utilizing the best technology is the most effective approach to detecting suspicious activity;
  • The only effective reporting is accurate, timely and thorough; and
  • Structure, discipline and cooperation are vital.

To discuss how to make your financial crimes compliance program more effective, reach out to me at mcarter@alvarezandmarsal.com.