Treasury issued 4 reports today but one seems to be missing!
THERE IS NO REPORT ON THE 'MISUSE OF THE U.S. FINANCIAL SYSTEM'
SEE PIC
STRATEGY REPORT SAYS THIS ABOUT MISUSE OF THE US FINANCIAL SYSTEM
U.S.-based terrorist financiers and supporters seek to place their funds, often legitimately
earned, into the U.S. financial system and transfer the money abroad. Due to prevalence and accessibility, banks and money services businesses (MSBs) are the most commonly used channels.51
Importantly, due to the nature of terrorist financing (often legitimately sourced funds
later used to fund illicit activity), these entities face challenges in distinguishing terrorism-related
financial transactions from licit activity.
Due to the centrality of the U.S. financial system and the U.S. dollar, U.S. banks continue to
face TF risk due to their role in U.S. dollar clearing and processing international payments. For
example, along with raising funds in the United States or through U.S. persons, ISIS financiers
and supporters seek to access the U.S. and international financial systems, both directly and
indirectly, to move funds in support of ISIS and its regional affiliates throughout the world.52
U.S. authorities have also identified instances where ISIS operatives route transactions through
third parties to avoid detection, as well as channel financial activity through neighboring localities
(as ISIS operates in regions with limited access to the international financial system).53
Some U.S.-based MSBs face TF risk from the acts of complicit employees, as well as isolated
compliance deficiencies in smaller online payment providers that provide person-to-person funds
transfers.54 Unlicensed money transmitters also remain an important channel for some terrorist
groups and their supporters. Robust implementation of AML/CFT standards by U.S. financial
institutions makes cash a relatively secure if inefficient alternative for terrorist groups or supporters
that prioritize operational security over the speedy movement of funds.
CHARITIES
U.S. tax-exempt charitable organizations that only operate and disburse funds domestically face
low risk of TF abuse.55 However, there continues to be greater TF risk for the small number of
U.S. tax-exempt charitable organizations that operate in, send funds to, or have affiliated organizations
in high-risk regions where ISIS and its regional affiliates, AQ and its regional affiliates,
Al-Shabaab, ANF and other terrorist groups are most active, such asAfghanistan, Pakistan,
Somalia, Syria, and Yemen.56
KEYWORDS
ISIS
BANKS
MONEY SERVICE BUSINESSES
CHARITIES DOING BIZ IN - AFGHANISTAN, PAKISTAN, SOMALIA, SYRIA, YEMEN
MAYBE THIS IS WHAT THE 66,000+ SEALED COURT DOCS ARE ABOUT?
https://home.treasury.gov/system/files/136/nationalstrategyforcombatingterroristandotherillicitfinancing.pdf
https://home.treasury.gov/news/press-releases/sm581