2023-11-20 14:41:17
The Central Office for Financial Intelligence Unit (FIU) of the General Customs Directorate is taking the current events in the Middle East and thus the attack on Israel by Hamas and the Palestinian Islamic Jihad (PIJ) as an opportunity to update its information for obligated parties on identifying conspicuous circumstances. to counter terrorist financing.
The responsible Federal Ministry of the Interior has on November 2, 2023 Bans on activities for Hamas, which is banned in the EU, and the international network “Samidoun – Palestinian Solidarity Network” issued:
1. Hamas and PIJ fundraising typologies
Funding to finance terrorism or possible terrorist attacks can be obtained from various sources, including:
direct fundraising, fundraising through misuse of non-profit organizations (NPOs), fundraising by people associated with or sympathetic to Hamas.
Financing terrorism is often carried out under the guise of humanitarian fundraising campaigns led by various associations, charities or through private initiatives. The funds collected will be channeled to individuals or entities associated with Hamas and the PIJ. The organizations in question conduct fundraising campaigns across many communication channels, e.g. Telegram, X (formerly Twitter), Facebook, Instagram and TikTok, both in stand-alone threads/posts and via inserted comments. In many cases, these channels are interconnected by posting identical or similar messages and providing links to related Telegram or other social media channels. They are misused for publishing terrorist content (e.g. calls for action) as well as for publishing fundraising campaigns and links to fundraising campaigns that ostensibly promote humanitarian aid but in reality collect funds for terrorist attacks. The alleged donations are collected via, among other things, bank transfers and other types of electronic transfers, credit card payments and through exchanges using cryptocurrencies (such as BTC, ETH, USDT, USDC and TRX).
2. Possible indicators in detail (the list is not exhaustive)
Crypto addresses, bank accounts, digital means of payment, etc. published on Hamas-affiliated social media platforms or with links to such platforms. Using phrases and numeric codes when transferring funds that indicate a connection to terrorism in general or to current events. For example, money transfers to organizations whose purpose suggests a connection to terrorism, such as the name of a famous martyr, keywords such as “jihad/jihad,” or an explicitly stated purpose that appears to support hostilities or serious crimes. Unusual activities carried out by family members of individuals associated with terrorist acts or by entities associated with a terrorist organization. Importing goods from abroad and selling these goods to conflict areas. Particularly if payment for the goods is made by a seemingly uninvolved third party. Opening an account and immediately carrying out large-scale financial activities for humanitarian purposes. Payments made through a website that at first glance appears inoffensive, but upon closer inspection reveals evidence of links to a terrorist organization. Media posts that contain references to organizations involved in financial activities related to Hamas, PIJ or other associated organizations. Use of a postal address by an NPO or its affiliated organizations that is used by organizations suspected of terrorist activities. Activities or assets of NPOs, including their bank accounts or safe deposit boxes, that may be linked to entities against which bans have already been imposed or are intended to be imposed. NPOs that make bank transfers to other NPOs that are known to be linked to terrorist activities or their financing. Receipt of a transfer order to a relevantly known organization or an entity close to it. Evidence that donors, partners, suppliers or beneficiaries of NPOs may themselves be associated with terrorist activities or are close to organizations that are themselves involved in terrorist activities. (see.) An organization that suddenly collects donations that were previously donated to an organization whose activities have been banned.
3. Further information
If, after assessing a fact, the obligated party has facts that indicate that a business event, a transaction or an asset is related to terrorist financing, this fact must be reported to the FIU immediately, regardless of the value of the asset concerned or the transaction amount . For this purpose, when submitting the report via the reporting portal “goAML Web”, the following indicator must be set in the input field “Statement of the reason for the report”: A2000 – Terrorist Financing Further comprehensive background information on the topic of “Islamism and Islamist terrorism” can be found in particular Website of the Federal Office for the Protection of the Constitution can be removed below.
Source: Central Office for Financial Transaction Investigations (FIU) of the General Customs Directorate
Stand: 15.11.2023
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