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Banks should use recently published terrorist financing guidance when developing risk-based anti-money laundering programs. Recent publications that shed light on terrorist financing include the FATF Report on Money Laundering Typologies,² FATF Guidance for Financial Institutions in Detecting Terrorist Financing Activities, the FinCEN SAR Bulletin Issue 4, “Aspects of Financial Transactions Indicative of Terrorist Funding” published January 2002, and the 2002 National Money Laundering Strategy.

The FATF Guidance discusses similar methods of laundering funds by terrorist organizations and organized crime, though their motives may differ. The report also notes that terrorist groups have increasingly resorting to criminal activity to raise funds. With the exception of three activities, there is little difference in the funding sources currently used by terrorists and organized crime groups. The three funding activities distinct to terrorism include:

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