International Business Transactions (1) "Eastern Emporium Trading Company" Use of business accounts – an example: This example is based on a real case. A business in a high risk country sources and exports ethnic crafts for sale overseas. Customer businesses pay legitimate amounts of money in payment of invoices received from the business, for goods that have been supplied and purchased legitimately. The payments are often made by electronic transfer, given that the customer businesses are based overseas. Alongside these legitimate revenues from its customers the business receives wired terrorist funds. These funds are comingled with the legitimate revenues in the business’s accounts. Individuals with signatory authority for the business’s accounts then withdraw funds via local bank branches in the terrorists’ target country, to fund local terrorist activities. © Lessons Learned Ltd 2016

International Business Transactions (2) Key facts Connections with high risk countries: Distribution of funds from country where raised to country where used Diaspora owned businesses: International ‘network’ of businesses as collection points Terrorist financier’s perspective Diaspora involvement: willing assistance or assistance through coercion/extortion ‘Cover’ of business transactions: swift movement of funds across international borders Key facts Businesses that have a connection – either through their ownership, their location or through their trading – with high risk countries clearly constitute a higher risk of involvement and may require enhanced due diligence. Diaspora-owned businesses around the world are particularly vulnerable, since they can provide the terrorists with a ready-made network of business accounts of and the willing assistance of the business owners of those accounts (assuming they support the terrorists’ causes in their homeland). Terrorist financier’s perspective As indicated above diaspora owned businesses are potentially higher risk and may require enhanced due diligence, as the diaspora who own them (immigrants or refugees from their country of origin) may actively support the terrorists’ causes in their homeland and may be quite willing to allow their businesses to be used. There have also been cases where diaspora owners of businesses have been forced to co-operate with the terrorists under the threat of possible repercussions for their families back home, if they do not. The network of businesses across the world – and in particular the use of import/export businesses – provides the terrorists with a network of legitimate international business via which electronic transactions may be carried out frequently, with terrorist financing transactions hidden alongside. © Lessons Learned Ltd 2016

International Business Transactions (3) Possible ‘red flags’ The use of a business account to channel funds to a small number of overseas recipients Both individuals and businesses in a country of specific concern An unusually high volume of wire transfer activity into and out of this business account Large and unusual currency withdrawals from a business account Business owned by nationals of countries of specific concern Transaction features and behaviours shown on this slide should give rise to concern that business accounts is potentially being exploited by terrorists in order to move their funds. © Lessons Learned Ltd 2016