Wednesday 13th September 2017 Professor in Financial Crime ‘Terrorist financing via social media: a step into the regulatory unknown?’ Wednesday 13th September 2017 Dr. Nicholas Ryder Professor in Financial Crime

Centre for Research and Evidence of Security Threats This work has been conducted under the Centre for Research and Evidence on Security Threats through an ESRC grant which is funded in part by the UK security and intelligence agencies. FYI: (ESRC Award: ES/N009614/1) Terrorist financing via social media: a step into the regulatory unknown?

Introduction Sources of terrorist funding, Terrorist financing and social media, UK terrorist financing Legislative framework Conclusion. Terrorist financing via social media: a step into the regulatory unknown? 3

Sources of Terrorist Financing State Sponsors of terrorism: Sudan, Iran and Syria Private terrorist moneys may be classified into two categories : legitimate, and unlawful funds Corporate donations, Non-profit organisations, Drug trafficking, Extortion, Fraud, Kidnappings for ransom and Oil refining. Terrorist financing via social media: a step into the regulatory unknown?

Terrorist Financing via Social Media Twitter and ISIL: Shafi al-Ajmi, Hajjaj al ‘Ajmi and Al-Anizi (United States Department of Treasury, 2014). Twitter, Bitcoin and ISIL: Ali Shukri Amin (Financial Action Task Force, 2015). Twitter and Skype ISIL ((Financial Action Task Force, 2015). Terrorist financing via social media: a step into the regulatory unknown?

Terrorist Financing via Social Media Cryptocurrencies and digital currencies: Becoming increasingly popular By design they are anonymous and it is impossible to ascertain with certainty the facilitator of such payments Terrorist financing via social media: a step into the regulatory unknown?

Legislative Framework The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017: Payment Services Regulations Electronic Money Laundering Regulations Do they fall within the scope of the Money Laundering Regulations 2017? Terrorist financing via social media: a step into the regulatory unknown?

Social media payments covered? Payment Services Regulations (S.I 2017/752) If yes, they are would be through ‘money remittance’ or ‘executing payment transactions’. Therefore, fall within the scope of the Regulations. Terrorist financing via social media: a step into the regulatory unknown?

Social media payments covered? The Electronic Money Regulations (S.I 2011/99) If yes, the payment would be classified as ‘e-money’. Therefore, fall within the scope of the Regulations. Terrorist financing via social media: a step into the regulatory unknown?

Conclusions If the payments fall under either of these Regulations, the social media provider is subject to Money Laundering Regulations 2017. However, it is not clear how the Money Laundering Regulations will apply. Terrorist financing via social media: a step into the regulatory unknown?