Terrorist Financing Red Flags — Training for Financial Institutions & VASPs

All financial institutions and Virtual Asset Service Providers are responsible for detecting and monitoring illicit or suspicious activity related to terrorist financing. Following FinCEN's issuance of Terrorist Financing Red Flags on October 20, 2023 in response to the Hamas terrorist attack on the people of Israel, many financial institutions sought to ensure their compliance teams could effectively recognize and respond to these red flags.

FinCEN urged all financial institutions including VASPs to be vigilant in identifying suspicious activity relating to the financing of Hamas and to report it to FinCEN. FinCEN requested that financial institutions reference the alert in SAR field 2 (Filing Institution Note to FinCEN) and the narrative by including the key term "FIN-2023TFHAMAS" and select SAR field 33(a) (Terrorist Financing—Known or suspected terrorist/terrorist organization).

Foodman has been educating and training compliance staff on understanding FinCEN's Terrorist Financing 7 Red Flags, equipping institutions with the knowledge to meet their reporting obligations and protect against exploitation by bad actors.