Terrorist Financing (TF) Activities Related to Islamic State (ISIS) in the United States

Despite a significant reduction in U.S. persons traveling overseas to join ISIS, there is still a risk of TF activity in the United States. This report highlights key points and case examples that demonstrate the ongoing threat.

The Threat of Terrorist Financing in the United States

• Risk remains: Despite a decrease in U.S. individuals joining ISIS abroad, there is still a significant risk of TF activity within the country.
• Layered financial schemes: U.S.-based supporters collect and consolidate donations within the United States before transferring funds outside the country using unwitting money services businesses (MSBs) or banks.

Methods Used by Terrorist Facilitators

• Virtual assets: Although limited, ISIS continues to explore the use of virtual assets for moving funds raised in the United States to shell companies around the world.
• Shell companies: Financial facilitators are looking to move funds through these entities to avoid detection.
• Complicit individuals and entities: Authorities have identified instances where ISIS operatives route transactions through complicit individuals or shell companies to evade detection.

Case Examples

• Conspiracy to provide material support: A Bangladeshi husband and wife were sentenced in 2022 for conspiring to provide material support to ISIS.
• Attempted material support: An individual pleaded guilty in 2021 to attempting to provide material support to ISIS and Al-Nusra Front.
• Cyber-enabled terror finance campaigns: Several forfeiture actions were taken in 2020 to dismantle cyber-enabled terror finance campaigns supporting ISIS, AQ, and HAMAS.

Conclusion

The ongoing risk of TF activity related to ISIS in the United States requires financial institutions to remain vigilant in detecting and preventing such activities.