On 17 July, the FIAU in Malta released this document on emerging trends, typologies and red flags related to the funding of terrorism.  This replaces a 2018 publication after, in 2019, the National Co-ordinating Committee on Combating Money Laundering and Funding of Terrorism (NCC) carried out a Terrorism Financing Risk Assessment to assess the risks of financing of terrorism in Malta.  This new Guidance Document on the Funding of Terrorism combines insights and select findings from the 2019 risk assessment and builds on the 2018 Guidance Note by providing more substantive information on emerging trends and typology-specific case studies and red flags. The document is divided into 3 Chapters –

  • Chapter 1 introduces the topic of financing terrorism, by defining and setting out the activities that comprise it and provides an overview of Malta’s inherent vulnerabilities relating to the movement of funds;
  • Chapter 2 looks at different typologies and red flags associated with various products and services, with case studies from across the globe; and
  • Chapter 3 contains a list of red flags based on emerging trends identified in Malta.


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Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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