YOU ASKED: WHICH OF THE TWO ECONOMIC SECTORS IS MORE VULNERABLE TO EXPLOITATION BY TERRORIST GROUPS: BANKING OR INSURANCE? RELATED EXAMPLES
It is no secret that the type and number of terrorist organizations and related threats have evolved over time but the sine qua non of terrorism remains the same; to raise, move and distribute funds as surreptitiously as possible. Nevertheless, as the nature, structure and scope of terrorist organizations have changed, so –too- have their methods to acquire and manage funds. The resourcing needs of a terrorist organization vary greatly, depending on the nature of the organization itself, its operational continuum and the particular circumstances. Financing is necessary not just to fund specific terrorist operations; a considerable infrastructure is also required to sustain transnational terrorist networks and to promote their objectives over time. Terrorists have proved to be infinitely flexible, adaptive and creative regarding their fundraising methods. Disrupting the financial flow of terrorist organizations is instrumental in constraining the overall capabilities of terrorists and in helping hinder their ability to execute attacks. Thwarting terrorist financing involves both systemic safeguards, which protect the financial system from criminal abuse, and targeted economic sanctions informed by counter-terrorism intelligence, (FATF, p.4, 2008). The Financial Action Task Force (FATF) was established in 1989 on the initiative of the G7 to –initially- develop policies to combat money laundering but in 2001 the purpose expanded to include terrorism financing, (FATF, [no date]). Terrorist financing is often examined in tandem with money laundering. It is well known that that terrorist organizations periodically engage in money laundering and other general criminal activities, so as to supplement their revenues with other funding sources; therefore for both financial malfeasances, many of the possible countermeasures are similar (UNAFEI, 2016). However, there is an essential distinction between money laundering and terrorist financing; organized crime syndicates tend to disguise the criminal provenance of their proceeds using various surreptitious techniques, in order to make them appear legitimate, (Krieger & Meierrieks, 2011). More so for monetary profit, while –typically- terrorist organizations are more interested in the disbursement of the money and quite often, their funding sources are actually legitimate, (UNAFEI, 2016). Relatedly, terrorist financing is mainly directed at future activity and it is believed to constitute a small and difficult to detect portion of funds, occasionally embedded in the global, established financial system, (Krieger & Meierrieks, 2011). The multiplicity of fundraising schemes employed by terror networks, the constant evolution of tactics in response to international measures and the opportunistic nature of terrorist financing make it difficult to establish an effective epistemological framework to counter terrorist financing, (Williams, 2005). Although the progress made in the domain is substantially non-negligible and anti-money laundering (AML) and countering the financing of terrorism (CFT) regulations have made it more difficult for terrorist organizations to use traditional methods to raise or move funds (FATF, p.7, 2015), there are still considerable vulnerabilities and “loopholes”. Terrorist organizations seem to have a very sophisticated and intricate knowledge of the global financial system and exploit the same to their advantage, (Acharya, 2009).
The Banking Sector: Vulnerabilities / DeficienciesAccording to the FATF, “The banking sector continues to be the most reliable and efficient way to move funds internationally, and remains vulnerable to terrorist financing”, (FATF, p.22, 2015). The banking sector is a particularly appealing means for terrorist groups seeking to move funds within the international financial system, because of its rapidity and relative easiness. The sheer size and scope of the international banking sector allows terrorist groups and financiers to blend in with normal financial activity and –ultimately- to avoid detection, (FATF, 2015). The formal banking sector includes depository financial institutions (DFIs) – banks, savings and loans, and credit unions –, which are the sole entities permitted “to engage in the business of receiving deposits and providing access to those deposits” via a multitude of different paying methods i.e. checks, electronic transfers, credit and debit cards, and bank-to-bank transfers, (U.S. Money Laundering Threat Assessment, p. 1, 2005). Terrorism financing through the banking sector usually involves small-scale transactions and –more often than not- the aforementioned transactions are consistent with the customer’s profile, hence, seemingly innocuous, (National Commission on Terrorist Attacks Upon the United States, 2002). More complex schemes have used accounts of both legitimate and shell corporations with an international presence as fronts to clandestinely funnel money offshore, through mainstream financial channels, (Chatain et al. 2008). Although financial institutions worldwide have introduced a myriad of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) mitigation measures (both in the West and increasingly so in most emerging market countries), the risk remains high. Since the 1990s and with the 9/11 attacks and the post-2007 economic crisis, the banking sector became subject to scrupulous regulatory oversight, in attempts to make banking operations less risk prone and less vulnerable to terrorist financing. Most western banks are required to maintain detailed records, know their customers and report suspicious transactions of any amount, (Freeman, 2013). However, some traditional bank products and services pose a higher risk of money laundering or terrorist financing and they can be easily abused. Generally speaking, an increased level of risk may exist in cases, where, for instance, a bank’s products or services allow the customer to be treated anonymously, or involve international transactions or high volumes of currency transactions, (Chatain et al. 2009).
These high-risk categories can include, but are not limited to:
- Retail banking, where banks offer products and services directly to individuals and/or business customers (including legal arrangements), i.e. current accounts, loans (including mortgages) and savings products.
- Corporate and investment banking, where banks provide corporate finance and banking products, as well as investment services to corporations, governments and institutions.
- Investment services (or wealth management), where banks provide products and services to manage their customers’ wealth (sometimes referred to as private banking)
- Correspondent services, where banking services are provided by one bank (the “correspondent bank”) to another bank (the “respondent bank”).
-Electronic funds payment services: electronic cash stored value cards/payroll cards, payable upon proper identification transactions, third payment processors, and domestic and international funds transfers; also, automated clearing house transactions (ACH), remittance activity, Automated Teller Machines (ATM) and Mobile Phone Financial Services, (M-FS), (FATF, p.17, 2014; Chatain et al. p.32, 2009).
Before the 9/11 attacks, both the US government and the West in general, “did not think in terms of financial tracking, certainly not systematically and on an urgent basis”, (National Commission on Terrorist Attacks Upon the United States, p.8, 2002). Al Qaeda knew all the regulatory weaknesses and loopholes of the international banking system. Prior to the 9/11 attacks, AQ extensively utilized the notoriously under-regulated regional banking systems of the Middle East, including the United Arab Emirates, Lebanon, Bahrain and Kuwait, as well as bank branches in Pakistan, while it was based in Afghanistan, (Roth et al. p.67, 2004). Al Qaeda is also known to resort frequently to offshore banking services that provide high degrees of privacy and confidentiality, especially those in the Bahamas and Liechtenstein, (Vittori, p.90, 2005). Moreover, the group has extensively used Islamic Banking Institutions, which are purposely designed to operate in accordance with the rules of Shari’ah; these institutions usually have a high degree of autonomy and are known to commingle the funds of certain depositors with those of the investment account holders, preserving, this way, the anonymity of the accounts, (Vittori, p.90, 2005). Terrorist organizations in general, have frequently exploited the built-in practical impediments to international regulatory and law enforcement cooperation and have made use -on many occasions- of their financial services to carry out wire transfers and to establish accounts that require minimal or no identification or disclosure of ownership, (US Department of State Report, p.1, 2004). It should be noted, however, that even when a bank complies with enhanced “customer due diligence” standards, there are still substantial risks. For instance, in preparation for the 9/11 attacks, AL Qaeda allowed mostly low-level (unknown to law enforcement) operatives to use the international banking system, (Freeman, 2013); these operatives opened accounts at specific US banks, (namely the Union Bank of California and Sun Trust Bank in Florida) with their real identities, (National Commission on Terrorist Attacks Upon the United States, p.8, 2002). Al Qaeda operatives used these accounts to deposit and transfer funds (essential for the operation) and accessed the funds with ATM and debit cards, (Roth et al. p.67, 2004). These activities are consistent with standard financial services and due to the relatively small size of the transactions and the lack of credible threat indicators, these routine transactions would –possibly- not have set off any red flags even today, (Freeman, 2013). A far more extreme example of a terrorist group actually using banks to fund its activities involves the Islamic State group, which “looted between $500 million and $1 billion from bank vaults captured in Iraq and Syria and extorted many millions more from the populations under its control”, including Iraqi (government) bank employees, (Kaplan, p.1., 2015). The Iraqi government eventually shut down and cut off from the global financial system around 90 banks operating in territory controlled by ISIS, (Kaplan, 2015). Internationally coordinated efforts have been relatively successful in preventing ISIS from exploiting the Iraqi and Syrian bank branches and other financial institutions that it controls, that could be used to conduct international transactions. Nonetheless, ISIS is still able to receive money transferred to nearby areas or to designated individuals, whether through bank-issued electronic funds transfers (EFTs) or alternative money transfer systems, (Levitt, p.1., 2015). It is interesting to note that –historically- several terrorist organizations have resorted to bank robberies in order to raise revenue. For instance, the Red Army Faction (RAF) in Germany extensively used bank robberies as a fund-raising method and so did the Red Brigades in Italy (after 1972), ETA in Spain, the PIRA in Northern Ireland and so on, (Durmaz et al. 2007). Though bank robberies have declined in the past several years (due -in part- to improved security measures) as a revenue-generating method for terrorist groups, there are still several terrorist organizations that occasionally engage in bank robbery, including Al Qaeda in the Arabian Peninsula, Lashkar-e-Taiba, the Greek Revolutionary Struggle and others, (Money Jihad 2014; Greek Reporter, 2016; NDTV, 2016).
Relatedly, the Taliban are also believed to have used the regulated banking system on many occasions, in order to move the proceeds from drug trafficking, according to a 2014 Afghan drugs trafficking report, (FATF, 2015).Along the same lines, correspondent accounts have long been used by financial institutions to facilitate cross border transactions. Foreign correspondent banking relationships involve a domestic financial institution providing banking services to a foreign financial institution and its customers in a foreign country, (Volkov, p.1, 2016). Correspondent banking relationships are susceptible to terrorist financing because they involve a bank carrying out transactions on behalf of another bank’s customers, where information on those customers is very limited, (Volkov, 2016). The problem arises because banks have specific “Counter Terrorist Financing” compliance systems designed for their local country of operation and their regulatory guidelines are not necessarily capturing all the information and potential risks of another country’s financial institutions. That is why arranging new correspondent-banking relationship takes time and most international banks usually conduct and on-site visit and evaluation of the other bank’s risk compliance regime, before setting up a correspondent relationship, (Freeman, 2013). Such due diligence was not undertaken by HSBC-US which, according to a Senate Report, willfully ignored all allegations (subsequently proven true) of connections to terrorist financing, that involved one of its correspondent banks, the Riyadh-based Al Rajhi Bank, (US Senate Report, p.189, 2012).
The Underestimated Insurance Sector: Risks and Vulnerabilities
The origins of the modern insurance industry can be traced back to 1774, with the establishment of Lloyds; ever since, the financial sector of insurance has never ceased growing in scope, purpose, and availability, (Buckham et al. 2010). The economic reforms initiated in the early 1990s paved the way for the growth of the financial sector, which subsequently led to the gradual development of the insurance industry, (Ernst & Young, 2010). The insurance industry was opened up for private players in 2000 and saw a period of sustained massive growth over the past decade –globally- with the entry of global insurance majors, (Ernst & Young, p.8, 2010). The insurance industry in the United States is the largest in the world in terms of revenue. Since 2011, the annual revenue of the industry, known as insurance premiums, exceeded the $1.2 trillion mark, (Millard, p.1, 2015). Similarly, it is estimated that over 5,000 insurance and reinsurance companies operate currently in Europe, (Buckham et al. p. 9, 2010).The insurance sector is susceptible to systemic risks generated in other parts of the financial sector and it is vulnerable to criminal exploitation in different ways to that of the banking sector, (IAIS, 2006; Ridley, p.112, 2012). Firstly, the insurance industry is viewed as potentially vulnerable to ML and TF primarily because of its size, the easy availability and diversity of its products and the structure of its operational continuum. Regarding this last point, it should be mentioned that –occasionally- insurance is, in some jurisdictions, a cross-border business and -more often than not- it involves the distribution of its products through intermediaries and/or brokers, who are not necessarily under the immediate control or supervision of the company that issues the product, (FATF, p.19, 2004). Additionally, due to the fact that the beneficiary of an insurance product could potentially be different from the policy holder, it is often unclear when and for whom it is necessary to perform customer due diligence, (FATF, p.19, 2004). It is noteworthy also, that in many jurisdictions Customer Due Diligence and the subsequent monitoring of purchasers of insurance policies are actually carried out by intermediaries, (Ridley, p.114, 2012). Secondly, it is important to note that insurance policies in some jurisdictions are in bearer bond form, as in, they are unregistered (no records are kept of the owner, or transactions involving ownership), allowing anonymous purchase and transfer, (Ridley, p. 112, 2012). Anti money-laundering and terrorist financing awareness is directly proportional to risk-sensitive customer due diligence, monitoring measures and record-keeping of all financial activities, i.e. accepting deposits, making investments and/or opening accounts, (Financial Services Authority, 2011). Moreover, once a policy is purchased, there is a standardization of the premium payment; usually the premiums are paid regularly up to the time of cashing in the policy, with little to no monitoring at all and “no other transactional activity occurs”, (Ridley, p.114, 2012). Furthermore, it could be argued that the insurance sector has been –and to some extent still is- relatively antiquated in terms of its regulatory architecture. This is partly due to the fact that for a long period of time the insurance industry was not considered particularly susceptible to ML or TF. Restructuring in the banking and insurance sector in the mid-1990s led to a significant growth in complex financial investment products and the insurance sector also widened its scope, providing a broader array of insurance products, using high context information to personify policies, and allowing for aggregators to commoditize the market, (Laferriere, p.1, 2016). The variety of options and the plethora of investment and premiums made the industry considerably vulnerable to criminal exploitation. It must be noted, however, that insurance fraud has probably been around as long as insurance itself and it is (still today) perceived by a sizeable majority as a “victimless crime”, (Baldock, 1997). This faulty conceptualization paired with the complaisant mindset of regulators and the lack of systematic supervision and control has allowed insurance fraud to flourish worldwide, (Western National Insurance, [no date]). As mentioned above, the banking sector has come under tight scrutiny of regulation and prudential norms; such regulatory oversight was –somewhat- less pronounced in the insurance industry, (Acharya & Richardson, 2010). Money laundering has been an area of attention for policy makers for a while; notably, the European Union has been a leading institution in the Fight Against Money Laundering and in 1999 it adopted a Pan European Directive, standardizing the fight against money laundering, (Van Duyne et al. 2002). Nonetheless, it was not until the passing of the Second Anti Money Laundering Directive (2001) that the insurance sector was also included (on suspicious transactions and customers due diligence measures) and not until the Third Anti Money Laundering Directive (2005) that these regulations specifically applied to terrorist financing, as opposed to the rather generic term “terrorism”, (Ridley, p.116, 2012; Third Anti Money Directive, 2005). With the SOLVENCY II Directive –comprised of three pillars- (which eventually came into effect on 1 January 2016), the European Union officially adopted a regulatory framework that codifies and harmonizes the EU insurance regulation, primarily the amount of capital that EU insurance companies must hold to reduce the risk of insolvency, (Directive 2009/138/EC European Parliament & Council). However, this initiative was met with skepticism because it was contended that certain reforms -originally directed at the banking sector- and eventually transposed to other financial industries, could constitute a bad precedent: the conceptual and operational continuum of the banking sector is different to that of the insurance sector, hence applying banking-inspired regulatory standards to insurers, without an appropriate distinction between these two vastly different business models, could have a materially negative impact not only on the insurance sector but on the whole economy, (Insurance Europe, 2014). Although the demanding nature of SOLVENCY II has created compliance issues among EU firms, the Directive is still viewed by certain regulatory circles as the “best practice globally”, (Thomson Reuters, 2016).
Insurance as a modus operandi of terrorist financing? Related ExamplesAs mentioned above, there has been substantial underestimation of the growing symbiotic connection between insurance fraud and terrorist financing. There have been several cases indicating an insurance fraud - terrorist financing nexus. The most notable one took place in Germany, in 2003, where two Al Qaeda operatives plotted to fake the death of a fellow AQ member in a car crash in Egypt to collect more than $6.1 million in a massive life-insurance scheme. The proceeds would be remitted to an AQ cell in Europe. The purported crash victim, a Palestinian, would then continue to Iraq as a suicide bomber. The mastermind of the operation was a reputed AQ recruiter in Europe and received seven years in prison while the Palestinian received six, (Rollins & Wyler, 2012). Similarly, operatives of a UK-based terror cell were apprehended in the early stages of plotting a bomb attack in London; in order to fund the alleged plot, they planned to use insurance money by faking injuries from setup crashes. They pleaded guilty to terror-related charges, (Perry & Brody, 2011). Also of note, a 2006 case in the United States, which involved Karim Koubriti and his co- defendant Ahmed Hannon, both found guilty of insurance fraud and material support of terrorism in connection with their “economic jihad” scheme to defraud auto insurers with fake injuries for a minor auto crash. They provided fictitious invoices for medical bills, lost wages and rental-car costs, (O’Neil, 2007). There have been various similar incidents linking Hezbollah, the Jamaat Ul Fuqra group, Chechen separatists and even Islamic radical preachers (Musa and Ahmad Jebril) to insurance fraud and terrorist financing, (Barkhuizen, 2014). Additionally, British officials have repeatedly linked false claims on home and motor insurance policies to the travel of radicalized British Muslims to join the Islamic State in Syria and Iraq, (Insurance Fraud News, p.1, 2014). Insurance investigators did not actively pursue insurance fraud-terror links for some time, probably due to the existing misconception that terrorist groups need a considerable amount of money in order to perpetrate an attack; since the realization that small sums of money can easily finance an operation, insurance regulators have been more leery, (Barkhuizen, 2014). The insurance sector could potentially prove productive in terms of revenue raising for terrorism (although most plots are foiled with relative ease), but –more importantly- it occasionally has a consequential impact, usually favorable to terrorist groups. Perhaps the most notable maritime terrorist attack to date was the 2004 bombing of the Super Ferry 14, off the coast of the Philippines, that resulted in the loss of 116 lives; the explosion was perpetrated by the AQ-linked Abu Sayyaf group and it was officially classified as a terrorist attack, (Elegant, 2004). The incident resulted in a drastic increase in marine insurance premiums, inflicting major economic losses to the fragile Philippine economy, (Associated Press, 2005). Another far larger example of insurance indirectly having an effect on or facilitating terrorism is that of regional maritime attacks. In the case of an attack on the High Seas with verified terror background¹, the underwriters are precluded from funding any payments that could benefit terrorist activity. In other words, “if ransom is linked to terrorism, a claim for ransom costs by a cargo or hull owner would need to be declined”, at least officially, (Cargo Cover, Insurance & Piracy, [no date]). The eventuality of future maritime terrorism would oblige the shipping insurance companies to drastically increase their premiums to the shipping company that suffered the attack, (Eng Hock, 2013). Therefore, many cases of maritime terrorism (and even piracy attacks) are under-reported, predominantly for insurance reasons, i.e. the subsequent increase in insurance premiums; this increase often outweighs the value of the claim for smaller attacks, (Eichstaedt, 2010, Sakellaridou, p.10, 2009). A graphic illustration of this would be the case of the French-registered oil tanker, MV Limburg, which in 2002 was bombed by Al Qaeda off the coast of Yemen, (Kanana & Suwaed, 2009). In the period following the attack, Yemen’s port saw a sharp increase in insurance costs, forcing vessels to bypass Yemen and re-route to the ports of Djibouti and Oman, Yemen’s competitors in the shipping industry. It was reported that insurance premiums increased by 300%, while port activities decreased by 50%. These events resulted in an estimated loss of U.S.$3.8 million per month in port revenues for the Yemeni economy (Eng Hock, p.12, 2003; Office of Counter Terrorism, 2002). Maritime attacks oﬀer terrorists an alternate means of causing mass economic destabilization and the insurance aspect should not be underestimated.
¹There is a conceptual haziness between maritime piracy and maritime terrorism and there is a lack of intellectual and definitional consensus regarding the concept of maritime terrorism; it can be loosely described as “violent acts carried out by malevolent actors operating at sea, that are not piracy”, (Chalk, 2008).
What is more worrisome is that there seems to be an even darker link between piracy and terrorism; according to several analysts, Somali pirates pay as much as 50% of their revenue to the radical Islamist group Al Shabaab in the areas it controls, (Harper, 2009). There is a growing body of evidence suggesting that the large amounts of funds being raised –indirectly- by terrorist groups from ship-owner payments, could actually be funding the next generation of Islamic militants, (Helfman, 2011).
Given the vulnerabilities mentioned above, there is little doubt that both the banking and the insurance sector could be potentially exploitable for terrorist financing. A legitimate comparison between the two financial sectors can be made in that the points of entry and exit for both ML and TF schemes are through the banks, which constitute the backbone of the financial system. With the banking sector being substantially more scrutinized than the insurance sector, the latter was –long- left comparatively unsupervised and substantially underestimated as to its potential to generate funds for terrorist groups. Nevertheless, it appears that after years of “clamping down” on banks, the regulatory arbitration is starting to shift towards the insurance sector.
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