Crowdfunding for Terrorism Financing

• Proving intent may be difficult as donors may not know the true purpose of a crowdfunding campaign, and may not be aware that the funds will be used for terrorist financing. Fundraisers may lie about the true purpose and trick donors into supporting a fake sympathetic cause (e.g. to help victims of a natural disaster).
• Frequently, crowdfunding transactions are complex and can involve multiple digital payment methods that allow users to move funds quickly across borders anonymously, making it difficult to track financial flows.
• Many countries have not assessed the extent to which crowdfunding platforms are misused for terrorist financing and do not collect data on the subject. 
• Transactions and communications can be split across multiple digital platforms, some of which may be encrypted, hiding amounts sent, sender and recipient identities and correspondence between them. Platforms may have varying rules regarding data sharing and confidentiality.

• Consider factors that can increase risk of terrorist financing and violent extremism, for example the same crowdfunding service providers may appear again and again in TF investigations, or crowdfunding platforms that allow fundraising through unregulated virtual asset service providers are used.
• Take a holistic approach to considering the misuse of crowdfunding and analyse the entirety of the transaction chain, including the client's behaviour on any digital platforms, the type of crowdfunding platform used and any red flags related to the campaign itself.

The following risk indicators can help law enforcement recognise potential terrorist financing activity related to crowdfunding during their investigations.  

• The crowdfunding platform used hosts or enables other projects related to terrorism or violent extremism, or enables payments through unregulated financial institutions.
• The crowdfunding campaign contains a lack of information about the purpose, goals and ultimate beneficiaries of the campaign, or the project description features hateful rhetoric or symbolism.
• The project promoter withdraws funds immediately after receiving a donation, or their account receives a conspicuously large volume of transfers.
• Donors take great efforts to obscure the source of funds, or are connected to terrorist organisations or other organisation with violent extremist views.
• The campaign raises money for an organisation with links to conflict zones or neighbouring countries and receives unusually substantial donations.

• Intermediary organisations offering crowdfunding services may not have an-depth understanding of terrorist financing. They may struggle to recognise potential terrorist financing activity, and take the necessary action to disrupt it if does occur. 
• The financial institutions that are partnering with organisations providing crowdfunding services may encounter challenges in following the source of funds, especially if a campaign is launched on social media. 
• They may also have difficulty recognising suspicious activity given that many transactions involve small amounts of money. 

• Intermediary organisations offering crowdfunding services should develop awareness and expertise on terrorist financing, and have mechanisms in place to detect potential terrorist financing activity and report suspicious transactions.
• Crowfunding platforms’ terms of service should explicitly prohibit fundraising for the purpose of terrorism and violent extremism, and there should be consequences when this activity is detected.
• Platforms should balance mitigation of terrorist financing risks and innovation, without disrupting legitimate crowdfunding activity.
• Private and public sectors should enhance collaboration and information sharing, including between private sector stakeholders.

Certain red flags, or indicators, can point to potential crowdfunding for terrorism. The most relevant for the industry stakeholders are: 

• The crowdfunding platform used hosts or enables other projects related to terrorism or violent extremism, or enables payments through unregulated financial institutions.
• The crowdfunding campaign contains a lack of information about the purpose, goals and ultimate beneficiaries of the campaign, or the project description features hateful rhetoric or symbolism.
• The project promoter withdraws funds immediately after receiving a donation, or their account receives a conspicuously large volume of transfers.
• Donors take great efforts to obscure the source of funds, or are connected to terrorist organisations or other organisation with violent extremist views.
• The campaign raises money for an organisation with links to conflict zones or neighbouring countries and receives unusually substantial donations.

The vast majority of crowdfunding activity is legitimate.  This includes donations-based crowdfunding, which non-profit organisations frequently use to raise funds for a range of important causes, including humanitarian need to those in need.   

However, donations-based crowdfunding is also the type of crowdfunding that is most at risk of being misused to raise funds for terrorism: 

• Fraudulent campaigns that claim to be for humanitarian purposes (often in the absence of a registered charity) but are actually for terrorist financing.
• Fundraising campaigns are organised by or affiliated with charity organisations that operate as a front for terrorist financing and do not actually undertake humanitarian work.
• Terror groups or violent extremist entities abuse legitimate campaigns and skim the funds raised.

It is important to protect the legitimate use of crowdfunding platforms and to ensure human rights due diligence:

• Governments should balance the need to understand and mitigate terrorist financing risk with the need to support innovation and avoid hampering legitimate fundraising activity.
• Policy makers should be mindful of potential unintended consequences on the crowdfunding industry, and on legitimate users of crowdfunding platforms.
• The desing and review of measures to mitigate the risk of crowdfunding for terrorism financing should involve all relevant stakeholders, including representatives from civil society, to ensure human rights due diligence.
• Countries should fully implement the FATF standards regarding non-profit organisations.

The following risk indicators relevant to non-profit organisation could indicate potential crowdfunding for terrorism financing   

• Crowdfunding campaign is run by individuals or groups not linked to registered charities.
• Campaign appears to be fictitious i.e., the project has a name similar to an association or another well-known campaign or seems to impersonate it.
• The intermediary platform hosts or enables other projects related to terrorism or violent extremism.
• Funds raised are destined for areas noted as being at high-risk from terrorist financing or conflict zones.
• Crowdfunding campaign has a vague description and seeks funding for a general humanitarian cause like children in conflict zones.

Law enforcement, reporting entities and supervisors face a range of challenges to detect, investigate and prosecute crowdfunding for terrorism financing.  To strengthen their awareness, understanding and effective action, countries should:

• identify, assess and understand the terrorist financing risks related to the crowdfunding sector, and ensure those risks are effectively mitigated, while avoiding hampering legitimate financial activity.
• encourage a multi-stakeholder approach to risk mitigation, including representatives from national authorities, private sector, civil society and academia when designing and reviewing risk mitigation measures to ensure human rights due diligence.
• recognise the importance of public-private information sharing and put in place measures to do this effectively on a continuous basis.
• fully implement the FATF Standards relevant to other sectors involved in the crowdfunding ecosystem e.g., virtual assets, non-profit organisations and money and value transfer services.