Counter-terrorist financing
Counter-terrorist financing

The following Risk & Compliance guidance note provides comprehensive and up to date legal information covering:

  • Counter-terrorist financing
  • What is terrorist financing?
  • Counter-terrorist financing and anti-money laundering
  • What’s the risk?
  • Terrorism Act 2000
  • Principal offences
  • Failure to disclose offences
  • Tipping-off and interfering with materials
  • SuperSARs
  • Other terrorist property offences

This Practice Note outlines counter-terrorist financing provisions (CTF), including the offences and obligations contained in the Terrorism Act 2000 (TA 2000) and related legislation. It sets out what terrorist financing is, how it relates to the anti-money laundering (AML) regime and why it is important for businesses.

What is terrorist financing?

Terrorists need funds to plan and carry out attacks. TA 2000 criminalises both the participation in terrorist activities and terrorist financing.

In general terms, terrorist financing is the provision or collection of funds from legitimate or illegitimate sources with the intention or in the knowledge that they should be used to carry out any act of terrorism, whether or not those funds are in fact used for that purpose.

Counter-terrorist financing and anti-money laundering

Counter-terrorist financing (CTF) and AML are different concepts, albeit with similar aims. The CTF and AML regimes run together in UK legislation. Many of the provisions of the Proceeds of Crime Act 2002 (POCA 2002) and TA 2000 closely mirror one another and the definitions in each are deliberately matched. Both Acts run parallel to the MLR 2017 in terms of required systems and controls.

Both AML and CTF regimes require a risk-based approach under the MLR 2017. However, since terrorist funds can originate from a legitimate source it can be much harder to detect. The