Terrorist Financing (JFSC Guidance Note)

Summary

This is an educational guidance note from the JFSC explaining what terrorist financing is, how it differs from money laundering and proliferation financing, and how funds are raised, moved, stored, managed, obscured and used by terrorist organisations, cells and individuals. It does not create new rules but is intended to help supervised persons recognise terrorist financing risk indicators and typologies as part of their existing AML/CFT obligations.

• Nature of terrorist financing: Explains that terrorist financing is a criminal offence in Jersey under the Terrorism (Jersey) Law 2002 and the Sanctions and Asset-Freezing (Jersey) Law 2019, and can occur even if funds are never actually used for an attack.
• Linear process stages: Describes the stages of terrorist financing (raising, moving, storing, managing, obscuring and using funds) with examples such as charities/NPO abuse, virtual assets, informal value transfer systems and professional service providers.
• Forms of involvement: Lists activities that constitute involvement in terrorist financing, including facilitating travel of foreign terrorist fighters, providing training, recruiting, procuring funds and laundering proceeds for terrorist purposes.
• Targeted financial sanctions: Notes that targeted financial sanctions related to terrorist financing (TFS-TF) prohibit making funds or assets available to designated persons and require freezing of existing funds; circumventing or facilitating a breach is a criminal offence.
• Cross-references: Points readers to the Handbook's comparison table on money laundering, terrorist financing and proliferation financing, Appendix D2 on country risk, and Section 8 of the Handbook for reporting requirements.

The note is aimed at supervised persons and professionals (such as lawyers, accountants, estate agents and lenders) to raise awareness of terrorist financing risk, rather than to impose new standalone requirements beyond those already set out in the Handbook and relevant Jersey laws.

Applies to

supervised persons, lawyers, accountants, estate agents, lenders, trust company service providers