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MAT SAYS:  comprehensive update on the FATF Terrorist Financing Typologies Report and its latest evolution

14/11/2025

MAT SAYS:  comprehensive update on the FATF Terrorist Financing Typologies Report and its latest evolution:

What the FATF Report Covers

The Financial Action Task Force (FATF) publishes periodic typology reports and updates on terrorist financing (TF).

The 2025 Comprehensive Update on Terrorist Financing Risks is the most extensive global assessment in a decade. It examines:

  • How terrorists raise funds:
    • Cash remains dominant but increasingly fragmented into micro-transactions to avoid detection.
    • Exploitation of natural resources (oil, minerals, timber) in weak governance zones.
    • Abuse of non-profit organisations (NPOs) and humanitarian channels.
    • Criminal convergence: links with drug trafficking, human smuggling, and extortion.
  • How funds are moved and stored:
    • Hawala and informal value transfer systems remain resilient.
    • Use of formal banking channels, prepaid cards, and money service businesses.
    • Digital platforms (social media, crowdfunding) for solicitation and propaganda.
    • Virtual assets and blockchain for pseudo-anonymous transfers.
    • Hybrid models combining cash, crypto, and trade-based laundering. [verafin.com][fiaumalta.org][sfm.com]
  • Adaptability and opportunism:
    • Terrorist groups exploit both traditional and emerging financial technologies, creating multi-layered financing channels that are harder to trace.
    • FATF warns that typologies are evolving faster than regulatory responses. [fatf-gafi.org][sfm.com]

Does It Properly Evaluate Evolution for Smarter CT?

Strengths of the Report:

  • Granular analysis: Includes case studies spanning 10+ years and contributions from 80+ jurisdictions, the private sector, academia, and think tanks.
  • Risk-based approach: Emphasises proportionality and context-specific measures rather than blanket restrictions.
  • Integration of digital risks: Addresses virtual assets, decentralised finance, and online platforms in detail.
  • Cross-sector convergence: Highlights links between terrorism financing and organised crime, corruption, and professional enablers. [un.org][gnet-research.org]

Limitations:

  • Indicators vs. actionable typologies: The report provides 150 risk indicators, but many resemble generic AML red flags and fall short of offering predictive typologies for proactive detection.
  • Effectiveness gap: FATF mutual evaluations show only 30% of countries rated positively for investigations (IO9) and 15% for prevention (IO10), meaning practical implementation lags behind analytical insight. [thefinanci…menews.com]
  • Private sector challenges: Detecting TF remains extremely difficult without named persons or high-risk jurisdictions; FATF acknowledges this gap persists despite guidance. [thefinanci…menews.com]

Key Recommendations for a Smarter, Nuanced Approach

  1. Enhance Financial Intelligence Fusion: Combine financial data with counter-terrorism intelligence for holistic threat mapping.
  2. Strengthen Virtual Asset Oversight: Implement blockchain analytics and licensing for VASPs (Virtual Asset Service Providers).
  3. Public–Private Partnerships: Expand information-sharing frameworks beyond banks to fintechs, crowdfunding platforms, and humanitarian actors.
  4. Contextual Risk-Based Controls: Avoid blanket de-risking; apply proportionate measures to preserve financial inclusion while mitigating TF risk.
  5. Capacity Building for Smaller Jurisdictions: Technical assistance and shared analytics to close structural gaps in detection and prosecution. [finreg-e.com][anti-money…ndering.eu]

Bottom Line

The FATF report does evaluate the evolution of terrorist financing comprehensively, but translating this into smarter CT (Counter-Terrorism) strategies requires:

  • Moving from descriptive indicators to predictive analytics.
  • Embedding technology-driven detection (AI, blockchain monitoring).
  • Balancing security with financial inclusion to avoid pushing transactions underground.

Source

https://www.fatf-gafi.org/en/publications/Methodsandtrends/comprehensive-update-terrorist-financing-risks-2025.html

MAT SAYS TERRORISM FINANCING FATF

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