Terrorism Financing Risk in Mauritius: One Man's Freedom Fighter Is Another Man's Terrorist

Mathew Beale, Comsure CEO, has prepared the following article in anticipation of his visit to Mauritius in October (13-25) and his training programmes during his visit.

• https://www.comsuregroup.com/news/mauritius-why-travel-for-training-when-you-can-bring-it-to-your-office/
• https://www.comsuregroup.com/news/mauritius-financial-crime-conference-speaker-lineup-for-22-23-october-its-impressive/

Terrorism Financing Risk in Mauritius: One Man's Freedom Fighter Is Another Man's Terrorist

In the intricate landscape of global security, the line between heroism and horror often blurs.

Mauritius’ Vulnerability as an IFC

• Mauritius’ robust financial sector and strategic location make it a magnet for legitimate finance but also a potential conduit for illicit funds.
• Terrorist financiers could exploit its UN-aligned standards to route money for groups sanctioned elsewhere but not locally, transferring assets from stricter jurisdictions, such as the US, UK, EU, through Mauritian entities before dispersing them globally.
• This regulatory arbitrage undermines international counter-terrorism efforts and exposes Mauritius to reputational risks, potential secondary sanctions, and scrutiny from the Financial Action Task Force (FATF).

Mauritius and terrorism cases:

• A recent case in Mauritius, where four nationals were charged with financing terrorism, exposes the island's vulnerability to exploitation by terrorist supporters and financiers. This incident underscores the broader challenge of preventing illicit funds from flowing through International Financial Centres (IFCs) like Mauritius, where regulatory gaps can be leveraged to support global terrorism.
• It has been reported that the four individuals, Mohammad Zafirr Rechad Golamaully, Rechad Golamaully, Lubnaa Rechad Golamaully, and Samuel Tashvin Jodhun, were provisionally charged under the United Nations (Financial Prohibitions, Arms Embargo and Travel Ban) Sanctions Act 2019 and added to Mauritius’ national sanctions list.
• They are accused of channelling financial support to ISIS via intermediaries in Türkiye.
• Reports also implicate family members in Mauritius and the UK, with UK-based relatives convicted in 2016 under the UK Terrorism Act for similar offences.

Who are the terrorists

• This case evokes the timeless adage:
• One man's freedom fighter is another man's terrorist.
• It highlights the profound challenges of preventing and detecting terrorism financing in a world where definitions of terrorism diverge sharply across borders.

The Global Framework and Its Limitations

• The United Nations Security Council (UNSC) maintains a Consolidated Sanctions List, a global benchmark for identifying terrorists and terrorist organisations. This list imposes asset freezes, travel bans, and arms embargoes on designated individuals and entities threatening international peace.
• Yet, the UN's designations often clash with national perspectives. Notably, Hamas is absent from the UN Consolidated Sanctions List and its terrorism-related regimes.
• As of September 2025, I could count only 9 out of 195 sovereign states (treating the EU as one) that designate Hamas as a terrorist organisation, leaving 186 without such a classification.
• This discrepancy hampers global enforcement efforts, limiting sanctions or asset freezes against Hamas compared to universally condemned groups like ISIS or Al-Qaida.

Mauritius adheres to the UNSC.

• Mauritius, a prominent International Financial Centre (IFC), adheres strictly to UNSC designations under its 2019 Sanctions Act, focusing primarily on groups like ISIS, Al-Qaida, and the Taliban.
• Unlike nations such as the UK or the US, which maintain autonomous terrorist lists through bodies like the Home Office or State Department, Mauritius has not independently designated additional terrorist organisations. Consequently, financing or associating with groups not on the UN list may not be criminalised locally, creating potential loopholes in the global counter-terrorism framework.
• However, Mauritius has demonstrated flexibility in targeting individuals. The recent inclusion of the four nationals on its national sanctions list, issued via public notices by the National Sanctions Secretariat, shows its ability to act domestically against specific threats outside the UN framework.
• This individual-focused approach enables swift enforcement against financiers or supporters, but does not extend to organisations, leaving groups like Hamas unchecked unless they are aligned with UN measures.

• Other unaligned approach leaves several prominent groups undesignated in Mauritius, including (but not limited to):
• Hezbollah
• Palestinian Islamic Jihad (PIJ)
• Popular Front for the Liberation of Palestine (PFLP)
• Al-Aqsa Martyrs Brigade
• Lashkar-e-Taiba (LeT)
• Islamic Revolutionary Guard Corps (IRGC)
• Balochistan Liberation Army (BLA)
• Wagner Group

The Wagner Group

• The Wagner Group illustrates how these gaps can be exploited.
• This Russian private military company, often tied to mercenary activities and human rights abuses, has leveraged international financial channels and illicit networks to fund operations some classify as terrorism-related.
• Investigations reveal that Wagner entities processed payments through central Western banks, such as HSBC and JP Morgan, often unwittingly, to evade sanctions.
• The group has also exploited African natural resources, gold and diamonds, to funnel proceeds through opaque financial systems.
• If Wagner can navigate these channels, other undesignated groups may adopt similar "IFC playbooks" to exploit regulatory differences.

Some Examples of Terrorist Exploitation of IFCs

• Documented cases highlight how terrorist groups leverage IFCs’ features, banking secrecy, ease of company formation, and global connectivity to obscure and move funds:
• Al-Qaida and Hamas in the Bahamas –
• Before and after the September 11, 2001, attacks, Al-Qaida and Hamas established offshore networks in the Bahamas, an IFC then known for privacy protections.
• Shell companies and trusts disguised funds as charitable donations or business transactions. U.S. Treasury efforts disrupted these networks, highlighting how lax oversight in IFCs can enable terrorist financing.
• ISIS in Türkiye –
• Between 2014 and 2024, ISIS used Türkiye as a regional financial hub, processing hundreds of thousands of dollars through hawala networks and local facilitators in Türkiye and Iraq.
• These funds, often blended with cash from controlled territories, supported operations in Europe, taking advantage of inconsistent enforcement of sanctions. U.S.-Türkiye designations in 2023 targeted this network.
• UAE as a Conduit –
• Until its removal from the FATF grey list in 2024, the UAE facilitated terrorist financing through its banking and trade sectors.
• Funds were routed via informal value transfer systems or disguised as remittances, with insufficient controls enabling groups to exploit the IFC’s connectivity.
• Hezbollah in Latin America –
• Hezbollah has used free trade zones like the Tri-Border Area (Paraguay, Brazil, Argentina), akin to IFCs, for fundraising through illicit trade and money laundering via shell companies.
• These funds support global activities, including arms procurement, which is often integrated with organised crime networks.
• These cases demonstrate a pattern of exploiting regulatory gaps, with terrorist groups adapting traditional methods like hawala alongside digital tools to evade detection.

Mauritius Should Move Towards a Balanced Response

• The global response to terrorism financing remains fragmented. The UN framework, while unifying, is constrained by conservative designations requiring consensus among veto-wielding powers, leaving exploitable blind spots.
• For Mauritius, striking a balance between sovereignty and global responsibility is crucial.
• Strengthening domestic oversight, such as expanding individual designations, creating a supplementary high-risk entity watchlist, or enhancing financial sector due diligence, could mitigate vulnerabilities without deviating from international norms.
• The adage One man's freedom fighter is another man's terrorist remains poignant.
• Divergent perceptions of terrorism shape policy, but in an interconnected world, these differences create opportunities for exploitation. The recent Mauritian case highlights the need for vigilance and a re-evaluation of global standards to address these gaps.
• Only by harmonising definitions and strengthening IFCs like Mauritius can we prevent the next "freedom fighter" from becoming tomorrow’s financier of terror.

Mathew Beale is in Mauritius between October 13 and 24 – please feel free to contact him at mathew@comsuregroup.com to organise a catch-up and/or some training.

MATHEW BEALE

Mathew Beale - Chartered FCSI

Principal & Director - Comsure Compliance Limited, Comsure Technology Limited, Comsure Mauritius

(the "Comsure Group of Companies")

mathewbeale@comsuregroup.com

www.comsuregroup.com

T (Jersey) +44 1534 733-588 /+44 7797 747-490