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SOCIAL MEDIA AND TERRORISMFINANCINGA joint project by Asia/Pacific Group on Money Laundering & Middle Eastand North Africa Financial Action Task ForceProject Co-leads: Egypt and MalaysiaAPG Comment: does anyone have a good picture for the cover page?

January 2019 APG/MENAFATFNo reproduction or translation of this publication may be made without prior written permission.Applications for permission to reproduce all or part of this publication should be made to:APG SecretariatLocked Bag A3000Sydney SouthNew South Wales 1232AUSTRALIATel: 61 2 9277 0600E mail: mail@apgml.orgWeb: www.apgml.orgPage 1

ContentsAbbreviations and Terminology . 1Executive Summary. 1Introduction . 2Objectives and Structure . 2Scope . 2Methodology. 3Disclaimer. 3Part One: Key Features of Global TF and Social Media Environments . 41.1 Evolving Nature of Terrorism and TF Methods and Trends . 41.2 Increasing Use and Evolution of Social Media Services and Vulnerabilities to Abuse for TF . 5Part Two: Analysis of Cases in which Social Media Services were abused for TF. 82.1 Channels used for Terrorism Financing . 82.1.1 Social Networking Services (SNS) . 82.1.2 Content Hosting Services . 102.1.3 Crowdfunding Services . 112.1.4 Internet Communication Services. 122.2 General Analysis and Summary . 152.2.1 Detection mechanisms. 152.2.2 NPOs and social media . 162.2.3 Payment methods . 162.2.4 Declared use of funds versus the actual use . 16Part Three: Challenges and Measures in Combating TF via Abuse of Social Media . 203.1 Challenges and measures for detection of TF. 203.2 Challenges and measures in investigation and prosecution of TF . 21Part Three: Collaborative Approaches to Preventing the Abuse of Social Media for TF . 233.3 Increasing public awareness of abuse of social media for TF . 233.4 Supporting the removal of Terrorism and TF related content. 233.5 Counter-Messaging . 23Conclusion and Recommendations . 25APPENDIX A – Social Media and Terrorism Cases. 26APPENDIX B - Summary of Indicators . 34APPENDIX C – Project Questionnaire . 36Page 1

Abbreviations and TerminologyAPGCHSCrowdfundingServicesFATFFTFGlobal SNSTTFTFITIThreatTPSVulnerabilityAsia/Pacific Group on Money LaunderingContent Hosting Services, which allow users to create or upload content,for example, text, photos or videos, which is almost always public withless of a focus on connections/networks and more of a focus on generalpublic consumption.Allow users to fund a project, venture or cause within a bounded systemby raising small amounts of money from many individuals.Financial Action Task ForceForeign terrorist fightersGlobal anti-money laundering/combating the financing of terrorism(AML/CFT) networkInternet Communication Services, which allow two or multiple users tocommunicate in-real time over the internet normally in text but also invoice and video and with imagesInternet Payment ServicesIslamic State of Iraq and the LevantMiddle East & North Africa FATFMobile Payment ServicesMoney value transfer servicesNew Payment MethodsNew payment products and servicesIs a function of three factors: threat, vulnerability and consequenceSocial Media PlatformsSuspicious Matter ReportSocial Networking Services, which allow users to create public or semipublic profiles and other content, articulate with other users they share aconnection with and also view and interact with the content these otherusers have created.TerrorismTerrorism financingTerrorism financing indicatorTerrorism indicatorIs a person or group of people, object or activity with the potential tocause harm to, for example, the state, society, the economy, etc. In the TFcontext this includes terrorists, terrorist groups and their facilitators,their funds, as well as past, present and future TF activities.Traditional Payment servicesComprises those things that can be exploited by the threat or that maysupport or facilitate its activities. In this context it could include thewider financial system and mechanisms or products used to move andstore funds. Vulnerabilities may also include the features of a particularsector, a financial product or type of service that make them attractivefor TF purposes.Page 1

Executive SummaryThe number, type, scope, and structure of terrorist actors and the global terrorism threat arecontinuing to evolve. Recently, the nature of the global terrorism threat has intensified withterrorist attacks across the globe carried out, for example, by small cells, and the threat posed byterrorist organizations such as Islamic State of Iraq and the Levant. Irrespective of the differencesin financial requirements between terrorist groups or individual terrorists, since funds are directlylinked to operational capability, all terrorist actors seek to ensure adequate revenue andmanagement of funds. The global anti-money laundering/combating the financing of terrorism(AML/CFT) network (Global Network) has recognised that social media services are susceptible tobe abused for terrorism financing (TF).To support Asia/Pacific Group on Money Laundering (APG) and Middle East & North Africa FATF(MENAFATF) members to combat TF, this report identifies techniques and trends, includingindicators, associated with the abuse of social media services for financing acts of terrorism,individual terrorists or terrorist organisations. This report is co-led by Egypt and Malaysia.27 jurisdictions responded to the report questionnaire and provided some case examples of TFthrough abuse of social media services. These cases show social networking services (e.g.Facebook), content hosting services (e.g. YouTube), crowdfunding services (e.g. GoFundme.com)and Internet Communication Services (e.g. WhatsApp) are being abused in a variety of ways for TF,as follows: Social networking and content hosting services are primarily used to solicit donations,promote terrorism through propaganda and radicalization. Consistent with the currentlimited integration of payment methods in these services, most cases provided as part ofthe report show donated funds are moved using traditional payment methods i.e. banks. Internet communication services were used in many cases to privately communicatewith campaigners or terrorist groups. They mainly discussed means of support andpayment methods. The vulnerabilities of these services, for example, encryptedcommunication and the number of active users, are factors driving their abuse for TF. Crowdfunding services were used in a number of cases, with campaigners oftendisguising the use of funds for humanitarian causes. These services often integratedtraditional and new payment services, which due to their vulnerabilities may hinder TFdetection and investigation by competent authorities.To assist APG and MENAFATF members to combat TF, this report examines key challenges in thedetection, investigation and prosecution of TF through the abuse of social media services, andincludes measures to assist competent authorities overcome these challenges.In acknowledgment of the prominent role of social media services in daily life and as key partnersin global counter terrorism efforts, this report also highlights a number of avenues APG andMENAFATF members can work collaboratively with social media companies to prevent their abusefor TF. These avenues include increasing public awareness, supporting the removal of terrorismand TF related content, and counter-messaging.Page 1

Introduction1.The Financial Action Task Force (FATF) in its 2015 report recognised social mediaservices as susceptible to abuse for raising terrorist funds. The report acknowledged the prominentvulnerabilities associated with social media services, including anonymity and access to a widerrange and number of potential sponsors or sympathizers1. Since this report, other publicationshave echoed similar views on the abuse of social media services for terrorist propagation andradicalisation, especially in relation to Islamic State of Iraq and the Levant (ISIL).2.In 2016 the Asia/Pacific Group on Money Laundering (APG) and Middle East & NorthAfrica FATF (MENAFATF) initiated a joint typologies project to identify techniques and trendsassociated with the abuse of social media services for financing acts of terrorism, individualterrorists or terrorist organisations. The purpose of the project is to assist APG and MENAFATFmembers, and the Global Network, to combat TF. This report is the primary output of the jointproject.Objectives and Structure3.This report has three primary objectives, which are reflected in the structure of thedocument, as follows: Part one: Provides an overview of the key features of the global social media and TFenvironments. Part two: Examines the methods and trends of TF through abuse of social mediaservices, and develops indicators for use by competent authorities to combat TF. Part three: Highlights the challenges in detecting, investigating and prosecuting TFassociated with social media within the APG and MENAFATF regions, and offersmeasures for overcoming these challenges and collaborative approaches to prevent theabuse of social media services for terrorism and TF.Scope4.This report aims to provide an updated and more precise understanding of TF through theabuse of social media services, by analysis of case studies primarily provided by APG andMENAFATF members. While this report includes some discussion on new payment products andservices (NPP&S) that are embedded in some social media services, it does not include an in-depthanalysis of these products and associated level of ML/TF risks2. For example, this report does notdistinguish between the different vulnerabilities of embedded Traditional Payment Services (TPS),Internet Payment Services (IPS) or Mobile Payment Services (MPS), such as PayPal, credit cardpayments, or bank transfers used in different crowdfunding sites; or peer-to-peer payment systemsused in Internet Communication Services.FATF Report on Emerging Terrorist Financing Risks (2015)Please see FATF Report on Money Laundering Using New Payment Methods (2010) for discussion on the risksassociated with New Payment Methods.12Page 2

5.Furthermore, as most social media services operate through internet browsers on standalone computers and applications on mobile devices, this report does not distinguish between thedifferent platforms social media services may operate on.Methodology6.The project was co-led by Egypt and Malaysia and supported by the APG and MENAFATFsecretariats. The report relies on data from members of the global AML/CFT network and on opensource material, including reports issued by governments or international organisations, and riskassessments undertaken by relevant jurisdictions.7.The project team collected information on abuse of social media services for TF through aquestionnaire (see Appendix B), which included a request for relevant case studies and questionson the following issues: National policy, legal, and regulatory measures;Monitoring and surveillance;Investigation and prosecution of TF cases relating to social media;International cooperation;Collaboration with the private sector;Capacity building; andCounter-messaging.8.The social media project questionnaire was disseminated to all APG and MENAFATFmembers/observers, and the AML/CFT Global Network. A total of 27 jurisdictions responded to thequestionnaire including 14 APG members/observers3, five MENAFATF members4 and seven othermembers of the Global Network5.Disclaimer9.This report names a number of social media and other associated companies, primarily incase studies. The authors of this report would like to stress that these companies are not supportingterrorism, TF or other criminal activities in any form. Rather, these companies are key partners inglobal counter terrorism efforts, and have been abused by individual terrorist, terrorist groups orcriminals.Australia, Bangladesh, Bhutan, Brunei, Japan, Macau, China, Malaysia, Singapore, Thailand, United States, Vietnam, LaoPDR, DPRK and Kiribati4 Kuwait, Sudan, Jordan, Yemen and Egypt5 Azerbaijan, Czech Republic, Ethiopia, Montenegro, Spain, Turkey and Zimbabwe3Page 3

Part One: Key Features of Global TF and Social Media Environments10.This section provides an overview of the key features of the global TF and social mediaenvironments. It includes a brief discussion of the evolving nature of terrorism and TF methodsand trends; and distinguishes between different social media services, their use, andvulnerabilities to TF abuse.1.1 Evolving Nature of Terrorism and TF Methods and Trends11.The number, type, scope, and structure of terrorist actors and the global terrorismthreat are continuing to evolve. Recently, the nature of the global terrorism threat hasintensified considerably. In addition to the threat posed by terrorist organisations such as ISIL,Al-Qaeda and other groups, attacks in many cities across the globe are carried out by individualterrorists and terrorist cells ranging in size and complexity. Commensurate with the evolvingnature of global terrorism, the methods used by terrorist groups and individual terrorists tofulfil their basic need to generate and manage funds is also evolving.12.Terrorist organisations use funds for operations (terrorist attacks and pre-operationalsurveillance); propaganda and recruitment; training; salaries and member compensation; andsocial services. These financial requirements are usually high for large terrorist organisations,particularly those that aim to, or do, control territory. In contrast, the financial requirements ofindividual terrorists or small cells are much lower with funds primarily used to carry outattacks. Irrespective of the differences between terrorist groups or individual terrorists, sincefunds are directly linked to operational capability, all terrorist groups and individual terroristsseek to ensure adequate funds generation and management6.13.The FATF and members of the Global Network have developed a large body of researchexamining TF methods and trends. In general, this research shows terrorist groups andindividual terrorists rely on numerous sources of funds, from both criminal and legitimateactivities, which they move, including internationally, using a variety of methods to end-usedestinations. The FATF Report on Emerging Terrorist Financing Risks (2015) discussestraditional and emerging TF methods and trends. This report highlights traditional methods ofgenerating funds including private donations; abuse and misuse of non-profit organizations;extorting local and diaspora populations and businesses; kidnapping for ransom; self-funding;legitimate commercial enterprise; and state sponsorship. Traditional methods to move fundsinclude transfers through banks; money value transfer systems and the physical transportationof cash.14.While the 2015 FATF report and subsequent research highlights that traditional TFmethods and trends are prevalent today and remain a significant TF risk, emerging or newmethods of generating and moving funds have been identified, particularly in association withforeign terrorist fighters (FTFs) and ISIL. For FTFs, revenue generation is primarily in the formof self-funding and support from recruitment and facilitation networks with funds moved viatraditional methods and NPP&S including virtual currencies, prepaid cards and IPS7. For ISIL,sources of revenue include illicit proceeds from occupation of territory; kidnapping for ransom;donations including by and through NPOs; and material support from FTFs with funds movedvia traditional methods and NPP&S8.15.In addition to the above TF methods and trends, research by the FATF and members ofthe Global Network highlights the abuse of social media services to generate and move funds tosupport the financial requirements of terrorist groups and individual terrorists. For example,See FATF Report on Emerging Terrorist Financing Risks (2015) for a detailed discuss of terrorist organisations use funds.FATF Report on Emerging Terrorist Financing Risks (2015)8 FATF Report on Financing of the Terrorist Organisation Islamic State in Iraq and the Levant (ISIL) (2015)67Page 4

FATF’s 2015 Report includes a discussion on how individuals associated with ISIL called fordonations on Twitter. This report aims to supplement previous research on TF and provide keyindicators for use by competent authorities to combat the financing of terrorist groups andindividual terrorist via social media services.1.2 Increasing Use and Evolution of Social Media Services and Vulnerabilities to Abuse forTF16.Consumer needs and market share continue to drive the use and evolution of socialmedia services. Since 2004 global use of social media services has increased dramatically. In2010 there were 0.97 billion social media users, in 2015 there were 2.14 billion users, and in2017 there were 2.46 billion9 users, which equates to approximately 32% of the globalpopulation10. It is estimated that by 2021, 3.02 billion people will be using some form of socialmedia service11. Facebook (launched in 2004) is the most popular social media service with 2.18billion monthly active users, followed by YouTube and WhatsApp with 1.50 billion and 1.3billion monthly active users, respectively (see Chart 1).17.Commensurate with the dramatic increase in use, social media companies continue todevelop their services to meet consumer needs, and this continually challenges definitionalconsensus of the term social media and research on their vulnerabilities to TF. In a 2015 reviewof the term social media and social media regulation, Obar and Wildman identified fourcommonalities of social media services, which are: (i) social media services are Web 2.0Internet-based applications, (ii) content is principally user-generated, (iii) individuals andgroups create user-specific profiles designed and maintained by a social media service, and (iv)social media services facilitate the development of online social networks by connecting aprofile with those of other individuals and/or groups12.Chart 1: Top 20 Global Social Media Services, Ranked by Number of Active Users(in Millions) as of January 2018132167150013001300980843 800 794568376 330 300 300260 260 255 250 203 umber-of-worldwide-social-network-users/Global population of 7.55 billion in 2017 - http://www.worldometers.info/world-population/11 of-worldwide-social-network-users/12 Obar, Jonathan A; Wildman, Steve. Social media definition and the governance challenge: An introduction to the special issue(2015)13 Chart modified from social-networks-ranked-by-number-of-users/910Page 5

18.For the analysis of case studies in this report, social media services have beencategorised as follows: Social Networking Services (SNS) allow users to create public or semi-public profilesand other content, articulate with other users they share a connection with and alsoview and interact with the content these other users have created14. Common SNSinclude Facebook, Twitter and Instagram. Content Hosting Services (CHS) allow users to create or upload content, for example,text, photos or videos, which is almost always public with less of a focus onconnections/networks and more of a focus on general public consumption. CommonCHS include YouTube, Vimeo and Blogger. Crowdfunding Services allow users to fund a project, venture or cause within abounded system by raising small amounts of money from many individuals. Commoncrowdfunding services include GoFundme.com, Youcaring.com and Kickstarter.com. Internet Communication Services (ICS) allow two or multiple users to communicate inreal time over the internet normally in text but also in voice and video and withimages. Common ICS include WhatsApp, Instant Messenger, WeChat, and Snapchat.19.Cases provided as part of this report show individual terrorists, terrorist groupsand/or sympathizes are exploiting social media services to facilitate TF. The FATF in its 2015report recognised prominent vulnerabilities associated with social media services includinganonymity, access to a wider range and number of potential sponsors or sympathizers, and therelative ease with which some social media services may be integrated with payment methodsand services. The Regional Risk Assessment on Terrorism Financing in 2016 involving Southeast Asia and Australia also highlighted vulnerabilities associated with social media services andcrowdfunding services, including that these services are widely accessible at a low cost andhave global reach. Terrorists and their financiers mainly use social media services ascommunication channels to solicit funding. The volume of legitimate funding activity that occurson these platforms may also mask the small amount of illegitimate activity. Most onlineactivities are highly visible, and without sophisticated understanding of computing and use ofencryption tools, can leave a trail that can be used for successful prosecution.20.Input provided by APG and MENFATF member/observers echoed vulnerabilitiesidentified by the FATF. APG and MENAFATF member/observers noted the following primaryvulnerabilities: Internet and mobile phone penetration: Increased internet and mobile phone accessfacilitates greater abuse of social media services for TF. Ease of access: The ability to access social media services through multiple devices(e.g. via mobile phones, tablets, PCs, etc.) provides greater mobility and outreachcreating new challenges for combating terrorism and TF. Anonymity: Ease by which users may set up fictitious accounts to use social mediaservices; ability to make anonymous donations on crowdfunding sites. Encryption: The wide use of encryption mechanisms to secure messages andconversations, especially in ICS, provides terrorists/terrorist organizations withobscure channels to communicate and exchange financial data to conceal j.1083-6101.2007.00393.x/fullPage 6

transactions. This creates serious challenges for competent authorities in detectionand disruption of their activities. Immediate / real-time nature of user-generated content: Social media services allowusers to publish content immediately and/or communicate in real-time. Generation of funds: Some social media services allow users to generate incomethrough advertisements. Ease of modification: Most social media services data can be subject to alterations byusers or even complete removal in real-time. Some ICS even allow for self-destructmessages that can only last for a desired time limit, leaving no trail for tracking. Provision of propaganda tools: Most social media services provide means for sharingmultimedia contents (e.g. videos, photos, sound files, etc.), allowing terrorists/terrorist organizations to demonstrate power and influence potential sympathizers.21.While an in-depth analysis of integrated payment methods and services is outside thescope of this report, it is important to identify which social media services are currently usingNPP&S and some of the key vulnerabilities associated with these products and services.Currently the majority of SNS, CHS and ICS are not specifically designed to conduct financialtransactions; however, to varying degrees, particularly ICS, have begun to incorporate IPSand/or MPS. For example, WeChat Pay allows user to make mobile payments and send moneybetween contacts15, and WhatsApp has recently launched a peer-to-peer payment system inIndia16. In contrast, consistent with the nature of crowdfunding services, they use a variety ofTPS and IPS to raise funds such as payment by cards (debit, credit, and prepaid) and PayPal.22.The 2010 FATF Report on Money Laundering Using New Payment Methods andsubsequent FATF publications highlight some vulnerabilities of IPS and MPS that may facilitateabuse of social media services, particularly crowdfunding services, for TF. These include: Non-face-to-face relationships and anonymity: IPS and MPS may allow for non face-to-face business relationships, which without adequate customer identification andverification measures may impact on the service providers’ ability to identify theindividuals involved in transactions. Geographical reach: IPS and MPS may allow for global use for payments ortransferring funds. Furthermore, service providers may be located in a jurisdictionwith weaker AML/CFT controls. Methods of funding: IPS and MPS allow accounts and transactions to be funded in anumber of different ways with IPS and MPS that may allow funding through cash(through a network of agents) and third parties, which increases AML/CFT risks. Access to cash: IPS and MPS may allow cash withdrawals. Segmentation of services: IPS and MPS payments and transactions may be conductedvia and/or facilitated by multiple parties, which may be spread across cy-policy-5060367/1516Page 7

Part Two: Analysis of Cases in which Social Media Services wereabused for TF23.This section of the report examines the abuse of social media services for TF in the APGand MENAFATF regions through case studies. For each of the below subsections, the analysisfocuses on how social media services are used for TF and for each case study, a non-extensivelist of indicators (I) is identified. All indicators are included in a summary table in Appendix B.24.In addition to the abuse of social media services for TF, the case studies haveoverwhelmingly shown a trend in the misuse of social media services for terrorism purposes,which may be conducted concurrently with TF elements or standalone. For example, in somecase studies persons publicly pledged allegiance to terrorist organisations, and used socialmedia services for radicalization and the distribution ISIL propaganda. The full text of the casestudies related to abuse of social media services for terrorism are included in Appendix A of thisreport.2.1 Channels used for Terrorism Financing2.1.1 Social Networking Services (SNS)25.Case examples provided as part of this report show SNS are primarily used to call forfunding (see case 1 as an example) and/or to initially cast the net for potential sympathisers tosupport terrorist groups, individual terrorists or family members of the terrorists (see cases 2and 3 as examples). SNS were also abused by terrorists or sympathisers to promote theirdonation campaigns and to communicate with individuals located in the conflict zones. Thisfinding is consistent with previous research by the FATF and members of the Global Network,and consistent with the limited ability for payments or financial transactions to be made viaSNS. The large number

The Financial Action Task Force (FATF) in its 2015 report recognised social media services as susceptible to abuse for raising terrorist funds. . 1 FATF Report on Emerging Terrorist Financing Risks (2015) 2 Please see FATF Report on Money Laundering Using New Payment Methods (2010) for discussion on the risks associated with New Payment .

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