TSC Issue Brief COUNTERING TERRORIST FINANCING-Far Right Terrorism June .
ISSUE BRIEFCOUNTERING TERRORIST FINANCING:Lessons Learned for TacklingFar-Right TerrorismJUNE 2021thesoufancenter.orgKEY FINDINGS The establishment of the multilateralarchitecture to address terrorist financingwas focused on transnational jihadistgroups following the attacks of September11, 2001. In the two decades since, theprimary tool wielded for combatting thefinancing of terrorism (CFT) has been theapplication of targeted sanctions to freezeand block the assets associated withindividuals connected to designatedterrorist groups. New forms of terrorism and terroristfinancing have emerged, ranging frommicrofinancing to low-scale individualattacks, all of which are more difficult totrace as they exist outside of the formalfinancial system and formal terroristdesignations. An increase in violent far-right extremismand terrorism poses an escalating threat.Furthermore, violent far-right extremistgroups have been adept at diversifyingfunding sources, necessitating concertedinternational action. The divergence of definitions andapproaches adopted by states in counteringfar-right terrorism complicates the ability toconsistently apply counterterrorism andCFT measures. Therefore, coordination isrequired between states, the UN, and otherinternational actors to join in identifyingthe threat posed by violent far-rightextremist groups and strengthen the legaland policy measures to counter theirfinancing, using both existing and tailoredtools. Recommendations include: apply existingpolicy tools where possible to far-rightterrorist financing; adopt “ideologicallyagnostic” prevention programs; ensureadequate operational guidance; andincrease engagement between the UN andthe private sector.1
INTRODUCTIONIn a post-9/11 world, the interna onalcommunity has devoted signi cant a en onand resources to countering the nancing ofterrorist groups.1 For the most part, over thepast twenty years this a en on has focusedon curbing the nancial ac vi es of Sala jihadist groups like al-Qaeda and ISIS.2 Whilethe UN’s 1267 Sanc ons Commi ee wasfounded in 1999, its primary focus was theTaliban. It wasn’t un l a er al-Qaeda’s deadlya ack on September 11th did the UN 1267Commi ee rapidly expand the aperture bysanc oning al-Qaeda and associated en esin October 2001. The UN would also, in thewake of September 11th, adopt SecurityCouncil Resolu on 1373 on September 28,2001. UNSCR 1373’s aim, among otherthings, was to criminalize the funding ofterrorist acts and to encourage governmentsto freeze the assets of individuals and en esengaged in terrorist nancing.The UN would not be the only ins tu onwith wide remit to counter terroristnancing.3 The Financial Ac on Task Force(FATF), the premier intergovernmental bodythat develops policies to ght moneylaundering and terrorist nancing, also gotinto the ght against terrorist nance late.4Founded in 1989, FATF did not begin to focuson countering terrorist nancing un l a erSeptember 11th, but now the pendulum hasswung in the opposite direc on and many ofFATF’s focal areas target terrorist access tonance. Its forty recommenda ons provide abasis to guide states and interna onal actorsin implemen ng CFT measures against someuniform standards.5Like FATF, the Egmont Group, a coopera veen ty composed of Financial IntelligenceUnits (FIUs), was founded before September11th. In 1995, the Egmont Group had twentyfour members who primarily shared nancialintelligence related informa on pertaining toThis Issue Brief is part of a project examining the lessons learned from UN and interna onal counterterrorisme orts over the past two decades and their implica ons for interna onal e orts to address violent far rightextremism and terrorism, with a par cular focus on terrorism nancing and strategic communica ons andnarra ves. The Soufan Center is grateful to the German Mission to the United Na ons for suppor ng this project.1Clarke, Colin P. Terrorism, Inc: The Financing of Terrorism, Insurgency, and Warfare. Santa Barbara, California:Praeger, 2015.2Giraldo, Jeanne K., and Harold A. Trinkunas. Terrorism Financing and State Responses: a Compara ve Perspec ve.Edited by Jeanne K. Giraldo and Harold A. Trinkunas. Stanford, Calif: Stanford University Press, 2007;For theory and typology, see also: Freeman, Michael. Financing Terrorism: Case Studies. London, [England] :Routledge, 2016;For framing within interna onal rela ons literature, see also: Wi g, Timothy. Understanding Terrorist Finance.Houndmills: Palgrave Macmillan, 2011.3Jackson, James K. “The Financial Ac on Task Force: An Overview.” Congressional Research Service. March 23,2017. h ps://fas.org/sgp/crs/misc/RS21904.pdf.45 “Interna onal Standards on Comba ng Money Laundering and the Financing of Terrorism & Prolifera on.”Financial Ac on Task Force, October 2020. h ps://www.fa -ga .org/media/fa /documents/recommenda ons/pdfs/FATF%20Recommenda ititt2fffifiCOUNTERING TERRORIST FINANCING: LESSONS LEARNED FOR TACKLING FAR-RIGHT TERRORISM
organized crime endeavors. Since 9/11, theEgmont Group's rapid expansion to now 166member FIUs re ects the interna onalcommunity’s dedica on to counteringterrorist access to funding.been the primary tool wielded against theseactors. This is a logical outcome given that alQaeda, according to the 9/11 Commission,used the formal nancial system to moveapproximately 60% of the funding associatedwith the September 11th a ack.7 Whileterrorist groups, like criminal organiza ons,h ave a d j u ste d to t h e i nte r n a o n a lcommunity’s focus on following the moneyby using informal methods of raising andmoving nance, the use of the formalnancial system by bad actors remains veryimportant. In fact, the U.S. TreasuryDepartment’s most recent Terrorist AssetsReport (TAR) indicated that more than 50terrorist groups have had their funds blockedfrom moving within the U.S. formal nancialsystem.The pivot to counter terrorism nancing fromtradi onal forms of criminal group nancingand other types of threats, such asinsurgencies as represented by the Taliban,was a natural response to the deadliestterrorist a ack in modern history. That,coupled with the rise of the so-called IslamicState (ISIS) and its ability to acquire and holdterritory in Syria and Iraq that was equivalentin size to the United Kingdom, has resulted ina complex and arguably e ec veinterna onal system designed to counterterrorist access to nance, par cularlythrough the formal nancial system.6 Theinterna onal community’s central focusrelated to countering Sala -jihadist forms ofnancing has been the applica on oftargeted sanc ons. Indeed, the freezing andblocking of assets moving through the formalnancial system associated with individualsconnected to designated terrorist groups hasLarge scale a acks, like 9/11, inevitably a ectthe formal nancial system. More recently,however, low-scale self-directed a acks arechallenging domes c and interna onalresponses to terrorist nancing.8 Unlikeformal terrorist organiza ons, individuals,especially those without connec ons todesignated terrorist groups, have been ableFor more informa on on ISIS nancing, see: Johnston, Patrick B., Mona Alami, Colin P. Clarke, and Howard J.Shatz, “Return and Expand? The Finances and Prospects of the Islamic State A er the Caliphate.” RANDCorpora on, 2019. h ps://www.rand.org/pubs/research reports/RR3046.html;Clarke, Colin P., Kimberly Jackson, Patrick B. Johnston, Eric Robinson, and Howard J. Shatz, “Financial Futures of theIslamic State of Iraq and the Levant: Findings from a RAND Corpora on Workshop.” RAND Corpora on, 2017.h ps://www.rand.org/pubs/conf proceedings/CF361.html;Johnston, Patrick B., Jacob N. Shapiro, Howard J. Shatz, Benjamin Bahney, Danielle F. Jung, Patrick Ryan, andJonathan Wallace, “Founda ons of the Islamic State: Management, Money, and Terror in Iraq, 2005–2010.” RANDCorpora on, 2016. h ps://www.rand.org/pubs/research reports/RR1192.html.6Cid Gomez, Juan Migel del. “A Financial Prolife of the Terrorism of Al-Qaeda and its A liates.” Perspec ves onTerrorism 4, no. 4 (October 2010).7Harrell, Peter. “The Threat of Small-Dollar Terrorism.” Poli co. August 29, 2017. h ps://www.poli -dollar-terrorism-000503/;Kea nge, Tom. “Terror on the Cheap: Financing Lone Actor and Small Cell A acks.” RUSI. August 17, 2015. h ps://rusi.org/commentary/terror-cheap- nancing-lone-actor-and-small-cell-a acks;Ranstorp, Magnus. “Micro nancing the Caliphate: How the Islamic State Is Unlocking the Assets of EuropeanRecruits.” Comba ng Terrorism Center at West Point, November 16, 2017. h ps://ctc.usma.edu/micro iti3ttfififiCOUNTERING TERRORIST FINANCING: LESSONS LEARNED FOR TACKLING FAR-RIGHT TERRORISM
to nance and carry out their a acks withoutdetec on. Individuals, like Anders Breivik andBrenton Tarrant, have self- nanced theirdeadly a acks. In other cases, micronancing, especially the solicita on of smalldona ons, have become also common with abroad range of terrorist actors, to includeviolent right-wing extremist groups. Theseforms of fundraising, and associatedmovement, if any, within the formal nancialsystem present a challenge to interna onalbodies charged with curbing illicit nance.MULTILATERAL TOOLS TOCOUNTER THE FINANCINGOF TERRORISMThe “1267" sanc ons regime re ected thetransna onal nature of Al-Qaeda and ISIS; ittherefore represented a global consensusthat these groups, along with their a liates,posed a threat to interna onal peace andsecurity, making them under the purview ofthe Security Council. The establishment ofthe mul lateral ins tu onal architecture atthe UN to address terrorist nancingtherefore emerged from the impetus toaddress the threat posed by transna onaljihadist groups likely to move large scalefunds and resources across borders andnancial ins tu ons.10Moreover, trends are poin ng to violentright-wing actors becoming an ascendantt h r e a t . I n A p r i l 2 0 2 0 , t h e U N ’sCounterterrorism Execu ve Directorate(CTED) noted that there was a more than320% increase in violence associated withthe extreme far-right over the past veyears.9 As such, the interna onal communityshould con nue to expend more resources tocounter the nancing of the extreme farright. There are lessons in the ght against alQaeda and ISIS that are relevant to extremefar-right nancing, but given the di use andleaderless nature of the violent far-rightthreat, new policies and approaches arewarranted. This issue brief will explore theseissues as the interna onal community beginsits nascent ght against far-right terrorists.Consequently, en es like the 1267Sanc ons Monitoring Team, CTED, UnitedNa ons O ce on Drugs and Crime (UNODC),and the United Na ons Counter-TerrorismO ce (UNOCT) focused on ensuring thatstates developed the ins tu onal, legal, andpolicy frameworks necessary to counterterrorist nancing and, when possible,o ered targeted capacity-building support.While the 1267 regime is speci c to al-Qaedaand ISIS, the CFT obliga ons set out bySecurity Council Resolu on 1373, and severalsubsequent itera ons, and the UN’s GlobalCounterterrorism Strategy are not limited inapplica on to speci c groups or regions.9 Blazakis, Jason and Naureen Chowdhury Fink. “The Interna onal Far-Right Terrorist Threat Requires a Mul lateralResponse.” Lawfare, April 4, 2021. h ps://www.lawfareblog.com/interna onal-far-right-terrorist-threat-requiresmul lateral-response.“Tackling the Financing of Terrorism." United Na ons Counterterrorism Implementa on Task Force (New York:United Na on, 2009). h ps://www.un.org/counterterrorism/c /sites/www.un.org.counterterrorism.c / les/c nancing eng fifiCOUNTERING TERRORIST FINANCING: LESSONS LEARNED FOR TACKLING FAR-RIGHT TERRORISM
Although the ini al impetus of measures tocounter the nancing of terrorism targetedthe nancing of terrorist acts, the guidanceprovided by FATF and the recently adoptedSecurity Council Resolu on 246211 shi edthe focus on the nancing of terrorism morebroadly, recognizing that for groups thatneeded to fund personnel, accommoda on,materiel, communica ons, and travel, forexample, funding was fungible. Fundingterrorism need not therefore be related to ana ack, but to the maintenance of theterrorist organiza on more broadly. As aresult, interna onal CFT e orts have focusednot just on funding associated with terrorista acks, but funding that may be associatedwith the maintenance of terrorist networks inthe absence of a link to speci c a acks.Moreover, the increased prevalence in lowcost, low tech terrorist a acks perpetrated by“self-ac vated” or “self radicalized”individuals or small groups, with li le to nofo r m a l a s s o c i a o n w i t h a te r ro r i storganiza on, has increased the concerns ofgovernments and experts regarding thetraceability of small amounts of funds movedby individuals with no previous criminalrecord or footprint.The mul lateral system demonstrated bothcrea vity and responsiveness in developinglegal instruments to address evolvingterrorism nancing risks as they developed.When it became clear that ISIS wasnancially and materially bene ng fromthe tra cking of human beings and culturalheritage, for example, states adoptedSecurity Council Resolu on 2331 (2016). Thiscon rmed that individuals could bedesignated under the 1267 sanc ons regimefor using sexual violence or human tra ckingto raise funds for terrorism. This re ected therecogni on by states of the use of sexualviolence as a tac c of terrorism, and the useof human tra cking by groups like BokoHaram and ISIS to perpetuate sexual slaverya s a m e a n s o f re wa rd i n g g h te rs ,incen vizing foreign recruits and punishingcommuni es, such as the Yazidis.12Addi onally, Security Council Resolu on2347 (2017) highlights the poten al linkagesbetween the destruc on of cultural heritageand terrorism nancing broadly.13 Councilmembers condemned:any engagement in direct or indirect tradeinvolving ISIL, Al-Nusra Front (ANF) and allother individuals, groups, undertakings anden es associated with Al-Qaida, andreiterates that such engagement couldcons tute nancial support for en esdesignated by the 1267/1989/2253 ISIL(Da’esh) and Al-Qaida Sanc ons Commi eeand may lead to further lis ngs by theCommi ee.14While that sanc ons regime applies to twospeci c groups, the resolu on is broader in“UN Security Council Resolu on 2462: Threats to Interna onal Peace and Security.” UN Security Council, S/RES/2482 (19 July 2019), 16. h p://unscr.com/ les/2019/02482.pdf.11“Con ict-Related Sexual Violence." United Na ons: O ce of the Secretary General, 2017. h ps://www.un.org/sexualviolenceincon ict/wp-content/uploads/2020/07/report/con ict-related-sexual-violence-report-of-theunited-na ons-secretary-general/2019-SG-Report.pdf.12“UN Security Council Resolu on 2347: Maintenance of Interna onal Peace and Security." UN Security Council, S/RES/2347 (24 March 2017), 2. h titt5ttfiCOUNTERING TERRORIST FINANCING: LESSONS LEARNED FOR TACKLING FAR-RIGHT TERRORISM
its applica on, a rming that a acks on sitesand buildings dedicated to religion,educa on, art, science, charitable purposes,or historic monuments may cons tute warcrimes under certain circumstances.15Moreover, the Security Council urged statesto introduce e ec ve na onal measures atthe legisla ve and opera onal levels toprevent and counter tra cking in culturalproperty and related o enses.16 Despite theimportant linkage made here betweendestruc on of cultural heritage andterrorism, this remains a largely underu lized instrument to address terrorismnancing and support.environmental crime and illicit armstra cking.17In addi on to the FATF, the Global CounterTerrorism Forum is also working on the issueof Racially and Ethnically Mo vatedTerrorism, and the Interna onal Ins tute forJus ce in Malta, a “GCTF-inspired ins tu on”has also begun to put together trainingworkshops and support to states on thisissue.In his report on implementa on of the UNGlobal Counter-Terrorism Strategy, theSecretary-General also noted that:The transna onal threat from racially,ethnically or ideologically mo vatedindividuals and groups resor ng to terroristtac cs, variously described as “whitesupremacist,” “far right” or “extreme rightwing” has also increased. These groups havesought to capitalize on the COVID-19response in order to increase and diversifytheir support base, including by accelera ngpre-exis ng trends of social polariza on andcultural manipula on.18As more states confront the emerging violentfar-right threat – or racially and ethnicallymo vated – extremism and terrorism, it willbe important to consider if and how themul lateral instruments to counter terroristnancing might be applicable. Responding toincreased concerns voiced by states,mul lateral actors have begun to shitowards a focus on violent far-right threats.For example, in assuming the Presidency ofthe Financial Ac on Task Force for2021-2022, Germany set out a number ofstrategic priori es, including:In concluding his report, the SecretaryGeneral asks states to a rm the role of theUnited Na ons in suppor ng states toaddress this threat. However, as describedabove, there are a number ofcounterterrorism resolu ons and measuresthat can be applied to addressing mul pleforms of terrorism, which could be applied to work to tackle some of the great challengesfacing socie es around the world includingthe opportuni es that new technology o ersto strengthen AML/CFT systems throughdigital transforma on; ethnically or raciallymo vated terrorism; migrant smuggling;“UN Security Council Resolu on 2347: Maintenance of Interna onal Peace and Security." UN Security Council, S/RES/2347 (24 March 2017), 4. h %29.15“UN Security Council Resolu on 2347: Maintenance of Interna onal Peace and Security." UN Security Council, S/RES/2347 (24 March 2017), 8-9. h %29.16Pleyer, Marcus. “Priori es for the Financial Ac on Task Force (FATF) Under the German Presidency.” FinancialAc on Task Force, 2020. h ps://www.fa -ga .org/media/fa /documents/German-Presidency-Priori es.pdf.17“Ac vi es of the United Na ons System in Implemen ng the United Na ons Global Counter-Terrorism Strategy.”United Na ons General Assembly, A/25/729 (29 January 2021), 10. h titititititiffititititi6tififiCOUNTERING TERRORIST FINANCING: LESSONS LEARNED FOR TACKLING FAR-RIGHT TERRORISM
strengthening interna onal legal andprac cal coopera on to counter terroristnancing.19stability. This consensus resulted in hundredsof new lis ngs of individuals and groupsbeing designated at the UN’s 1267C o m m i e e . T h e FAT F a d o pte d n ewrecommenda ons, some of which focus onterrorism nancing for the rst me. And, ofcourse FIUs across the globe were able to usethe Egmont informa on portal to shareac onable nancial intelligence related togroups like al-Qaeda. This interna onalmomentum based on consensus also createdmomentum for countries to develop theirown counterterrorism nancing measures –something countries were clearly reluctant tod o u n i l a t e ra l l y p r e - 9 / 1 1 . D o m e s capproaches alone, especially when trying tocounter transna onal groups that carry outac vi es that defy borders, to includenancing, are inherently limited. Thus,mul lateral approaches will be invaluable tocountering transna onal far-right terroristgroups.LESSONS LEARNEDDespite the widespread interna onalinvestment in countering terrorist nancingglobally, iden fying what has worked, or notworked, in the past can be challenging. AsCFT expert Jessica Davis noted at a May 2021webinar organized by The Soufan Center,“We haven’t even really se led the debateabout what CFT is supposed to do. Is itsupposed to stop the ow of funds toterrorist groups, which is a pre y vagueobjec ve, or is it meant to reduce terrorismglobally, which is a pre y big set of objec vesfor a rather narrow set of ac vi es?” Theanswers ma er because they determine howwe measure progress. However, drawing onthe experiences over the past two decades, afew ini al insights emerge.Historically, even groups that may have aprimary base of opera ons, like theProvisional Irish Republican Army (PIRA),required external nancing. In the case of thePIRA, a key source of nancing came from aU.S. based non-pro t organiza on known asNorthern Irish Aid (NORAID).20 NORAIDaggregated small dona ons from U.S.-basedIrish ex-pats and funneled the proceeds tothe PIRA. Ul mately, because of bilateralcoopera on between UK law enforcementand the U.S. Federal Bureau of Inves ga on(FBI) this channel of PIRA nance dried up.Mutual coopera on between lawenforcement agencies in the ght against theOne key lesson learned in the wake ofSeptember 11th is that the most e ec ve wayto counter a transna onal group’s access tonance is by taking a mul lateral approach.As noted in the introduc on, the UN, FATF,and the Egmont Group all became morefocused on countering terrorism nancepost-9/11. In September 11th’s a ermath theinterna onal community was able to achieve,brie y, consensus regarding the threat alQaeda posed to interna onal peace and“Ac vi es of the United Na ons System in Implemen ng the United Na ons Global Counter-Terrorism Strategy.”United Na ons General Assembly, A/25/729, (29 January 2021), 77. h /00/PDF/N2102400.pdf?OpenElement.19Clarke, Colin P. “Countering Provisional Irish Republican Army (PIRA) Financing and Comba ng the Ability ofInsurgents to Raise Funds Through Crime in Northern Ireland” in Lawrence Cline and Paul Shemella, eds., TheFuture of Counterinsurgency: Contemporary Debates in Internal Security Strategy, Santa Barbara, Calif.: iCOUNTERING TERRORIST FINANCING: LESSONS LEARNED FOR TACKLING FAR-RIGHT TERRORISM
COUNTERING TERRORIST FINANCING: LESSONS LEARNED FOR TACKLING FAR-RIGHT TERRORISMviolent far-right will be paramount, especiallysince the broader interna onal community,such as the UN and FATF, have providedlimited or no guidance to member statesregarding the nancing threat associatedwith the extreme far-right. For example, theU.S. based Atomwa en Division (AWD) hasinspired spin-o s throughout the globe.21 AsU.S. based AWD members communicate,coordinate, and synchronize ac ons withoverseas counterparts, it will be cri cal forlaw enforcement agencies to shareinforma on with each other regarding AWD’sfuture plans.donors from providing funding to listedterrorists because of the fear of becoming aninterna onal pariah and blocked from theinterna onal nancial system. Thus,sanc ons may raise the stakes in terms of thecost-bene t analysis a prospec ve nanciermay carry out as they consider ge nginvolved in terrorism.There is no interna onal agreed uponde ni on of terrorism, although the closestachieved through the UN is in SecurityCouncil Resolu on 1566.22 Despite this, theUN, especially through the auspices of thelis ngs carried out pursuant to the UN 1267Commi ee, has prac cally de ned themodern manifesta ons of terrorism. In lis ngal-Qaeda and ISIS-linked individuals anden es, the United Na ons has created acommon basis for member-states to ac onagainst an important subset of terrorists. Ofcourse, applying the UN 1267 regime toother types of violent actors that could bede ned as terrorists will be very di cult. Yet,it is a conversa on that should be held at thehighest levels, par cularly given the markedincrease in extreme far-right violence ashighlighted by CTED.Despite the broad array of unilateral andmul lateral sanc ons imposed againstgroups like al-Qaeda, the organiza onremains a threat to the interna onalcommunity. While the al-Qaeda core grouphas strained under the nancial pressureplaced upon it by the interna onalcommunity and is unlikely able to providesigni cant seed funding for the types ofopera onal ac vi es the group is best knownfor, al-Qaeda’s a liates in Somalia, NorthAfrica, and Yemen s ll operate with rela veimpunity. Moreover, there have beenprac cal impacts because of the sanc onslevied against al-Qaeda. For instance, in theUnited States, according to the latestTreasury TAR, nearly 4 million in al-Qaedafunds are blocked in the U.S. formal nancialsystem. While impossible to measure, it isalso likely that sanc ons against groups andindividuals have deterred poten al bigNonetheless, sanc ons should not be seen asa panacea. Groups listed at the UN 1267commi ee have been adept, for instance, bychanging their names as a way to bypass theconsequences of a UN lis ng. For example,Jabhat al-Nusrah has changed its name onmul ple occasions to both circumscribe the“The Atomwa en Division: The Evolu on of the White Supremacy Threat.” The Soufan Center, August 2020,h 8/The-Atomwa en-Division-The-Evolu 1“UN Security Council Resolu on 1566: Threats to Interna onal Peace and Security Caused by Terrorist Acts.” UNSecurity Council, S/RES/1566 (8 October 2004), 3. h ps://www.un.org/ruleo aw/ les/n0454282.pdf;For more informa on on issues of de ning terrorism, see: Ho man, Bruce. Inside Terrorism. New York, NY:Columbia University Press, tititifffitititttitttititifititititifitifititt8
COUNTERING TERRORIST FINANCING: LESSONS LEARNED FOR TACKLING FAR-RIGHT TERRORISMwill of the interna onal community and toalso endear itself with local popula ons.23We have learned also about nega ve impactsof CFT and sanc ons measures, such as thei m p o r ta n c e o f d u e p ro c e s s i n t h edesigna ons system and mi ga ng nega vee ects on principled humanitarian ac on andcivil society. There has been greatins tu onal innova on, as sanc ons expertSue Eckert noted at The Soufan Center’s May2 0 2 1 we b i n a r. S h e h i g h l i g hte d t h eestablishment of the Ombudsperson’s o ceand appeals process for 1267 sanc ons,allowing designated individuals to challengetheir lis ng or appeal for relief measures.24This was a response to interna onal concernsabout the poten al for human rightsviola ons and due process concernsregarding the designa on mechanism andthe lack of an appeals process.25 Moreover,the adop on of Security Council Resolu on2462 on terrorism nancing re ected agreater acknowledgement thatcounterterrorism e orts should not harmlegi mate humanitarian ac on; this wasrea rmed soon a erwards in Resolu on2482 in the UN system.26While these ini al steps do not whollyaddress the tensions betweencounterterrorism and humanitarian ac ons,they are posi ve ini al steps, and lay thegroundwork for dialogue and capacitybuilding e orts bringing together keystakeholders in government, the privatesector and civil society. These adapta onsprovide some important lessons and modelsfor other states to consider. In the UK, the“Tri-Sector Working Group” is one example,and the Global Counter-Terrorism Forum’sini a ve on Ensuring Implementa on ofCountering the Financing of TerrorismMeasures While Safeguarding Civic Space isanother. These are important lessons learnedthat should shape the applica on of futureCFT e orts, building in stronger due processconsidera ons and transparency to boost thelegi macy of any sanc ons or designa onsprocess, and ensuring they complementbroader strategic objec ves like ensuring safee nv i ro n m e nt s fo r c i v i l s o c i e t y a n dhumanitarian actors.FAR-RIGHT FUNDRAISINGAs discussed in The Soufan Center's 2019report on White Supremacy Extremism,27 theviolent far-right has been adept atdiversifying its sources of nance. Forexample, violent far-right extremists haveClarke, Colin P. “Al-Qaeda Can Change its Name, but Not its Stripes.” The Cipher Brief, March 23, 2017. h ps://www.thecipherbrief.com/ar ame-but-not-its-stripes.23“Financing Terrorism: Lessons Learned for Tackling Violent Far-Right Groups.” The Soufan Center, May 18, 2021.h ps://thesoufancenter.org/ lent-far-right-groups/.24Fromuth, Peter. “The European Court of Jus ce Kadi Decision and the Future of UN Counterterrorism Sanc ons.”American Society of Interna onal Law 13, no. 20: (October 2009). h pean-court-jus “UN Security Council Resolu on 2482: Threats to Interna onal Peace and Security.” UN Security Council, S/RES/2482 (19 July 2019), 16. h p://unscr.com/ les/2019/02482.pdf.26“White Supremacy Extremism: The Transna onal Rise of the White Supremacist Movement.” The Soufan Center,September 2019. h extremism-the-transna ifftititititititifftititiffitifftt9
raised nance through music labels and
COUNTERING TERRORIST FINANCING: LESSONS LEARNED FOR TACKLING FAR-RIGHT TERRORISM In a post-9/11 world, the internaWonal community has devoted significant aYenWon and resources to countering the financing of terrorist groups.1 For the most part, over the past twenty years this aYenWon has focused
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Andreas Wagner†‡ Historically, one of the most controversial aspects of Darwinian evolution has been the prominent role that randomness and random change play in it. Most biologists agree that mutations in DNA have random effects on fitness. However, fitness is a highly simplified scalar representation of an enormously complex phenotype .
