Terrorist financing involves the collection or provision of funds with the intention or knowledge that they will be used to support terrorist acts or organisations. Unlike money laundering, which typically involves concealing the origins of illicit funds, terrorist financing can involve both legal and illegal sources of money.
The UK’s National Risk Assessment of Money Laundering and Terrorist Financing has graded Terrorist Financing for Accountancy services as being low, in 2017, 2020 and 2025.
“We continue to judge that accountancy services are not attractive for terrorist financing, and there remains no evidence of these services being abused by terrorists. Therefore, the risk of terrorist financing through the sector is assessed to be low.”
Accountants are in a unique position of trust and access to financial systems. This makes them potential targets for misuse by individuals or entities seeking to finance terrorism. Under UK law, accountants have legal obligations to detect and report suspicious activity under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
An accountant noticed under-declared income and large cash deposits inconsistent with the business profile. Further investigation revealed links to overseas entities in high-risk jurisdictions. A SAR was filed, and authorities later uncovered a financing network tied to extremist groups.
A small charity approached an accountant for audit services. The charity received frequent donations from abroad and made large transfers to conflict zones. The accountant’s due diligence raised concerns, leading to a SAR. The charity was later found to be a front for funnelling funds to a terrorist organisation.
