Greatest risks of terrorist financing identified

Acquiring and/or disbursing funds through Dutch foundations or other legal entities is among the 12 greatest risks of terrorist financing. This is evident from the second National Risk Assessment (NRA) on Terrorism Financing, which was submitted to the House of Representatives on September 11th. This is a key consideration for notaries when establishing foundations, particularly charities.

The 2nd NRA on Terrorism Financing identifies the 12 greatest risks related to terrorist financing. The focus is on terrorist financing risks that could arise in the Netherlands and that Dutch policy could address, although many methods of terrorist financing also (can) have an international element. In 2017, the Research and Documentation Centre (WODC) of the Ministry of Justice and Security conducted the 1st NRA on Terrorism Financing .

Charities
One of the greatest risks of terrorist financing is acquisition and/or financing through Dutch charitable, religious, and/or educational foundations or other legal entities. According to the National Coordinator for Counterterrorism and Security (NCTV), various foundations systematically organize projects to collect donations for those in need in the Netherlands and in conflict zones abroad where jihadist groups are active, such as Syria, Afghanistan, and Somalia. These are foundations active within online Salafist communities and on social media channels where jihadism is propagated. As an example, a case is cited in which a traveler established a dozen so-called "charity" foundations and solicited funds on Islamic forums for purposes such as aid campaigns for Syria, Afghanistan, orphans, toys, wells, or nurses.

Effectiveness
The 2nd NRA on Terrorism Financing also maps the effectiveness of existing measures to prevent and combat terrorist financing. Minister of Finance Wopke Hoekstra, on behalf of Minister of Justice and Security Ferd Grapperhaus, writes that the researchers conclude that the risks are significantly mitigated by the preventive and repressive measures already available. Furthermore, the researchers share their expectation that recently introduced instruments will further mitigate the risks.

NRA Money Laundering
In July, the second NRA on Money Laundering was submitted to the House of Representatives. It identified the 15 greatest money laundering risks. Various money laundering risks can arise in notarial practice, such as laundering through ABC transactions, legal structures, loan-back arrangements, and the use of intermediaries.