Financial institutions should also refer to the red flags and other information provided in this an d the May 2015 non-public advisory to formulate a more comprehensive assessment of potential suspicious activity.
Depending on their products and services offered, financial institutions may be able to observe one or more of the following red flags.
With respect to publicly available information, for instance, ISIL and other terrorist organizations are known to be active on social media sites.
Financial institutions may find available social media information helpful in evaluating potential suspicious activity and in identifying risks connected to the red flags provided in this and other advisories.
This advisory is not intended to call into question financial institutions’ maintenance of normal relationships with other financial institutions, or to be used as basis for engaging in wholesale or indiscriminate de-risking practices. Activity Possibly Associated With FTFs Once recruited, FTFs seek to travel to areas where ISIL, al-Qa’ida, and their affiliates operate, such as Iraq and the Levant region.
Accordingly, financial activity of FTFs may reflect transactions related to their travel preparations and arrangements, departure, in-transit period, and arrival and presence in the conflict zone.
Similarly, the location from which a customer logs into a financial institution’s online services platform may also be considered when determining whether a transaction is suspicious (see next section). In applying the red flags below, financial institutions are advised that no single transactional red flag is a clear indicator of terrorist activity.
Financial institutions should consider additional factors, such as a customer’s overall financial activity and whether he or she exhibits multiple red flags, before determining a possible association to terrorist financing and FTFs.