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FIU-the Netherlands

What a single crypto transaction can mean for an FIU-analysis

This case study, focusing on cryptocurrency transactions, shows how valuable an objective report can be.

Alongside analysing money laundering, analysing terrorist financing is one of FIU’s core tasks. We regularly share practical cases relating to money laundering, but you will hardly find any cases concerning terrorist financing on our website or LinkedIn page. This doesn’t mean there is nothing to report on terrorism financing. Neither does it mean there are no examples in which financial intelligence was a decisive piece of the puzzle, concerning investigations into terrorism financing. But these are delicate matters. To highlight the significance of this aspect of our work and especially the importance of reporting such cases, we are sharing a ‘composite’ case that combines several practical cases, in order to protect the privacy of those involved.

“The primary objective in this case was to determine whether the crypto wallet referred to in the report could be linked to a specific person,” says Rosemary. In addition to being an analyst in the field of terrorist financing, she also specialises in blockchain analysis. Using special tools, she can track transactions on the blockchain to establish links between transactions, wallet addresses and, ultimately, real people. “In this case, we quickly discovered with the help of the reporting cryptocurrency service provider that the wallet belonged to Mr R., who lives in the Netherlands.”

Terrorist financing?
Coincidentally, Mr R. had previously come to light in another FIU-analysis. “Therefore, we had reason enough to take a closer look at this new report,” says Rosemary. “The question then is: who owns the wallet to which Mr R. transferred his cryptocurrency, worth many thousands of euros? What do we see happening in the surrounding transactions? How are the wallets being fed and who is he in contact with?” It turns out that the crypto service provider has flagged the wallet that Mr R. transferred his crypto into. This means that the wallet is linked to possible abuses. The beneficiary of these funds appears to be someone who seems to be raising funds for a radical group, linked to terrorism.

Like-minded individuals
Does Mr R. then make himself guilty of terrorist financing or sanctions violations with his transfer? Rosemary: “To investigate that, we need to find out more about the destination of the money and the individuals involved. To do this, we look at financial flows, available police information, information from foreign FIU’s and open sources.”

Rosemary finds several indications that Mr R. sympathises with an internationally sanctioned terrorist organisation.

Valuable
The file contained sufficient indications of terrorist financing and possible violations of the sanctions law to warrant transferring it to the investigation services. This shows how valuable even those reports are that were only reported because a legal ‘threshold amount’ was exceeded, without the reporter having to assess whether anything suspicious was going on.