USA Terrorist Financing As A Financial Crime: A Case Study

The USA terrorist financing as a financial crime. The United States has many laws specifically designed to criminalize terrorist financing. Under 18 U.S.C. §§ 2339A–C (Titled Providing Material Support To terrorists) and 21 U.S.C. § 960a (Titled Foreign Terrorist Organizations, Terrorist Persons and Groups), it is a crime in the United States to fund any terrorist activity. Indeed, the statute makes it illegal for anyone to even attempt to give anything of value to anyone who has committed a terrorist act or intends to commit a terrorist act.

A Case Study: USA Terrorist Financing As A Financial Crime

The laws against terrorist financing in the USA have not only targeted individuals but organizations as well. Even registered charities such as the Benevolence International Foundation, the Holy Land Foundation for Relief and Development, the Islamic American Relief Agency (self-described as the U.S. affiliate of the Islamic African Relief Agency), the Child Foundation, the Tamils Rehabilitation Organization, and Care International have been prosecuted for financing terrorism by the United States department of Justice.

Several companies have also faced criminal charges for terrorist financing. Quite infamously, InfoCom Corporation was indicted along with its directors for dealing with Mousa Abu Marzook, a Hamas political leader who was deemed a Special Designated Terrorist (SDT) by the Federal Bureau of Investigation (FBI). United States companies are required by law not to process payments that finance terrorism such as those to SDTs.

Terrorism And Financial Intelligence

Terrorism and Financial Intelligence develops and implements U.S. government strategies to combat terrorist financing domestically and internationally, and develops and implements the National Money Laundering Strategy as well as other policies and programs to fight financial crimes.


The Office of Terrorism and Financial Intelligence (TFI) marshals the department’s intelligence and enforcement functions with the twin aims of safeguarding the financial system against illicit use and combating rogue nations, terrorist facilitators, weapons of mass destruction (WMD) proliferators, money launderers, drug kingpins, and other national security threats.


Headed by an Under Secretary, the Office of Terrorism and Financial Intelligence (TFI) marshals the Treasury Department’s policy, enforcement, regulatory, and intelligence functions to sever the lines of financial support to international terrorists, WMD proliferators, narcotics traffickers, money launderers, and other threats to our national security.

Two components of TFI are led by Assistant Secretaries. The Office of Terrorist Financing and Financial Crimes (TFFC), is the policy and outreach apparatus for TFI.  The Office of Intelligence and Analysis (OIA) is responsible for TFI’s intelligence functions, integrating the Treasury Department into the larger intelligence community (IC), and providing support to both Treasury leadership and the IC. 

TFI also oversees several component offices and bureaus. The Office of Foreign Assets Control (OFAC) administers and enforces economic and trade sanctions. The Treasury Executive Office for Asset Forfeiture (TEOAF) administers the Treasury Forfeiture Fund (TFF), which is the receipt account for the deposit of non-tax forfeitures.

Responsible for administering the Bank Secrecy Act (BSA) and other regulatory functions is one of Treasury’s bureaus, the Financial Crimes Enforcement Network (FinCEN), which supports law enforcement investigative efforts and fosters interagency and global cooperation against domestic and international financial crimes. It also provides U.S. policy makers with strategic analyses of domestic and worldwide trends and patterns. The director of FinCEN reports directly to the Under Secretary. TFI also works in close partnership with the IRS Criminal Investigative Division (IRS-CI) to enforce laws against terrorist financing and money laundering, including the Bank Secrecy Act.

Final Thoughts

Stopping terrorists’ ability to finance their operations is a critical component of the United States’ counterterrorism strategy. To that end, the Administration has implemented a three-tiered approach based on (1) intelligence and domestic legal and regulatory efforts; (2) technical assistance to provide capacity-building programs for US allies; and (3) global efforts to create international norms and guidelines. The effective implementation of this strategy necessitates the participation and coordination of several elements of the United States. Government. This report provides an agency-by-agency survey of the United States’ efforts. This report will be updated as new information becomes available.

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