“We see our adversaries as a business. It’s a business that produces fear, discord and chaos.”

Lt. Col. Joshua Potter, U.S. Special Operations Command (SOCOM), says that perspective is key to developing the interagency strategies needed to confront the growing threat of home-grown terrorism.

Today’s ACAMS opening session, “Rearming Compliance Policies to Fight New Forms of Threat Finance” focused on methods of identifying potential terror threats through financial monitoring. And that requires cooperation between agencies and the private sector.

As Joseph Lombardo, Office of the Sheriff, Las Vegas Metropolitan Police Department, noted during his day one keynote yesterday at ACAMS 2016, local law enforcement agencies play a crucial role in the current AML investigations landscape, but are often stretched for resources tracking down an ever-evolving scope of illicit activities.

Adam Drucker, FBI assistant section chief, described how terror financing has shifted in recent years with new breeds of bad actors taking advantage of traditional banking systems, money service businesses (MSBs) and virtual currencies. This is a shift from al Qaeda’s finance method – literally carrying “laundry bags of cash” to and from Afghanistan, etc.

Lt. Col. Joshua Potter, U.S. Special Operations Command (SOCOM) noted that as ISIL swept into the power vacuum in Iraq, bank robbery was a key method used to acquire cash quickly. Compound that with their reach on social media and ISIL was able to grow rather quickly, noted Celina Realuyo, senior fellow, Joint Special Operations University, MacDill Air Force Base, Fla.

Since 2013, ISIL’s command and control structures have suffered major setbacks, but Drucker stated the current strategy is to inspire small-scale, global attacks, like the Inland Empire shooting in San Bernardino, Calif.. While these attacks may seem random from outward appearances, he noted that there are exploitable financial patterns behind these events. After an attack, investigators try to pinpoint where the perpetrators banked, where they purchased supplies, and so on. And though they may use false documents or throwaway phone numbers, Drucker explained, there are still threads for investigators to follow.

As Lt. Col. Potter stated, terror groups can be viewed as a business. “It’s a bureaucracy, and bureaucracies leave trails.”

He added that these trails often lead to a broad web of illicit activities, including drug trafficking and organized crime syndicates. The key is to make sure that the financial sector and domestic law enforcement are connected to the intelligence that can help identify and track “small cell” bad actors. As Lt. Col. Potter added, this can’t be done with bombs and guns, it’s done with information.

As Realuyo described, the goal is to raise awareness in the private sector of the financial behaviors that can be indicative of a potential terror attack, such as end-of life account planning.

In many cases, Realuyo noted, the most effective method to confront illicit activity is to follow the “see something, say something” rule, which often means that the general public needs to be involved as well. She added that this was a key component in apprehending the suspect in the recent attacks in New York City, and it will continue to be a key component to confronting home-grown terror moving forward.

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